DAQ-2024-004312

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DAQC-1319-23
Site IDs: 11281 and 11486 (B1)

MEMORANDUM

TO: FILE – ICON HEALTH AND FITNESS

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: December 7, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Cache County

INSPECTION DATE: July 12, 2023

SOURCE LOCATION: 1500 South 1000 West, Logan

DIRECTIONS: The office is located on the northwest end of the east
building.

SOURCE CONTACT: Todd Slade, Safety and Environmental Director:
(435)-750-5000 X5122, (435)-757-9705 (Cell);
[e-mail]

OPERATING STATUS: Operating.

PROCESS DESCRIPTION: ICON manufactures and distributes replacement parts for
treadmills which are now manufactured in Georgia and
California. ICON still utilizes four injection molding
machines to make different sizes of replacement plastic parts
for the treadmills. The plastic beads arrive by truck. The
plastic injection molder sucks the beads to be melted. The
molten liquid is poured in a mold. The plastic parts are
molded by extrusion machines. A non-contact cooling tower
water cools the injection molders.

If the plastic part requires painting, it is transferred to the
painting booth which is equipped with filters. The
water-based paints are applied using airless applicators. The
painted parts then go through a pre-heat oven, then through a
curing oven, both operating at 160 degrees Fahrenheit.

The natural gas-fired furnace supplies heat for the building.
The wall vents and fans are the only outlets for emissions
from the room.

APPLICABLE REGULATIONS: AO DAQE-338-95, dated April 21, 1995

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SOURCE EVALUATION:

Condition 1. This AO applies to the following company:

ProForm Fitness Products, Inc.
1500 South 1000 West
Logan, Utah 84321-0270

Telephone Number: [phone]
Fax Number: [phone]

ICON HEALTH AND FITNESS

Telephone Number: [phone]
Fax Number: [phone]

The equipment listed below in this AO shall be operated at the following location:

PLANT LOCATION:

Universal Transverse Mercator (UTM) Coordinate System:
4,620,150 meters Northing, 428,750 meters Easting

Status: In Compliance. The company is now known as iFIT Health and Fitness. The
telephone and fax numbers have been updated.

Condition 2. Definitions of terms, abbreviations, and references used in this AO conform to those used
in the UACR, Utah Administrative Codes (UAC), and Series 40 of the Code of Federal
Regulations (40 CFR). These definitions take precedence unless specifically defined
otherwise herein.

Status: Not a compliance item. A statement of fact.

Condition 3. ProForm Fitness Products, Inc. shall install and operate a plant that manufactures fitness
equipment according to the information submitted in the Notice of Intent dated
September 26, 1994, and additional information submitted to the Executive Secretary
dated October 21, 1994, and January 20, 1995.

Status: In Compliance. The source no longer manufactures treadmills at this
location. Consequently, most of the processing equipment has been removed from
this location.

Condition 4. A copy of this AO shall be posted on site. The AO shall be available to the employees
who operate the air emission producing equipment. These employees shall receive
instruction as to their responsibilities in operating the equipment according to all of the
relevant conditions listed below.

Status: In Compliance. A copy of the AO is posted and available for all employees to
view.

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Condition 5. The approved installations shall consist of the following equipment (MMBTU/HR stands
for million BTUs per hour):

i) One direct fired furnace rated at 4.95 MMBTU/HR (Manufactured by Lennox)
ii) One powder coat operation, with a stage one furnace rated at 7.00 MMBTU/HR
and a stage three furnace rated at 1.50 MMBTU/HR (Manufactured by Eclipse)
iii) One enclosed vacuum paint powder collection system which does not vent
directly outside the building
iv) One curing oven rated at 4.80 MMBTU/HR (Manufactured by Eclipse)
v) One burn off furnace rated at 0.30 MMBTU/HR
vi) Two water heaters, each rated at 0.155 MMBTU/HR
vii) Other equipment that produce negligible or no air emissions

Status: Not in Compliance. Two unpermitted generators were viewed during the
inspection. One natural gas-fired generator rated at 140kW to back up the
computer systems. One natural gas-fired generator rated at 30kW for emergency
lighting.

The above listed equipment is still located onsite with the following exceptions:

i. The direct fire furnace is actually 2 MMBtu/hr, not 4.95.
ii. No longer used.
iii. No longer used.
iv. The cure oven is 1 MMBtu/hr.
v. No longer used.
vi. Still used.
vii. Also, on site was a pre-heat oven rated at 2.5 MMBtu/hr.

Condition 6. Emissions to the atmosphere from the indicated emission point shall not exceed the
following rates and concentrations:

Source: Stack of the stage one furnace in the powder coating operation, which is rated at
7.00 MMBTU/HR

Pollutant ppmdv
(3% O2 dry)
NOx .................................. 79.15

Status: Compliance determination not made. The source has not been directed to
perform stack testing.

Condition 7. Stack testing to show compliance with the emission limitations stated in the above
condition shall be performed as specified below:

A. Emission Testing Test
Point Pollutant Status Frequency
Furnace Stack in
Condition #6 NOx .................. * ....................... @

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B. Testing Status
* No initial testing is required. However, the Executive Secretary may
require testing at any time in accordance with R307-1-3.4.1, UAC. The
source shall be tested if directed by the Executive Secretary.
@ Test if directed by the Executive Secretary. Tests may be required if the
source is suspected to be in violation with other conditions of this AO.

C. Notification
The applicant shall provide a notification of the test date at least 45 days before
the test. A pretest conference shall be held if directed by the Executive Secretary.
It shall be held at least 30 days before the test between the owner/operator, the
tester, and the Executive Secretary. The emission point shall be designed to
conform to the requirements of 40 CFR 60, Appendix A, Method 1, and
Occupational Safety and Health Administration (OSHA) or Mine Safety and
Health Administration (MSHA) approved access shall be provided to the test
location.

D. Sample Location
40 CFR 60. Appendix A, Method 1

E. Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2

F. Nitrogen Oxides (NOx)
40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D or 7E

G. Existing Source Operation
For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

Status: Compliance determination not made. The source has not been directed to
perform stack testing.

Condition 8. Visible emissions from any point or fugitive emission source in the plant shall not exceed
10% opacity. Opacity observations of emissions from stationary sources shall be
conducted in accordance with 40 CFR 60, Appendix A, Method 9.

Status: In Compliance. No visible emissions from any point or fugitive source were
observed.

Condition 9. The following limits shall not be exceeded without prior approval in accordance with
R307-1-3.1, UAC:

80,000 Decatherms of natural gas usage plant-wide per 12-month period;

Compliance with the annual limitations shall be determined on a rolling 12-month total.
The owner/operator shall calculate a new 12-month total based on the first day of each
month using data from the previous 12 months. Records of consumption/production shall
be kept for all periods when the plant is in operation. Records of
consumption/production, including rolling 12-month totals, shall be made available to the
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Executive Secretary or his representative upon request, and shall include a period of two
years ending with the date of the request. The records shall be kept on a monthly basis.
Natural gas consumption shall be determined by examination of monthly natural gas
billing statements which shall be maintained and produced to the Executive Secretary or
his representative upon request as described above.

Status: In Compliance. The rolling 12-month consumption totals from July 2022 –
June 2023, was 15,180 decatherms. Billing records are maintained and used to
calculate total natural gas usage.

Condition 10. 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 R307-1-3.1, UAC.

Status: In Compliance. Only natural gas is used. The source provided invoices
during the inspection from Dominion Energy.

Condition 11. All installations and facilities authorized by this AO shall be adequately and properly
maintained. All pollution control vendor recommended equipment shall be installed,
maintained, and operated. Instructions from the vendor or established maintenance
practices that maximize pollution control shall be used. All necessary equipment control
and operating devices shall be installed and operated properly and easily accessible to
compliance inspectors. A copy of all manufacturers' operating instructions for pollution
control equipment and pollution emitting equipment shall be kept on site. These
instructions shall be available to all employees who operate the equipment and shall be
made available to compliance inspectors upon their request.

Status: In Compliance. The source indicated that the coatings are water-based and
are applied using an airless spray applicator. The paint booth is equipped with
filters which according to the source are replaced every six months when the plant is
not in full production mode and weekly when the plant is in full production. No
painting activity was in progress during the inspection. All paint equipment is
washed in a trough, and the wastewater goes through a six-stage water separator
which separates the water from the sludge. The water empties into a drain, and the
sludge is collected for off-site disposal.

Condition 12. The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses
unavoidable breakdown reporting requirements. The owner/operator shall
calculate/estimate the excess emissions whenever a breakdown occurs. The total of
excess emissions shall be reported to the Executive Secretary as directed for each
calendar year.

Status: In Compliance. The source indicated that no breakdowns have occurred
since the previous inspection.

AREA SOURCE RULES

Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No fugitive emissions or dust were observed during the inspection. The area
is fully paved.
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EMISSION INVENTORY: Not required at this time. The engineering review from the AO dated
April 21, 1995 reported the following potential to emit in tons/year:

PM10: 0.48
SO2: 0.03
NOX: 4.00
CO: 0.84
VOC: 0.15

PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS
RECOMMENDATIONS: Not in Compliance with the conditions of AO DAQE-338-95.
iFIT Health and Fitness installed and operates two unpermitted
natural gas-fired emergency generators. A compliance advisory
was issued on August 10, 2023 (DAQC-824-23). The source
responded to the Compliance Advisory on October 11, 2023, and
a permit revocation was issued (DAQE-GN112810001-23). A no
further action letter was submitted to resolve the advisory
(DAQC-1308-23).

RECOMMENDATION FOR
NEXT INSPECTION: A permit revocation was issued for the site after the source
applied for a small source exemption to resolve the Compliance
Advisory. It was determined by NSR that this site has multiple
site IDs (11486 and 11281). Refer to both site IDs and the
attached NSR memorandum (DAQE-MN112810001-23) if
reviewing records.

ATTACHMENTS: Compliance Advisory (DAQC-824-23), No Further Action
Letter (DAQC-1308-23), Permit Revocation Letter
(DAQE-GN112810001-23), NSR Memorandum
(DAQE-MN112810001-23)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-824-23
Site ID 11486 (B1)

Sent Via Certified Mail No. 70190700000208347525

Todd Slade
iFIT Health and Fitness Inc.
1500 South 1000 West
Logan, Utah 84321

Dear Mr. Slade,

Re: Compliance Advisory – iFIT Health and Fitness Inc. (FKA Icon Health and Fitness), Approval
Order (AO) DAQE-338-95, dated April 21, 1995, Utah Administrative Code (UAC) R307-
401, Cache County

On July 12, 2023, a representative of the Utah Division of Air Quality (DAQ) conducted a full
compliance inspection of iFIT Health and Fitness Inc. (iFIT) in Logan, Utah. The DAQ observed the
installation and operation of two emergency generators which may be in violation of Condition 5 of
the AO and UAC R307-401-5 for operating unpermitted equipment and a failure to submit a Notice of
Intent (NOI).

iFIT is required to comply with the above regulations. A written response to this letter is required
within ten (10) business days of receipt of this letter.

Additional details about the above observations and regulations are attached to this letter. Please
contact Connor Kijowski at 385-245-6720 or [e-mail] if you have any questions about this
letter.

Sincerely,

Chad Gilgen, Manager
Minor Source Compliance Section

CG:CK:km

cc: Bear River Health Department
Alan Humpherys, UDAQ, Minor NSR Section Manager
August 10, 2023
DAQC-824-23
Page 2

Potential Violations
On July 12, 2023, an inspector from the DAQ observed iFIT at 1500 South 1000 West in Cache
County, Utah.

At the time of the inspection the DAQ documented the following potential violation s:

• Condition 5 of AO DAQE-338-95

iFIT installed and operates additional generators not listed on the current AO. One 140kW
generator used to back up computer systems and one 30kW generator for emergency lighting.

• Utah Administrative Code R307-401-5

iFIT failed to submit a NOI to install and operate two additional emergency generators.

AO Conditions/Rules
AO DAQE-338-95, dated April 21, 1995

Condition 5:
The approved installations shall consist of the following equipment (MMBTU/HR stands
for million BTUs per hour):
i) One direct fired furnace rated at 4.95 MMBTU/HR (Manufactured by Lennox)
ii) One powder coat operation, with a stage one furnace rated at 7.00 MMBTU/HR
and a stage three furnace rated at 1.50 MMBTU/HR (Manufactured by Eclipse)
iii) One enclosed vacuum paint powder collection system which does not vent
directly outside the building
iv) One curing oven rated at 4.80 MMBTU/HR (Manufactured by Eclipse)
v) One burn off furnace rated at 0.30 MMBTU/HR
vi) Two water heaters, each rated at 0.155 MMBTU/HR
vii) Other equipment that produce negligible or no air emissions

Utah Administrative Code R307-401. Permit: New and Modified Sources

UAC R307-401-5:
(1) Except as provided in Sections R307-401-9 through R307-401-17, any person subject to Rule
R307-401 shall submit a notice of intent to the director and receive an approval order precedent
to the construction, modification, installation, establishment, or relocation of an air pollutant
source or indirect source. The notice of intent shall be in a format specified by the director.

DAQC-824-23
Page 3

The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You are
responsible for complying with the Utah Air Conservation Rules. There are possible administrative
and civil penalties for failing to do so. Section 19-2-115 of the Utah Code Annotated provides that
violators of the Utah Air Conservation Act and/or any order issued there under may be subject to a
civil penalty of up to $10,000 per day for each violation.

The written response to this CA will be considered in resolving the deficiencies documented in this
letter. It may include information demonstrating compliance with the regulations or a schedule to
bring your company back into compliance with the applicable regulations. The DAQ will review your
response and this CA may be revised as a result of that review. Failure to respond in writing within ten
(10) business days of receipt of this CA will be considered in any subsequent enforcement action and
the assessment of penalties.

Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.

This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this
inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the DAQ
did not observe or evaluate, or any other conditions found during future inspections.

A meeting may be requested to discuss this CA. Please contact Connor Kijowski at 385-245-6720 or
[e-mail] if you would like to request a meeting or if you have any questions about this
letter.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-1308-23
Site IDs: 11281 and 11486 (B1)

Todd Slade
iFIT, Incorporated
1500 South 1000 West
Logan, UT 84321

Dear Mr. Slade:

Re: Compliance Advisory, No Further Action – iFIT, Incorporated

On August 10, 2023, the Utah Division of Air Quality (DAQ) sent iFIT, Incorporated (iFIT) a
Compliance Advisory (DAQC-824-23) for potential violations of the Utah Air Quality Rules. On
October 11, 2023, iFIT submitted additional information that resolved the potential violations
outlined in the Compliance Advisory referenced above. A permit revocation
(DAQE-GN11281001-23) was issued on November 16, 2023. Based on the additional information
provided to the DAQ, no further action is required at this time. Please be aware that closure of this
Compliance Advisory does not constitute a bar to enforcement action for conditions found during
other inspections.

Thank you for your cooperation in resolving this matter. If you have any questions regarding this
letter, please contact me at [phone] or at [e-mail].

Sincerely,

Chad Gilgen, Manager
Minor Source Compliance Section

CG:CK:rh

cc: Bear River Health Department
Alan Humpherys, UDAQ, Minor NSR Section Manager

Attachments: DAQE-GN11281001-23
December 6, 2023

DAQE-GN112810001-23

{{$d1 }}

Todd Slade
iFIT, Incorporated
1500 South 1000 West
Logan, UT 84321
[e-mail]

Dear Mr. Slade:

RE: Revocation of Approval Order DAQE-338-95 dated April 21, 1995
Project Number: N112810001

The Division of Air Quality (DAQ) received your request to revoke Approval Order DAQE-338-95 on
October 27, 2023. iFIT, Incorporated has requested the above-referenced Approval Order (AO) be
revoked and replaced with a Small Source Exemption (SSE). The DAQ has revoked the above-
referenced AO effective as of the date of this letter.

As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the
invoice.

If you have any questions, please contact Dungan Adams who can be reached at [phone] or
[e-mail].

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

cc: DJ Law, EPA Region 8
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

November 16, 2023
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DAQE- MN112810001-23

M E M O R A N D U M

TO: Source File: 11281: iFIT Inc.
THROUGH: Alan Humphreys, Minor NSR Manager – Air Quality
FROM: Dungan Adams, Minor NSR Engineer – Air Quality
DATE: November 15, 2023
SUBJECT: iFIT Inc. Logan Facility TEMPO ID Clarification
This memoradnum serves as clarification for the various TEMPO sites for iFIT Inc. (Previously
known as Icon Health and Fitness and ProForm Fitness Products, Inc.).

On October 11, 2023, the Division of Air Quality (DAQ) received a request from iFIT Inc.
(iFIT) for an Evaluation of Compliance with Utah Administrative Code (UAC) Rule R307-401-
9: Small Source Exemption (SSE) for a Fitness Equipment Manufacturing Facility. The facility
is located at 1500 S 1000 W in Logan, Cache County. TEMPO Site ID 16183 was created for the
project. After the SSE was approved, it was determined that the facility was already in TEMPO
under Site ID 11486, and that the facility had an active Approval Order (AO), DAQE-338-95.

However, TEMPO Site ID 11486 references an address in Smithfield, not Logan. A different
AO, DAQE-1002-95, was found under TEMPO Site ID 11486 in the EDocs database. This
indicates that an active site existed in Smithfield since November 1995 and that TEMPO Site ID
11486 was incorrectly used for the Logan facility. The active AO for the Logan facility, DAQE-
338-95, uses the historic name ProForm Fitness Products Inc. TEMPO Site ID 11281 was found
with the company name ProForm and the correct location at 1500 S 1000 W, Logan.

Therefore, all future projects and inspections for the iFIT Fitness Equipment Manufacturing
Facility located at 1500 S 1000 W in Logan shall use TEMPO Site 11281.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director