DAQ-2024-004606

1
DAQC-CI140080001-23
Site ID 14008 (B1)

MEMORANDUM

TO: FILE – DEMATIC – Automated Storage & Retrieval Machine Mfg.

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: December 14, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: August 28, 2023

SOURCE LOCATION: 265 South 5200 West
Salt Lake City, UT 84104
DIRECTIONS: Take I-80 to 5600 West, go south and turn left at 300 South.
Travel east to just past the RC Willey warehouse. This is a
secure building that requires phoning the plant contact in order to
enter the lobby.

SOURCE CONTACTS: Maren DeBoer, EH&S Specialist: 801-715-2375
[e-mail]

OPERATING STATUS: Operating normally.

PROCESS DESCRIPTION: Dematic manufactures and tests automated storage/retrieval
machines and automated guided vehicles. The source welds,
paints, and assembles automated machines. Painting operations
occur in a large area with filter embankments on both sides of
the walls which vent to the roof. A 110-kw generator is on site to
provide emergency power.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN140080003-18, dated
December 11, 2018
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,
UAC R307-350 Miscellaneous Metal Parts and Products
Coatings

2
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Dematic - Automated Storage & Retrieval
Machine Mfg

265 South 5200 West 265 South 5200 West
Salt Lake City, UT 84104 Salt Lake City, UT 84104

SIC Code: 5084: (Industrial Machinery & Equipment)

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 two (2) 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: Not in Compliance with R307-350-7 for using a lacquer thinner that exceeded the
composite vapor pressure limit. The lacquer thinner will reportedly be replaced with a
compliant product in January of 2024. No compliance actions are recommended at this
time. This facility was otherwise in compliance as no other limits were exceeded, and no
additional equipment or changes to the permitted processes were observed during this
inspection. All records were made available upon request and the records are maintained
for at least two years. Maintenance performed on the permitted equipment occurs as
required and is recorded. No applicable Unavoidable Breakdowns have occurred.
Emissions Inventories are submitted every three years as required. The 2020 activity report
is attached for review. The 2023 Inventory will be due on April 15, 2024.

3
Section II: SPECIAL PROVISIONS

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

II.A.1 Automated Storage & Retrieval Machine Mfg

II.A.2 Paint Booths
Control: Filters

II.A.3 Emergency Generator
Rating: 110 KW
Fuel: Diesel
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

II.A.4 Welding
Included for informational purposes

Status: In Compliance. The equipment has been installed as described. The paint booth
areas are equipped with embankment filters that vent to the roof after filtration.

II.B Requirements and Limitations

II.B.1 Site-Wide Requirements

II.B.1.a The owner/operator shall not allow visible emissions on site to exceed 20 percent opacity.
[R307-305-3]

Status: In Compliance. The paint booths were being used during the site observations. No
visible emissions from the roof vents were detected during the inspection.

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-305-3]

Status: In Compliance. The observations were performed in a manner consistent with
Method 9 requirements. See the attached VEO.

II.B.2 Paint Requirements

II.B.2.a Each paint booth shall be equipped with particulate filters to control particulate emissions. All
exhaust air from the paint booths shall be routed through the filters before venting to the
atmosphere. [R307-401-8]

Status: In Compliance. Particulate filters have been installed in the walls of the painting
booth areas. The exhaust air from the paint booths are routed through the filters before
venting to the roof vents.

II.B.2.a.1 The filters shall be maintained and replaced according to the manufacturer's recommendations.
[R307-401-8]

Status: In Compliance. The filters are changed monthly or more often as needed.

4
II.B.2.b The plant-wide emissions of VOCs and HAPs from the paint booths and associated operations
excluding incomplete combustion products shall not exceed:

10.60 tons per rolling 12-month period for VOCs (excluding HAPs)
0.49 tons per rolling 12-month period for Xylene
2.25 tons per rolling 12-month period for Toluene
0.49 tons per rolling 12-month period for Glycol Ether
0.07 tons per rolling 12-month period for Ethyl Benzene
0.19 tons per rolling 12-month period for Methyl Isobutyl Ketone. [R307-401-8]

Status: In Compliance. The plant-wide emissions of VOCs and the referenced HAPs for the
rolling 12-month period of August 2022, through the end of July 2023, were reported as
follows:

VOCs, excluding HAPs = 1.280 tons (2560.52 lbs)
Xylene = 0.236 tons (472.53 lbs)
Toluene = 0.050 tons (101.43 lbs)
Ethylene Glycol Mono Butyl Ether = 0.371 tons (742.08 lbs)
Ethyl Benzene = 0 tons
Methyl Isobutyl Ketone = 0.0845 tons (169.05 lbs)

112.70 pounds of methyl ethyl ketone (MEK) was reported for the same time period due to
the use of the dematic lacquer thinner which is due to be replaced in January of 2024.
MEK is no longer considered to be a HAPS and appears to have been included in the VOC
total. See the attached submitted product spreadsheets and emission totals.

II.B.2.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. No later than
20 days after the end of each month, a new 12-month total shall be calculated using data from the
previous 12 months.
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/or 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/or HAP in each material used
D. Gallons of each VOC- and/or HAP-emitting material used
E. The amount of VOC and/or HAP emitted monthly by each material used shall be
calculated by the following procedure:
VOC = (% VOC by Weight)/100 x [Density (lb/gal )] x Gal Consumed x (1 ton/2000 lb)
HAP = (% HAP by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb)
F. The amount of VOC or HAP emitted monthly from all materials used
G. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified
and subtracted from the quantities calculated above to provide the monthly total VOC
or HAP emissions. [R307-401-8]

Status: In Compliance. Product use totals are calculated monthly on spreadsheets.
12-month rolling totals are available prior to 20 days after the end of each month. See the
attached product and emission totals spreadsheets.

II.B.3 Emergency Engine Requirements

II.B.3.a The owner/operator shall not operate the emergency engine for more than 100 hours per rolling
12-month period during non-emergency situations. There is no limit on the use of the engines
during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. The emergency generator was operated for testing and
maintenance purposes for a total of 24.1 hours for the rolling 12-month period of August
2022, through July 2023. No emergency engine use occurred during that time frame.

5
II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the twentieth 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:
1. The date the emergency engine was used

2. The duration of operation in hours

3. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. A log documenting the use of the generator is kept near the
generator. The log includes the date, duration of time, and the reason for use. The duration
of use is transferred to an electronic spreadsheet prior to the end of each month.

II.B.3.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. A non-resettable hour meter has been installed on the engine. The
engine meter hours are entered into a spreadsheet and the number is recorded each month.
Hours of use are determined by subtracting the change in the number each month. See the
attached generator use records submitted for the years of 2021, through 2023.

II.B.3.b The sulfur content of diesel burned in the stationary diesel engines on site shall not exceed 15
ppm by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. The generator is fueled and maintained by Power Systems West.
The contract with Power Systems West certifies that all of the diesel fuel used is Ultra Low
Sulfur Diesel that meets the federal standards.

II.B.3.b.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by
test reports from the diesel fuel marketer. [R307-203-1]

Status: In Compliance. All fuel used by the contracted company is certified as meeting the
federal standards for low sulfur fuels.

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.

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

Status: In Compliance. The 2006 Kohler diesel-fueled emergency generator qualifies as a pre-2007
model that commenced construction after July 11, 2005, and manufactured after April 1, 2006. The
emergency generator is equipped with a non-resettable hour meter. The meter records indicated that it
operated under the federal limit. The engine is maintained and tested routinely and receives a full
annual engine check by Power Systems West. See the attached annual maintenance record and the
engine specification records submitted for the NOI for the current AO. Compliance with this federal
standard is also met by compliance with the generator conditions II.B.3.a through II.B.3.b.1 of the
current AO.

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

Status: In Compliance. This engine meets the federal standards for NSP IIII, including fuel standards,
hours of use, testing, and maintenance. The requirements are also met by compliance with the current
AO Conditions II.B.3.a through II.B.3.b.1.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: Not in Compliance with R307-350-7 Work Practices. R307-350-7 (2) states that “Solvent
cleaning operations shall be performed using cleaning materials having a VOC composite vapor
pressure no greater than 1 mm Hg at 20 degrees Celsius, unless an add-on control device is used as
specified in R307-350-8”. A non-compliant custom lacquer thinner has historically been used at this
facility. Compliance assistance was provided after the inspection to work with the company to have
the product changed. The site contact, Maren DeBoer, stated that the non-compliant product will be
replaced by the end of January of 2024. See the attached email correspondence. The facility was
otherwise in compliance with this State Rule. Dematic's manufacturing process for the automated
equipment systems requires the use of extreme performance, extreme gloss and heat resistant
coatings. The coatings listed as currently used for this facility were under the 3.5 pounds of VOC per
gallon limit as per Table 1 of R307-350. The highest VOC lbs/gallon recorded for the products is 3.25.
See the Dematic Emissions Inventory sheet for the time period of August 2022, through July 2023.
See the attached product spreadsheets.

EMISSION INVENTORY:

An Emissions Inventory for the 2020 activity year was submitted and is attached for reference. The 2023
activity year inventory will be due on April 15, 2024. Listed before are the Actual Emissions Inventory
provided from Dematic - Automated Storage & Retrieval Machine Mfg. A comparison of the estimated
total potential emissions (PTE) on AO: DAQE-AN140080003-18, dated December 11, 2018, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 76.62
Carbon Monoxide 0.05
Nitrogen Oxides 0.23
Particulate Matter - PM10 0.97
Particulate Matter - PM2.5 0.97
Sulfur Dioxide 0.02
Volatile Organic Compounds 10.63
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Ethyl Benzene (CAS #100414) 140
Generic HAPs (CAS #GHAPS) 800
Glycol Ethers (CAS #EDF109) 980
Toluene (CAS #108883) 4500
Xylenes (Isomers And Mixture) (CAS #1330207) 980

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PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory (CA) was issued on July 18, 2018
(DAQC-943-18), for failure to submit a NOI for the 110-kW
emergency generator.

The above CA was resolved by an Early Settlement Agreement
dated October 16, 2018 (DAQC-2202-18), and signed on
October 18, 2018, with a penalty of $359.00.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance with the AO AN140080003-18 dated December
11, 2018, NSPS IIII, and MACT ZZZZ. This facility was not in
compliance with UAC R307-350-7 (2) due to the use of a
non-compliant lacquer thinner cleaner. The source has stated that
the lacquer thinner will be replaced with a compliant cleaner by
the end of January of 2024. See the attached email
correspondence.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Check for a R307-350-7 (2) compliant cleaner product. This is a
secure facility which will require scheduling in advance with the
site contact. Required PPE includes safety glasses, reflective
vent, and steel toe boots.

NSR RECOMMENDATIONS: None.

ATTACHMENTS: VEO, product coating VOC and HAPs records, generator
records, and email correspondence regarding the Dematic
lacquer thinner.
2020 Emissions Inventory Report
Emissions Summary for Dematic Corp. Automated Storage & Retrieval Machine Mfg. (14008)
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)0.03707 0.00101 0.03808
PM25-PRI PM2.5 Primary (Filt + Cond)0.03707 0.00101 0.03808
SO2 Sulfur Dioxide 0.01031 0.00003 0.01034
NOX Nitrogen Oxides 0.15593 0.03077 0.1867
VOC Volatile Organic Compounds 1.72242 0.00729 1.72972
CO Carbon Monoxide 0.03501 0.21286 0.24786

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC 0.00003
107028 Acrolein (HAP)VOC <.00001
71432 Benzene (HAP)VOC 0.00003
106990 1,3-Butadiene (HAP)VOC <.00001
7440473 Chromium (HAP)PM 0.00001
7440484 Cobalt (HAP)PM 0.00001
50000 Formaldehyde (HAP)VOC 0.00004
7439965 Manganese (HAP)PM 0.00159
91203 Naphthalene (HAP)VOC <.00001
7440020 Nickel (HAP)PM 0.00001
130498292 PAH, total (HAP)PM 0.00001
108883 Toluene (HAP)VOC 0.06761
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.31501

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
Customer Name Customer No.Details Part Numb Customer Site Site Description
Dematic Corp C3000278 Trouble call Branch Gen2127956 2127956 - 265 S
Start Date Assigned to Day Format CodQuestionnaire TitleStart Time
05/17/2023 tylerpickens Wed FSR PSW Field Service R00:00
No. (Question)Question Category No. ResponResponse Remark
9 Generator Owner:0 Dematic
10 Generator Location 0 265 S. 5200 W. S
11 Inspection Frequency 0
12 Next Inspection Due:0
13 Contact Name 0
14 Contact Phone #0
15 Generator Brand 0 Kohler
16 Generator Model Generator Details 0 100REOZJB
17 Generator Spec Generator Details 0 GM31029-GA3
18 Generator S.N.Generator Details 0 2127956
19 Unit Hours 0 574.6
20 Genst Volts 3 277/480
21 Phase 2 Three
22 Frequency 1 60 HZ
23 K.W. Rating 0 110kw
24 Load Bank Test 0 no
25 Engine Brand 0 John Deere
26 Engine Model Generator Details 0 6068TF250
27 Engine Spec Generator Details 0 n/a
28 Engine S.N.Generator Details 0 PE6068T617956
29 Date Last Oil Changed 0 10/15/22
30 Oil Capacity 2 Gallons
31 Oil Filter P/N 2 Checked
32 Oil Pressure 2 Checked
33 Fuel Filter P/N 2 Checked
34 Coolant Filter P/N 3 N/A
35 Air Filter P/N 2 Checked
36 Charging/Starting System 2 Checked
37 Battery Water Level 1 Replaced
38 Battery Last Changed 0 05/15/23
39 Size 1 24
40 Battery Charge Rate 0 good
41 Coolant Level/Protection 2 Checked
42 Hoses/Belts/Cooling Fins 2 Checked
43 Block Heater P/N 2 Checked
44 Fuel System/Day Tank 2 Checked
45 Governor System 2 Checked
46 Ignition System P/N'S 2 Checked
47 Exhaust System 2 Checked
48 Check All Systems For Leaks 1 Pass
49 Generator/Controls/Safeties 1 Pass
50 Instruments/Lamps/Wiring 2 Checked
51 Generator Test 2 No Load
52 Reset All Switches to Auto/Turn Breake 1 Yes
53 ATS Brand 0
54 ATS Model Generator Details 0
55 ATS Spec Generator Details 0
56 ATS S.N.Generator Details 0
57 Exercise Day:0
58 Exercise Time 0
59 Load/NO Load 0
60 Transfer Switch Controls/Contactor 2 Checked
Serial Number Date Opened Call NumbeStatus of Call Call Taker Zone Assigned to
2127956 05/15/23 07:35 SC2330005Closed hyrumconr 32 tylerpicken
End Date To Day End Time Appointment DuratioStatus Done?Subject
05/17/2023 Wed 0 0 Completed Y Dematic Co
Response Type Mandatory Question?
T
T
L
D
T
T
T
T
T
T
T
L
L
L
T
T
T
T
T
T
D
L
L
L
L
L
L
L
L
D
L
T
L
L
L
L
L
L
L
L
L
L
2127956
Today's Date:05/17/2023 32
Inspected By:tylerpickens
Locations:Portland OR
[phone]
Brand
Model
Spec
S.N.
574.6 277/480 110kw
10/15/22 Battery Charge Rate:good
No Load:
Replaced N/A
Oil Capacity Gallons Oil Pressure:
X
X
FIELD SERVICE REPORT
Site #
Cust #C3000278 Zone
Job #:SC233000535
Generator Location:265 S. 5200 W. Salt Lake City, UT Contact Name:
Contact Phone:
Salt Lake City UT
[phone]
Boise ID (800) 354-
6767
Fife WA
[phone]
Aurora CO
[phone]
Generator Owner:Dematic Corp Inspection Frequency:Next Inspection Due:
100REOZJB 6068TF250
GM31029-GA3 n/a
GENERATOR ENGINE AT S
Kohler John Deere
2127956 PE6068T617956
UNIT HOURS: GENSET VOLTS PHASE Three K.W. RATING
Date Last Oil Change:Battery Last Changed:05/15/23 Size:24
Exercise Day:Time:Load:
Generator Teset w/Load:Without Load:X Load Bank Test:
Oil Filter P/N
Qty (Parts Used)Remarks
1 gm106373-s battery
Checked
X
X
Air Filter P/N
Coolant Level/Protection
X
X
Coolant Filter P/N
Hoses/Belts/Cooling Fins X
Block Heater P/N
Fuel System Day Tank
X
X
Governor System X
X
Fuel Filter P/N X
Ignition System P/N's
Generator/Controls/Safeties
Battery Water Level
Charging/Starting Systems
Exhaust System
Check all Systems for Leaks
CUSTOMER OR AUTHORIZED AGENT
Summary of work/remarks/recommendations:
Arrived on site and found the unit had a dead battery. The GFI tripped, and the battery charger stopped working. Reset the outlet and replaced the battery. Tested the unit for 15 minutes.
Made sure all alarms were cleared. The unit is now back in auto and ready.
X
X
X
X
I HEREBY AUTHORIZE THE ABOVE REPAIR WORK TO BE PERFORMED USING PARTS AND MATERIALS AS NECESSARY. YOU AND YOUR EMPLOYEES MAY OPERATE ABOVE MACHINE FOR PURPOSE OF
TESTING INSPECTION OR DELIVERY AT MY RISK. AN EXPRESS MECHANICS LIEN IS ACKNOWLEDGED ON ABOVE MACHINE TO SECURE THE AMOUNT OF REPAIRS THERETO. IT IS UNDERSTOOD THAT
POWER SYSTEMS WEST ASSUMES NO RESPONSIBILITY FOR LOSS OR DAMAGE BY THEFT OR FIRE TO MACHINE PLACED WITH THEM FOR STORAGE, SALE, REPAIR OR WHILE FIELD TESTING.
Reset All Switches to Auto/Turn Breaker On Yes
Transfer Switch Controls/Contactor
Instruments/Lamps/Wiring
A.C. Voltage/Frequency
KOHLER . Warranty Processing System Unit History
Unit
Serial Number
2127956
Parts Coverage
12 Months / 2000 Hours
Model
100REOZJB
Test Date
11 /03/2006
Engine RPM
0
Amps
165.00
Low Volt
277
Brand
Kohler Generator Brand
Standard Warranty Part#
GM50088
Kits
Kit Type
Installed
Installed
Installed
Unknown
Installed
Unknown
Installed
Installed
Installed
Installed
Unknown
Installed
Installed
Installed
Unknown
Installed
Installed
Installed
Installed
Installed
Installed
Unit Registrations
In-Service Date
01/12/2007
Labor Coverage
12 Months / 2000 Hours
Specification Number
GM31029-GA3
Engine Serial Number
PE606 8T617956
Fuel Type
Diesel
Power Factor
0 .80
High Volt
480
Usage
Standby
Extended Warranty Part#
Kit Material Number
GM 17679-KA3
GM20968-KA 1
GM19461-KA2
222661
GM 2 1530-MA2
275595
GM19874-KA1
GM17672-MA15
GM33867-KA2
GM28569-KA 1
258811
GM33871-KA2
GM28625-KA2
GM20783-MA 1
333708
GM20880-MA 1
GM33830-KA6
GM37533-MA 1
GM19978-KA2
GM32625-KA14
364502-MA43
Warranty Expiration
01/12/2008
Travel Coverage
12 Months / 2000 Hours
Product ID
Generator Set
Engine Manufacturer Name
JOHN DEERE
KW
110
Hertz
60
Battery Volt
12
Standard Warranty Desc.
1 Year Industrial Standby
Standard Warranty
Kit Description
LCB , 150A,3P , 600V, UL,TH
Block Heater, 1500W, 120V
Flexible Fuel Lines
Nameplate Rat ing , Standby
Skid , 41 "
Safeguard Breaker
Decal, UL2200 Listing (Di
Alternator, 4S9
Enclosure, Weather
Battery Charger,FloaVEqu
Pow er Factor Test,0.8,3Ph
Silencer, Grit. Roof Moun
Coolant in Gensel 6 gals.
Air Intake , Standard Duty
Voltage ,60Hz,277/480V,Wye
Control & Harness,JD6068H
Rad iator Drain Valve
Cooling , Un it Mounted Rad
CSA Approval,4S
Double Wall , 114 Gal , 41"
Controller, 16 Light,Dec3+
Sales Order Number
1003164960
Material
100REOZJB
Engine Model
6068TF250
KVA
138.00
Phase
3
Market
Industrial
Extended Warranty Desc.
Serial # Type Submission ID Service ID Service Name Owner Last Name Owner Company Registration Date
2127956 Original 0
Unit Updates
Unit Update ID
14081
Serial Number
Unit History 7/26/2018 3 :53 :42 PM
POWER
SYSTEMS
WEST
Name
H KSYSTEMS
Description
03/26/2010
Creation Date
Pag e 1 of 1
in
0
0
N
co
0
0
N
Effectivity
Date
1-Jan-2005
1-Jan-2005
1-Jan-2005
1-Jan-2006
1-Apr-2006
1-Apr-2006
:
Option Code
9301
:
16**
..
16**
·., ,.·
9301 ,.·
..
93AU Ji
<l
93AV
Label Part
Number
R517821
R520265
\ R520264
R523558
R523559
(852:3561))
Label Type
US Export, EU Export,
Stationary ,
Non-Regulated
IMO Compliant,
U.S. Recreational
IMO Exempt ,
U.S . Recreational
US Export, EU Export,
Stationary ,
Non-Regulated
US Export, EU Export,
Non-NSPS
Non -Regulated
US Export, EU Export,
(B§PS:Slati om.i.n1_(QID)
~or,":R~ulatea)
Emissions Level
Tier 0 ,
Former Tier 1
Tier O / 1 Marine
( >= 130 kW)
Tier O / 1 Marine
( < 130 kW)
Tier 0 , Tier 1,
Former Tier 1,
Former Tier 2 ( >= 130 kW )
Tier O Nonroad / Marine
Tier 1 Marine
mer r comQlilIDIJ
(EQrmef Ti er n
(Former Tier 2 ( >= r ~o-RWj )
--------------------Applications Produced by Deere -----------------------
X
N/A
N/A
X
(Jan-Mar)
N/A
®
(f~"rlr:DjID
Export
(including
marine)
X
X
X
X
(Jan-Mar)
X
(Apr-Dec)
X
(Apr-Dec)
U.S.
Fire Pumps
E.U.
Constant Speed
X X
X N/A
X N/A
X X
(Jan-Mar) (Jan-Jun)
X N/A (Apr-Dec)
X X
(Apr-Dec) (Jul-Dec)
12/11/23, 10:51 AM State of Utah Mail - Re: Solvent vapor pressures
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1784026397475630711%7Cmsg-f:1784031406698520763&…1/2
Susan Weisenberg <[e-mail]>
Re: Solvent vapor pressures
1 message
Chad Gilgen <[e-mail]>Thu, Nov 30, 2023 at 3:54 PM
To: "[e-mail]" <[e-mail]>
Cc: Susan Weisenberg <[e-mail]>
Hi Randy,
I forgot MEK is no longer classified as a HAP and is counted as a VOC. I apologize for the mistake there.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Thu, Nov 30, 2023 at 2:35 PM Chad Gilgen <[e-mail]> wrote:
Hi Randy,
It was good to talk with you today. Thanks for sending over the vapor composite pressure values for each component
of the Dematic lacquer thinner. Based on the information provided, these are the corresponding mm Hg values of each:
Xylene - 882 Pa @ 25 C = 6.61 mm Hg. Since this is at 25 C we can expect this value to be lower at 20 C but still
above the 1 mm Hg limit.
MEK - 105 mbar @ 20 C = 78.8 mm Hg
Acetone - 247 mbar @ 20 C = 185.3 but this is an exempt solvent.
Each of the four components exceeds 1 mm Hg at 20 C so this product being used as a solvent is currently out of
compliance with R307-350-7(2) so it is appreciated you are being proactive to help Dematic switch over to a compliant
cleaning solvent.
It also looks like they are also out of compliance for using a product containing MEK as that is a HAP and they are not
currently permitted to use/emit MEK in their current Approval Order.
Thanks again and let me know if you have any follow-up questions.
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
12/11/23, 10:51 AM State of Utah Mail - Re: Solvent vapor pressures
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1784026397475630711%7Cmsg-f:1784031406698520763&…2/2
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Thu, Nov 30, 2023 at 12:52 PM [e-mail] <[e-mail]> wrote:
Chad,
Thank you for your me today.
Just for reference here are the solvent specs for vapor pressure measurement from the producers of the
solvents used in the current Demac lacquer thinner.
Xylene - 882 Pa @ 25 C
MEK - 105 mbar @ 20 C
Acetone - 247 mbar @ 20 C
VM&P Naptha - 1.5 kPa Room temperature (11mm Hg)
As seen above the VM&P Naphtha is the only one lisng the MM Hg measurement which is clearly
above the limit.
I will work with Demac to convert to a compliant system.
Thanks,
Randy Kontz
Technical Director
Valley Paint Manufacturing Co.
727 South 950 West - Woods Cross, UT 84087
Office - 801-298-4581 - Cell - 435-363-5950
12/11/23, 10:52 AM State of Utah Mail - Dematic Response
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1784466961738322497%7Cmsg-f:1784466961738322497&…1/1
Susan Weisenberg <[e-mail]>
Dematic Response
1 message
Chad Gilgen <[e-mail]>Tue, Dec 5, 2023 at 11:17 AM
To: Susan Weisenberg <[e-mail]>
Hi Susan,
I received your text earlier.
I think this one can be addressed by stating they are not in compliance but no action is currently recommended since they
are switching out the non-compliant solvent in January 2024. You can also state that compliance assistance was
provided to help them switch out the non-compliant solvent. That way this won't be marked as any sort of official potential
violation on our end. Also include the email correspondence with Maren as part of the memo and ask her to send an
email confirmation in January 2024 when they have changed solvents so we can add that to the source file.
If Maren has any concerns about this course of action, we can schedule a time to talk with her more about our process.
Thanks and let me know if you would like to discuss anything further.
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…1/8
Susan Weisenberg <[e-mail]>
RE: request for MSD sheet for dematic lacquer thinner
1 message
Deboer, Maren <[e-mail]>Mon, Dec 4, 2023 at 1:45 PM
To: Susan Weisenberg <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Hi,
Just checking in.. Randy Kontz from Valley Paint talked to Chad last week to see if we could come to an
understanding on what we needed to change in our Lacquer Thinner is order to be compliant.

Randy gave us 3 different options to try this week. He said that they would all be in compliance with what you are
requesting. We are going to try them out in the next 2 weeks and decide. We have enough of our old product V-098 to
last until the end of December. The plan will be to switch completely over to the new solvent on January 2, 2024.
My question to you is…. I have an External Audit for our ISO 14001 & 45001 Certification next week. I don’t want this
to show up as a non-conformance because we are actively fixing the issue. Can you verify that our permit is active
and we are still in compliance while we are switching to this new solvent?

Thank you so much for talking through this issue with Valley Paint. I appreciate your willingness to solve this and
make things better and safer for everyone.

Maren DeBoer
Senior Environment Health & Safety Professional 
DEMATIC l We Optimize Your Supply Chain

Dematic Corp.
265 South 5200 West
Salt Lake City, UT 84104
Phone: [phone], Cell:  801-910-1553, Teams:  385-831-1355
mailto: [e-mail]
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…2/8
www.dematic.com

PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS E-MAIL!
Important Note: This e-mail may contain trade secrets or privileged, undisclosed or otherwise confidential information. If you have received this e-mail in error, you are
hereby notified that any review, copying or distribution of it is strictly prohibited. Please inform us immediately and destroy the original transmittal. Thank you for your
cooperation.

From: Susan Weisenberg <[e-mail]>
Sent: Tuesday, November 28, 2023 11:35 AM
To: Deboer, Maren <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Subject: Fwd: request for MSD sheet for dematic lacquer thinner

WARNING: This email originated outside of the company. DO NOT CLICK links or attachments or enter any information
into forms unless you trust the sender and know the content is safe.
WARNING: This email originated outside of the company. DO NOT CLICK links or aachments or enter any informaon into forms
unless you trust the sender and know the content is safe.

Hello, as per my management, we will need a data sheet that documents that the Dematic blend lacquer thinner has a
VOC composite vapor pressure that is no greater than 1 mm Hg at 20 degrees Celsius. Thanks, let me know if you need
more information.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

---------- Forwarded message ---------
From: Chad Gilgen <[e-mail]>
Date: Tue, Nov 28, 2023 at 10:48 AM
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…3/8
Subject: Re: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>

Hi Susan,

Per our discussion this morning, the source needs to provide documentation demonstrating they are in compliance with
that R307-350 solvent cleaning requirement of VOC composite vapor pressure no greater than 1 mm Hg at 20 degrees
Celsius or that they are using an add-on control device (afterburner, RTO, etc.) to control emissions.

If they can't provide that information, then we will need to issue them a Compliance Advisory as it looks like they could be
using a high-VOC coating component for cleaning which is not it's intended purpose.

Thanks,
Chad

Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Wed, Nov 22, 2023 at 8:40 AM Susan Weisenberg <[e-mail]> wrote:
This is the response I received from Dematics. The updated sheet still doesn't include the vapor pressure data.
Apparently they have a specific blend that is custom made. Is there a way that a total vapor pressure can be calculated
from the listed VOC containing components?
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…4/8

---------- Forwarded message ---------
From: Deboer, Maren <[e-mail]>
Date: Wed, Nov 22, 2023 at 8:27 AM
Subject: RE: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>

Hi,
Hi Susan,
I had Valley Paint that provides our Lacquer Thinner update the SDS. It is attached.

As a general rule, they do not publish Product Data Sheets/Technical Data Sheets for customer-
specific thinner products. They can if necessary but it will take some time.
The SDS shows the specific solvents used in the V-098. Hopefully, this will be sufficient. If not let
me know and I'll ask them to start working on a TDS.

Thank you.
Have a very Happy Thanksgiving.

Maren DeBoer
801-910-1553

From: Susan Weisenberg <[e-mail]>
Sent: Tuesday, November 21, 2023 11:19 AM
To: Deboer, Maren <[e-mail]>
Subject: Fwd: request for MSD sheet for dematic lacquer thinner

WARNING: This email originated outside of the company. DO NOT CLICK links or attachments or enter any information
into forms unless you trust the sender and know the content is safe.
Hello Ms. DeBoer, it appears that in the past, inspectors have reviewed the VOC densities of your company's coating
products without analysing the VOC composite vapor pressure of the lacquer thinner. Can you send me a 2023
Product Data Sheet or Technical Data Sheet for your thinner? An example of the type of data that we are looking for
can be found on the attached sheet example (different lacquer thinner product) on page five, Item 9 "Physical and
Chemical Properties". Thanks, I appreciate your help with this.
Susan Weisenberg,
Environmental Scientist
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…5/8
Office: 385-306-6512

---------- Forwarded message ---------
From: Chad Gilgen <[e-mail]>
Date: Tue, Nov 21, 2023 at 11:01 AM
Subject: Re: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>

Hi Susan,

It's not listed on this Safety Data Sheet. It looks like this sheet is from 2021. They need to provide an updated sheet
with the VOC composite vapor pressure. It may also be on a Product Data Sheet or Technical Data Sheet. Sometimes
the Safety Data Sheets don't list everything we need for our purposes and the information can be found on one of the
other two.

Thanks,
Chad

Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Tue, Nov 21, 2023 at 9:10 AM Susan Weisenberg <[e-mail]> wrote:
Hello Chad, can you give me some guidance on how I calculate the composite VOC vapor pressure from this MDS?
Thanks
Susan Weisenberg,
Environmental Scientist
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…6/8
Office: 385-306-6512

---------- Forwarded message ---------
From: Deboer, Maren <[e-mail]>
Date: Mon, Nov 20, 2023 at 11:52 AM
Subject: RE: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>, Deboer, Maren <[e-mail]>
Cc: Chad Gilgen <[e-mail]>

Hi Susan,

Attached is the SDS for the V-098 Dematic Lacquer Thinner.

It is only used as a solvent cleaner.

Let me know if you have any other questions or need any other information.

Thank you,

Maren DeBoer
Senior Environment Health & Safety Professional 
DEMATIC l We Optimize Your Supply Chain

Dematic Corp.
265 South 5200 West
Salt Lake City, UT 84104
Phone: [phone], Cell:  801-910-1553, Teams:  385-831-1355
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…7/8
mailto: [e-mail]
www.dematic.com

PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS E-MAIL!
Important Note: This e-mail may contain trade secrets or privileged, undisclosed or otherwise confidential information. If you have received this e-mail in error, you
are hereby notified that any review, copying or distribution of it is strictly prohibited. Please inform us immediately and destroy the original transmittal. Thank you
for your cooperation.

From: Susan Weisenberg <[e-mail]>
Sent: Thursday, November 16, 2023 8:46 AM
To: Deboer, Maren <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Subject: request for MSD sheet for dematic lacquer thinner

WARNING: This email originated outside of the company. DO NOT CLICK links or attachments or enter any
information into forms unless you trust the sender and know the content is safe.
WARNING: This email originated outside of the company. DO NOT CLICK links or aachments or enter any informaon into
forms unless you trust the sender and know the content is safe.

Hello, I am the Utah DEQ, Air Quality inspector who performed a site inspection at your facility on August 28, 2023.
All inspection memos are reviewed by management and there is sometimes a lag time between the actual
inspection and the final review.

With regards to the VOC containing product list your company submitted, I was asked to get more information
regarding the product referenced as "093 Dematic Lacquer Thinner". All VOC coatings used on metal products are
covered by the attached State Rule R307-350. Can you give me more information about how the product is used? If
the thinner is used as a solvent cleaner, I need to document via a MSD sheet that it meets the standards of R307-
350-7(2):

"Solvent cleaning operations shall be performed using cleaning materials having a VOC composite vapor pressure
no greater than 1 mm Hg at 20 degrees Celsius, unless an add-on control device is used as specified in R307-350-
8".

If the thinner is otherwise used as a way to thin down other applied coatings, I need to document that the addition of
the thinner does not cause the VOC content of the coating to exceed Table 1 R307-350-5.
12/11/23, 10:53 AM State of Utah Mail - RE: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-f:1784385617446767021…8/8

Thank you for your time with this, please contact me if you have any questions.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

KION GROUP AG
Sitz der Gesellschaft | Registered Office: Frankfurt am Main (Germany)
Registergericht | Court of Registration: Frankfurt am Main (Germany), HRB 112163
USt-Id-Nr. | VAT No. DE 815429496
Vorsitzender des Aufsichtsrats | Chairman of the Supervisory Board: Hans Peter Ring
Vorstand | Executive Board: Dr. Richard Robinson Smith (Vorsitzender/CEO), Hasan Dandashly, Valeria Gargiulo,
Christian Harm, Andreas Krinninger, Dr. Henry Puhl, Ching Pong Quek
KION GROUP AG
Sitz der Gesellschaft | Registered Office: Frankfurt am Main (Germany)
Registergericht | Court of Registration: Frankfurt am Main (Germany), HRB 112163
USt-Id-Nr. | VAT No. DE 815429496
Vorsitzender des Aufsichtsrats | Chairman of the Supervisory Board: Hans Peter Ring
Vorstand | Executive Board: Dr. Richard Robinson Smith (Vorsitzender/CEO), Hasan Dandashly, Valeria Gargiulo,
Christian Harm, Andreas Krinninger, Dr. Henry Puhl, Ching Pong Quek
KION GROUP AG
Sitz der Gesellschaft | Registered Office: Frankfurt am Main (Germany)
Registergericht | Court of Registration: Frankfurt am Main (Germany), HRB 112163
USt-Id-Nr. | VAT No. DE 815429496
Vorsitzender des Aufsichtsrats | Chairman of the Supervisory Board: Hans Peter Ring
Vorstand | Executive Board: Dr. Richard Robinson Smith (Vorsitzender/CEO), Hasan Dandashly, Valeria Gargiulo,
Christian Harm, Andreas Krinninger, Dr. Henry Puhl, Ching Pong Quek
12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…1/9
Susan Weisenberg <[e-mail]>
Re: request for MSD sheet for dematic lacquer thinner
1 message
Susan Weisenberg <[e-mail]>Tue, Dec 5, 2023 at 11:36 AM
To: "Deboer, Maren" <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Hello, thanks for providing the additional information. Your current Approval Order is still active and my Section Manager
has determined that a formal compliance action will not be necessary provided that the lacquer thinner is replaced with a
compliant cleaner as you have described.
Please send me an email on the actual date that the product change has occurred. Be sure to include the details that will
document that the new product is in compliance. The applicable cleaner's compliance with R307-350-7 will be checked
again during the next DAQ inspection. If the cleaner is compliant at that time, no enforcement action is recommended.
Let me know if you have any questions.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Mon, Dec 4, 2023 at 1:45 PM Deboer, Maren <[e-mail]> wrote:
Hi,
Just checking in.. Randy Kontz from Valley Paint talked to Chad last week to see if we could come to an
understanding on what we needed to change in our Lacquer Thinner is order to be compliant.

Randy gave us 3 different options to try this week. He said that they would all be in compliance with what you are
requesting. We are going to try them out in the next 2 weeks and decide. We have enough of our old product V-098
to last until the end of December. The plan will be to switch completely over to the new solvent on January 2, 2024.
My question to you is…. I have an External Audit for our ISO 14001 & 45001 Certification next week. I don’t want
this to show up as a non-conformance because we are actively fixing the issue. Can you verify that our permit is
active and we are still in compliance while we are switching to this new solvent?

Thank you so much for talking through this issue with Valley Paint. I appreciate your willingness to solve this and
make things better and safer for everyone.

Maren DeBoer
Senior Environment Health & Safety Professional 
12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…2/9
DEMATIC l We Optimize Your Supply Chain

Dematic Corp.
265 South 5200 West
Salt Lake City, UT 84104
Phone: [phone], Cell:  801-910-1553, Teams:  385-831-1355
mailto: [e-mail]
www.dematic.com

PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS E-MAIL!
Important Note: This e-mail may contain trade secrets or privileged, undisclosed or otherwise confidential information. If you have received this e-mail in error, you are
hereby notified that any review, copying or distribution of it is strictly prohibited. Please inform us immediately and destroy the original transmittal. Thank you for your
cooperation.

From: Susan Weisenberg <[e-mail]>
Sent: Tuesday, November 28, 2023 11:35 AM
To: Deboer, Maren <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Subject: Fwd: request for MSD sheet for dematic lacquer thinner

WARNING: This email originated outside of the company. DO NOT CLICK links or attachments or enter any information
into forms unless you trust the sender and know the content is safe.
WARNING: This email originated outside of the company. DO NOT CLICK links or aachments or enter any informaon into
forms unless you trust the sender and know the content is safe.

12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…3/9
Hello, as per my management, we will need a data sheet that documents that the Dematic blend lacquer thinner has a
VOC composite vapor pressure that is no greater than 1 mm Hg at 20 degrees Celsius. Thanks, let me know if
you need more information.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

---------- Forwarded message ---------
From: Chad Gilgen <[e-mail]>
Date: Tue, Nov 28, 2023 at 10:48 AM
Subject: Re: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>

Hi Susan,

Per our discussion this morning, the source needs to provide documentation demonstrating they are in compliance with
that R307-350 solvent cleaning requirement of VOC composite vapor pressure no greater than 1 mm Hg at 20 degrees
Celsius or that they are using an add-on control device (afterburner, RTO, etc.) to control emissions.

If they can't provide that information, then we will need to issue them a Compliance Advisory as it looks like they could
be using a high-VOC coating component for cleaning which is not it's intended purpose.

Thanks,
Chad

Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…4/9

On Wed, Nov 22, 2023 at 8:40 AM Susan Weisenberg <[e-mail]> wrote:
This is the response I received from Dematics. The updated sheet still doesn't include the vapor pressure data.
Apparently they have a specific blend that is custom made. Is there a way that a total vapor pressure can be
calculated from the listed VOC containing components?
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

---------- Forwarded message ---------
From: Deboer, Maren <[e-mail]>
Date: Wed, Nov 22, 2023 at 8:27 AM
Subject: RE: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>

Hi,
Hi Susan,
I had Valley Paint that provides our Lacquer Thinner update the SDS. It is attached.

As a general rule, they do not publish Product Data Sheets/Technical Data Sheets for
customer-specific thinner products. They can if necessary but it will take some time.
The SDS shows the specific solvents used in the V-098. Hopefully, this will be sufficient. If not
let me know and I'll ask them to start working on a TDS.

Thank you.
Have a very Happy Thanksgiving.

Maren DeBoer
801-910-1553

12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…5/9
From: Susan Weisenberg <[e-mail]>
Sent: Tuesday, November 21, 2023 11:19 AM
To: Deboer, Maren <[e-mail]>
Subject: Fwd: request for MSD sheet for dematic lacquer thinner

WARNING: This email originated outside of the company. DO NOT CLICK links or attachments or enter any
information into forms unless you trust the sender and know the content is safe.
Hello Ms. DeBoer, it appears that in the past, inspectors have reviewed the VOC densities of your company's coating
products without analysing the VOC composite vapor pressure of the lacquer thinner. Can you send me a 2023
Product Data Sheet or Technical Data Sheet for your thinner? An example of the type of data that we are looking for
can be found on the attached sheet example (different lacquer thinner product) on page five, Item 9 "Physical and
Chemical Properties". Thanks, I appreciate your help with this.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

---------- Forwarded message ---------
From: Chad Gilgen <[e-mail]>
Date: Tue, Nov 21, 2023 at 11:01 AM
Subject: Re: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>

Hi Susan,

It's not listed on this Safety Data Sheet. It looks like this sheet is from 2021. They need to provide an updated sheet
with the VOC composite vapor pressure. It may also be on a Product Data Sheet or Technical Data Sheet.
Sometimes the Safety Data Sheets don't list everything we need for our purposes and the information can be found
on one of the other two.

Thanks,
Chad

Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…6/9

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Tue, Nov 21, 2023 at 9:10 AM Susan Weisenberg <[e-mail]> wrote:
Hello Chad, can you give me some guidance on how I calculate the composite VOC vapor pressure from this
MDS? Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

---------- Forwarded message ---------
From: Deboer, Maren <[e-mail]>
Date: Mon, Nov 20, 2023 at 11:52 AM
Subject: RE: request for MSD sheet for dematic lacquer thinner
To: Susan Weisenberg <[e-mail]>, Deboer, Maren <[e-mail]>
Cc: Chad Gilgen <[e-mail]>

Hi Susan,

Attached is the SDS for the V-098 Dematic Lacquer Thinner.

It is only used as a solvent cleaner.

Let me know if you have any other questions or need any other information.

Thank you,

12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…7/9
Maren DeBoer
Senior Environment Health & Safety Professional 
DEMATIC l We Optimize Your Supply Chain

Dematic Corp.
265 South 5200 West
Salt Lake City, UT 84104
Phone: [phone], Cell:  801-910-1553, Teams:  385-831-1355
mailto: [e-mail]
www.dematic.com

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Thank you for your cooperation.

From: Susan Weisenberg <[e-mail]>
Sent: Thursday, November 16, 2023 8:46 AM
To: Deboer, Maren <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Subject: request for MSD sheet for dematic lacquer thinner

WARNING: This email originated outside of the company. DO NOT CLICK links or attachments or enter any
information into forms unless you trust the sender and know the content is safe.
WARNING: This email originated outside of the company. DO NOT CLICK links or aachments or enter any informaon
into forms unless you trust the sender and know the content is safe.
12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…8/9

Hello, I am the Utah DEQ, Air Quality inspector who performed a site inspection at your facility on August 28,
2023. All inspection memos are reviewed by management and there is sometimes a lag time between the actual
inspection and the final review.

With regards to the VOC containing product list your company submitted, I was asked to get more information
regarding the product referenced as "093 Dematic Lacquer Thinner". All VOC coatings used on metal products are
covered by the attached State Rule R307-350. Can you give me more information about how the product is used?
If the thinner is used as a solvent cleaner, I need to document via a MSD sheet that it meets the standards of
R307-350-7(2):

"Solvent cleaning operations shall be performed using cleaning materials having a VOC composite vapor pressure
no greater than 1 mm Hg at 20 degrees Celsius, unless an add-on control device is used as specified in R307-
350-8".

If the thinner is otherwise used as a way to thin down other applied coatings, I need to document that the addition
of the thinner does not cause the VOC content of the coating to exceed Table 1 R307-350-5.

Thank you for your time with this, please contact me if you have any questions.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

KION GROUP AG
Sitz der Gesellschaft | Registered Office: Frankfurt am Main (Germany)
Registergericht | Court of Registration: Frankfurt am Main (Germany), HRB 112163
USt-Id-Nr. | VAT No. DE 815429496
Vorsitzender des Aufsichtsrats | Chairman of the Supervisory Board: Hans Peter Ring
Vorstand | Executive Board: Dr. Richard Robinson Smith (Vorsitzender/CEO), Hasan Dandashly, Valeria
Gargiulo, Christian Harm, Andreas Krinninger, Dr. Henry Puhl, Ching Pong Quek
KION GROUP AG
Sitz der Gesellschaft | Registered Office: Frankfurt am Main (Germany)
Registergericht | Court of Registration: Frankfurt am Main (Germany), HRB 112163
USt-Id-Nr. | VAT No. DE 815429496
Vorsitzender des Aufsichtsrats | Chairman of the Supervisory Board: Hans Peter Ring
Vorstand | Executive Board: Dr. Richard Robinson Smith (Vorsitzender/CEO), Hasan Dandashly, Valeria Gargiulo,
Christian Harm, Andreas Krinninger, Dr. Henry Puhl, Ching Pong Quek
KION GROUP AG
Sitz der Gesellschaft | Registered Office: Frankfurt am Main (Germany)
12/14/23, 10:43 AM State of Utah Mail - Re: request for MSD sheet for dematic lacquer thinner
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-928796513561556850%7Cmsg-a:r303405078141460408…9/9
Registergericht | Court of Registration: Frankfurt am Main (Germany), HRB 112163
USt-Id-Nr. | VAT No. DE 815429496
Vorsitzender des Aufsichtsrats | Chairman of the Supervisory Board: Hans Peter Ring
Vorstand | Executive Board: Dr. Richard Robinson Smith (Vorsitzender/CEO), Hasan Dandashly, Valeria Gargiulo,
Christian Harm, Andreas Krinninger, Dr. Henry Puhl, Ching Pong Quek