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Home My WebLink AboutDAQ-2024-0077821 DAQC-327-24 Site ID 12736 (B1) MEMORANDUM TO: FILE – C & C CAST POLYMERS INCORPORATED THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: March 25, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: March 6, 2024 SOURCE LOCATION: 1525 West 275 South, Lindon UT 84042 C & C Cast Polymers operations take place in the building directly west of the Master Bath building, which is visible from 200 South. C & C Cast Polymers is located east of the Lake Side Power Station. SOURCE CONTACT(S): Sid Clements, Manager, (801) 623-0071, sidclem1@aol.com marblemakers@aol.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: C & C Cast Polymers Incorporated manufactures cured resin vanity tops, tub surrounds, and showers. The appropriate molds are sprayed with a gel coat in a vented area. The molds are then filled with a mixture of catalyzed resin, fillers, and color. The molds are vibrated and then placed on drying racks. The dried material is removed from the mold and the rough edges are grinded off. The product is polished with a buffing compound and sent out to the job site. APPLICABLE REGULATIONS: Approval Order DAQE-AN2736002-06, dated January 13, 2006 SOURCE EVALUATION: General Conditions: 1. This Approval Order (AO) applies to the following company: Site Office C & C Cast Polymers, Inc. 1555 West 200 South Lindon, UT 84042 Phone Number (801) 796-8048 Fax Number (801) 796-8049 0 0 2 The equipment listed in this AO shall be operated at the following location: Same as above. Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 4,464.748 km. Northing, 435.940 km. Easting, Zone 12 Status: In Compliance. The address was changed to 1525 West 275 South by the USPS but the building was not moved. All other information listed in this condition is unchanged and correct. 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: This is not a compliance issue. 3. The limits set forth in this AO shall not be exceeded without prior approval in accordance with R307-401. Status: In Compliance. C & C Cast Polymers did not exceed any of the limits set forth in this AO. 4. Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved in accordance with R307-401-1. Status: In Compliance. C & C Cast Polymers did not make any modifications to the equipment or processes that could affect emissions covered by this AO. 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. Records shall be kept for a minimum two years. Status: In Compliance. C & C Cast Polymers maintains records for a minimum of two years. 6. C & C Cast Polymers shall operate the reinforced plastics manufacturing plant in accordance with the terms and conditions of this AO, which was written pursuant to C & C Cast Polymers’ Notice of Intent submitted to the Division of Air Quality (DAQ) on July 5, 2005. Status: In Compliance. C & C Cast Polymers maintains that their operations are in compliance with the terms and conditions of this AO. 7. This AO shall replace the AO (DAQE-AN2736001-02) dated November 25, 2002. Status: In Compliance. Only this AO was used to determine compliance. 3 8. The approved installations shall consist of the following equipment: A. Two (2) gel spray guns B. Miscellaneous containers including tanks and buckets C. Miscellaneous natural gas heaters and furnace D. Miscellaneous propane fork lifts and heaters E. Miscellaneous saws, grinders, sanders and etc. F. One (1) bulk resin storage tank Status: In Compliance. There was no unapproved equipment observed onsite during this inspection. Additional equipment information gathered at the time of inspection: • F- One (1) bulk resin storage tank is still on-site but has not been used for several years. The source indicated that resin is now purchased in 2800 lbs. totes and gel coat is purchased in 55-gallon drums. Limitations and Tests Procedures 9. Visible emissions from the following emission points shall not exceed the following values: A. All heating equipment - 10% opacity B. All vents to the atmosphere - 10% C. Forklifts - 20% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Status: In Compliance. There were no visible emissions observed from the heating equipment, vents, and forklifts during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. Fuels 10. The owner/operator shall use natural gas and/or propane as fuel in the combustion equipment. Status: In Compliance. C & C Cast Polymers only uses natural gas/and or propane as fuel in the combustion equipment. 4 VOC and Hazardous Air Pollutants (HAPs) Limitations 11. VOC/HAP containing materials shall be covered except when in use. Status: In Compliance. There were no uncovered VOC/HAP containing materials observed during this inspection. 12. The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement applicators, etc. and associated operations shall not exceed: 13.74 tons per rolling 12-month period for VOC (including all HAPs) 9.75 tons per rolling 12-month period for Styrene 0.38 tons per rolling 12-month period for Methyl Methacrylate 1.16 tons per rolling 12-month period for Toluene 1.21 tons per rolling 12-month period for Dimethyl Phthalate 1.24 tons per rolling 12-month period for Methylene Chloride 13.74 tons per rolling 12-month period for all HAPs combined Status: In Compliance. The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement applicators, etc. and associated operations did not exceed the AO limits in the rolling 12-month period from March 2023 through February 2024: 3.19 tons per rolling 12-month period for VOC (including all HAPs) 2.56 tons per rolling 12-month period for Styrene 2.91 tons per rolling 12-month period for all HAPs combined C & C Cast Polymers no longer uses Methyl Methacrylate and Methylene Chloride. Compliance with each of the limitations 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. Except for styrene emissions, 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 HAP 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 5 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 G. The amount of VOC or HAP reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. The source shall follow AP-42 Chapter 4.4, Polyester Resin Plastic Products Fabrication, to calculate styrene emissions. Status: In Compliance. C & C Cast Polymers maintains a monthly record of VOC and HAP emitting materials to determine VOC and HAP emissions. Records & Miscellaneous 13. 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. Status: In Compliance. C & C Cast Polymers Incorporated conducts regular maintenance of the two gel spray guns. Acetone is used to clean the spray guns. 14. The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. Status: In Compliance. C & C Cast Polymers Incorporated submitted the 2020 Emissions Inventory Report, and the emissions indicated compliance with the PTEs of this AO. 15. The owner/operator shall comply with R307-107. General Requirements: Unavoidable Breakdowns. Status: In Compliance. C & C Cast Polymers Incorporated has not experienced any breakdowns since the last inspection. 6 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards. Status: In Compliance. There were no visible emissions observed from the heating equipment, vents, and forklifts during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. R307-309. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. Status: In Compliance. There were no visible emissions observed during the inspection. R307-325. Ozone Nonattainment and Maintenance Areas: General Requirements. Status: In Compliance. All observed VOC containing materials were in covered storage containers. . R307-342. Adhesives and Sealants. Status: In Compliance. C & C Cast Polymers Incorporated uses Bondo, a polyester resin, with a VOC Content of 203 g/L, which is less than the 250 g/L for contact bonds listed in Table 1. R307-353. Plastic Parts Coatings. Status: In Compliance. C & C Cast Polymers Incorporated uses Axiom Marble coating to provide a clear coat, water-resistant, and glossy finish. The VOC Content on the SDS indicated 37% (w/w), which converts to 3.07 lbs/gallon and indicates compliance with Table 1 of R307-353-5 for top coat clear coat. EMISSION INVENTORY: C & C Cast Polymers Incorporated submitted the 2020 activity year Emissions Inventory Report as follows: Pollutant Tons/yr 1. CO ...................................................................... 0.025 2. NOx ..................................................................... 0.03 3. PM10 ................................................................... 0.28 4. SOx ..................................................................... 0.00018 5. VOCs .................................................................. 3.59 7 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance with the conditions of DAQE-AN2736002-06, dated January 13, 2006, at the time of inspection. The facility appeared to be adequately maintained and operated properly. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. ATTACHMENTS: VEO Form, Rolling 12-month VOC/HAP email