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HomeMy WebLinkAboutDAQ-2024-004799 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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-1300-23 Site ID 12321 (B1) Sent Via Certified Mail No. 70190700000208346429 Brian L. Boudreaux, CSP, MSOSH Honeywell Electronic Materials 4603 West 2100 South Salt Lake City, UT 84120 Dear Mr. Boudreaux: Re: Compliance Advisory – Honeywell Electronic Materials (Honeywell), Utah Administrative Code (UAC) R307-401, Approval Order (AO) DAQE-AN123210011-15 On August 28, 2023, a representative of the Utah Division of Air Quality (DAQ) conducted an inspection of Honeywell Electronics Materials Titanium Refinery, located at 4603 West 2100 South, Salt Lake City, Utah. The DAQ observed a natural-gas powered generator engine which may be a violation of UAC R307-401 and condition I.3 of AO DAQE-AN123210011-15. Honeywell 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 Irene Tucker at 385-306-6521 or itucker@utah.gov if you have any questions about this letter. Sincerely, Chad Gilgen, Manager Minor Source Compliance Section CG:rh cc: Salt Lake County Health Department Alan Humpherys, Manager, Minor Source NSR Section December 1, 2023 DAQC-1300-23 Page 2 Potential Violation(s) On August 28, 2023, a representative of the DAQ conducted an inspection of Honeywell Electronics Materials Titanium Refinery, located at 4603 West 2100 South, Salt Lake City, Utah. The DAQ observed an unauthorized natural-gas powered generator onsite. According to an inspection memo dated December 10, 2018, Honeywell had submitted a Notice of Intent (NOI) to the DAQ on September 24, 2018, to add a hot oil skid and the natural gas emergency generator. A subsequent inspection memo dated May 31, 2022, noted compliance assistance had been provided to Honeywell to add the equipment to the Approval Order. Failure to submit a Notice of Intent and receive an AO prior to operating the regulated equipment is a potential violation of UAC R307-401 and condition I.3 of AO DAQE-AN123210011-15. AO Conditions/Rules R307-401-5. Notice of Intent. (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. DAQE-AN123210011-15 Condition 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] 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. DAQC-1300-23 Page 3 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 Irene Tucker at 385-306-6521 or itucker@utah.gov if you would like to request a meeting or if you have any questions about this letter.