DAQ-2024-004860

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DAQC-CI132760001-24
Site ID 13276 (B1)

MEMORANDUM

TO: FILE – US SYNTHETIC – Synthetic Material Manufacturing

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: January 8, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: December 5, 2023

SOURCE LOCATION: 1260 South 1600 West
Orem, UT 84058
DIRECTIONS: Take University Boulevard exit and head west.

SOURCE CONTACTS: Ryan Larsen, HSE Specialist
[e-mail]

OPERATING STATUS: Operating normally at the time of inspection

PROCESS DESCRIPTION: US Synthetic creates man-made polycrystalline diamond cutters
by using a high pressure and high temperature sintering process.
On-site baghouses vent internally and control emissions from the
sandblasting and grinding. Additionally, hydrofluoric acid is
used to leach metals from the polycrystalline diamond surfaces.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN132760008-22, dated April 21,
2022
NSPS (Part 60), IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines
MACT (Part 63), ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

US Synthetic - Synthetic Material Manufacturing
1260 South 1600 West 1260 South 1600 West
Orem, UT 84058 Orem, UT 84058

SIC Code: 3533: (Oil & Gas Field Machinery & Equipment)

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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 five (5) 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
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]

Status: In compliance. No limits appear to have been exceeded. No modifications have been
made to equipment or process. Records were made available for review at the time of
inspection. The facility appears to be well maintained and a PM schedule is followed. No
reportable breakdowns have occurred since the previous inspection. A 2020 emission
inventory was submitted to DAQ.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 US Synthetic
Diamond manufacturer

II.A.2 Press Blasting and Leaching Process
Sintering and machining of diamond-tipped cutters
Hydrofluoric acid leaching to clean diamond surface

II.A.3 Two (2) Degreasing Units
Capacity: 15 gallons, each

II.A.4 One (1) Emergency Generator Engine
Rating: 400 kW (536 hp)
Fuel: Diesel
Construction Date: May 24, 2011
NSPS applicable: Subpart IIII
MACT applicable: Subpart ZZZZ

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II.A.5 One (1) Emergency Generator Engine
Rating: 250 kW (335 hp)
Fuel: Diesel
Construction Date: December 20, 2006
NSPS applicable: Subpart IIII
MACT applicable: Subpart ZZZZ

II.A.6 Four (4) Baghouses
Location: Building #3
Vent Internally

II.A.7 Seven (7) Baghouses
Location: Building #2
Vent Internally

II.A.8 Nine (9) Baghouses
Location: Building #1
Vent internally

II.A.9 Heaters
Rating: Less than 5 MMBtu/hr
Fuel: Natural Gas
Location: Buildings #1, #2, #3
For Informational Purposes

Status: In compliance with II.A.3. The equipment observed on site was consistent with that
listed with one exception, there are actually three 15 gallon degreasers on site. The previous
inspector discussed the degreasers with NSR and information submitted with the NOI
stated that these parts washing stations utilize a very low VOC solution, and a modification
to the AO is not warranted at this time for the extra degreaser. The third degreaser is
identical to the other two. Additional equipment and process information gathered at the
time of inspection:

The baghouses listed in II.A.6, II.A.7, and II.A.8 are a mix of dry, wet, and mist
collectors specific to the process being controlled. All baghouses vent internally and are
routed through a secondary filter bank prior to being vented back into the building.

II.B Requirements and Limitations

II.B.1 Source-Wide Requirements.

II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. All natural gas combustion exhausts - 10% opacity.

B. All other points - 20% opacity. [R307-401-8]

II.B.1.a.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. No visible emissions were observed during the inspection.

II.B.1.b The owner/operator shall use only natural gas as a fuel in all heaters/boilers. [R307-401-8]

Status: In compliance. Only natural gas is used as fuel in heaters/boilers.

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II.B.2 Hydrogen Fluoride Requirements

II.B.2.a The owner/operator shall not use more than 12,000 gallons of hydrofluoric acid (HF) per rolling
12-month period. [R307-401-8]

II.B.2.a.1 The owner/operator shall:

A. Determine usage by examination of individual hydrofluoric acid (HF) supplier billing
records.

B. Record usage of hydrofluoric acid (HF) on a daily basis.

C. Use the usage records to calculate a new rolling 12-month total by the 20th day of each
month using data from the previous 12 months.

D. Keep the usage records for all periods the plant is in operation. [R307-401-8]

II.B.2.a.2 The owner/operator shall keep hydrofluoric acid (HF) containers and beakers capped at all times,
except during transfer of HF to and from beakers. [R307-401-8]

Status: In compliance. The 12-month rolling total of hydrofluoric acid was 7,155 gallons.
No open containers were observed at the time of inspections.

II.B.2.b The owner/operator shall not use a hydrofluoric acid blend that exceeds a hydrogen fluoride
concentration of 30% by weight. [R307-401-8]

II.B.2.b.1 The owner/operator shall determine the hydrogen fluoride concentration by examination of the
hydrofluoric acid product safety data sheet (SDS). [R307-401-8]

Status: In compliance. The concentration of hydrogen fluoride varies from 26-30%
depending on the process. The SDS was made available for review during the inspection.

II.B.3 VOC Requirement

II.B.3.a The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:

15.01 tons per rolling 12-month period of VOCs. [R307-401-8]

II.B.3.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]. [R307-401-8]

II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed.
The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated
above to provide the monthly total emissions of VOCs. [R307-401-8]

II.B.3.a.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC-emitting material

B. The maximum percent by weight of VOCs in each material used

C. The density of each material used

D. The volume of each VOC-emitting material used

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E. The amount of VOCs emitted from each material

F. The amount of VOCs reclaimed and/or controlled from each material

G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8]

Status: In compliance. The 12-month rolling total for VOC was 1.19 tons. Emissions are
tracked as outlined.

II.B.4 Emergency Engine Requirements

II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

A. The date the emergency engine was used.

B. The duration of operation in hours.

C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]

II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

Status: In compliance. The 12-month rolling total for testing and maintenance operation
was 16 hours for the 400 kW engine and 17 hours for the 250 kW engine. The engines are
tested weekly. An operation log is kept. Each engine is equipped with a non-resettable hour
meter. The last oil change was conducted on February 14, 2023.

II.B.4.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each emergency engine. [R307-401-8]

II.B.4.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

Status: In compliance. Diesel fuel is purchased through J&J Oil and meets the 15 ppm or
less requirement.

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.

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NSPS (Part 60), A: General Provisions

Status: Compliance with NSPS (Part 60) A is determined by applicability of NSPS conditions at the
source location. See status of NSPS (Part 60) conditions for additional information.

NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In compliance with all applicable Subpart ZZZZ and IIII requirements. Engines are operated
less than 100 hours per year for maintenance and testing. Each generator is equipped with a
non-resettable hour meter. The source conducts monthly preventative maintenance on each generator
and contracts with Cummins Rocky Mountain for annual maintenance.

MACT (Part 63), A: General Provisions

Status: Compliance with MACT (Part 63) A is determined by applicability of MACT conditions at the
source location. See status of MACT (Part 63) conditions for additional information.

MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In compliance with all applicable Subpart ZZZZ and IIII requirements. Engines are operated
less than 100 hours per year for maintenance and testing. Each generator is equipped with a
non-resettable hour meter. The source conducts monthly preventative maintenance on each generator
and contracts with Cummins Rocky Mountain for annual maintenance.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-210. Stationary Sources

Status: In compliance. This area source rule is applicable per Subpart IIII. Compliance with this
area source rule is satisfied by compliance with Section II.B.4 of the AO.

R307-214. National Emission Standards for Hazardous Air Pollutants

Status: In compliance. This area source rule is applicable per Subpart ZZZZ. Compliance with
this area source rule is satisfied by compliance with Section II.B.4 of the AO.

R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards

Status: In compliance. The requirements of this area source rule are satisfied by compliance
with AO condition II.B.1.a. See status of AO condition II.B.1.a for additional information.

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

Status: In compliance. The grounds surrounding the source location are paved and landscaped.
There are no other potential sources of fugitive emissions or dust.

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R307-335. Degreasing

Status: In compliance. The source has three parts washing stations, one in each building. All lids
were closed at the time of inspection and have instructions for use and maintenance, as well as
information on the cleaning product which is Armakleen. Armakleen meets the VOC weight limit of
10.5 g/l.

R307-350. Miscellaneous Metal Parts and Products Coatings

Status: Not applicable. This area source rule was evaluated at the time of inspection. The source
indicated they do not conduct any metal parts or products coating as part of normal operations.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from US Synthetic - Synthetic Material
Manufacturing. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN132760008-22, dated April 21, 2022, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 98.29
Carbon Monoxide 2.54 0.12465
Nitrogen Oxides 5.11 0.54391
Particulate Matter - PM10 0.46 0.00909
Particulate Matter - PM2.5 0.46 0.00882
Sulfur Dioxide 2.34 0.022
Volatile Organic Compounds 15.01 0.01598

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 2 0.00022
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 4800

PREVIOUS ENFORCEMENT
ACTIONS: CA – April 3, 2020 – For modifying production processes to use
hydrofluoric acid without prior approval.

ESA – April 27, 2020 – for the above CA.

Signed ESA – May 26, 2020

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN132760008-22,
dated April 21, 2022: US Synthetic should be considered in
compliance. The facility appeared to be well maintained and
properly operated. Requested records were provided for review
at the time of inspection. There is a third degreasing station
on-site which is identical to the other two. The previous
inspector discussed this matter with NSR and it was determined
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that there was no need for the source to modify the AO based on
the very low amount of additional emissions.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: May need to contact Ryan Larsen to schedule inspection. Inspect
as normal.

NSR RECOMMENDATIONS: Add third parts washer to equipment list.

ATTACHMENTS: VEO Form.