DAQ-2024-008000

LIBERTy
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Utah Division of Air Quality
Attn: Bryce Bird
P.O. Box L44820
Salt Lake City, Utah 84LL4-4820
Deviation ReportTo: Bryce Bird I Executive Secretary, Utah Air Quality Board
From: Liberty Safe and Security ProductsRE: Deviation report for Permit # DAQE-AN125380008-19
Date: 41512(J24
Mr. Bird:
In accordance with Operating Permit provision I.S.2.b, and Utah Administrative Code (UAC) R307-
415-6a(3)(c)(ii), the following deviation report is submitted:
1. List the dates the deviation occurred: StartT/7/23 End: Ongoing -The site has
resolved the situation and will not be emitting additional styrene from surface coating at
this time. However, this condition is still being exceeded due to the condition being a 12-
month rolling limit condition.
2. Permit Conditions for which Deviation Occurred: ILB.1.b
3. Describe the deviation that occurred: There was an exceedance of the 0.12 tons per
rolling l2-month period for Styrene in the above referenced permit condition. The highest
emitted 12-month rolling total was 0.868 tons.
4. Was the Deviation Due to an "upset Condition" as defined in Section II of the
permit?
_Yes XNo _ "Upset Condition" not defined in Section II
5. Describe the probable cause of Deviation: As part of a program to increase production
efficiencies we partnered with our paint supplier, Cardinal, to change our primer to the
best available coating for our products._We chose a primer that is very widely used in
automotive paint refinish applications, provides the needed benefits of a high film build,
quick cure, and excellent sanding capabilities, and has moderate VOC content. We learned
that the coating contained styrene when we changed to our new environmental consultant,
Terracon. This led to us determining that we exceeded the_styrene emission levels in our
permit.
6. Describe any corrective actions or preventive measures taken: Site has discontinued
use of the coating that contained styrene and is currently preparing a permit modification
application to adjust the pollutant specific limits contained in the air permit to allow for
futu re operational flexibi lity.
In accordance with Operating Permit provision LK and UAC R307-415-5d, and based on
and belief formed after reasonable inquiry, I certify that the statements and
t are true, accurate, and complete.
Signature Official for the Source
Print or type the name tle of Responsible Official
I 199
(801) e25-1000
Utah Avenue, Payson, Utah 84651
Toll Free: [phone] Fax: [phone]