DAQ-2024-007121

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DAQC-CI140300001-24
Site ID 14030 (B1)

MEMORANDUM

TO: FILE – SPECIALITY LENS CORPORATION – Polarized Lens Production
Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: March 13, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: February 22, 2024

SOURCE LOCATION: 3955 South 210 West
Salt Lake City, UT 84107
DIRECTIONS: 210 West is also known as Howick Street.

SOURCE CONTACTS: Francisco Martinez, EHS Manager
801-290-3791 [e-mail]
Matt Meldrum, Director of Operations
801-290-3793

OPERATING STATUS: Operating normally.

PROCESS DESCRIPTION: The facility manufactures polarized prescription plastic lens
blanks to sell to optical laboratories. This involves running the
lenses though a series of small chemical dip tanks.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN140300005-16, dated May 5,
2016
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Specialty Lens Corporation - Polarized Lens
Production Facility

3955 South 210 West 3955 South 210 West
Salt Lake City, UT 84107 Salt Lake City, UT 84107

SIC Code: 3851: (Opthalmic Goods)

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]

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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: In Compliance. No limits appear to have been exceeded. No modifications have been
made to equipment or process. Records are kept and were provided for review at the time
of inspection. The facility appears to be well maintained and operated properly. No
reportable breakdowns have occurred since the previous inspection. A 2022 emission
inventory was submitted to DAQ.

Section II: SPECIAL PROVISIONS

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

II.A.1 Polarized Lens Production Facility

II.A.2 Exhaust Port 1
Vents emissions from the mold cleaning process

II.A.3 Exhaust Port 2
Vents emissions from the lens cleaning process

II.A.4 Exhaust Port 3
Vents warm air from the drying process
- listed for informational purposes only -

II.A.5 Exhaust Port 4
Vents emissions from the film cleaning process and the lens coating process

II.A.6 Exhaust Port 5
Vents emissions from the film glue and film cleaning process

II.A.7 Exhaust Ports 6, 7, and 8
Vents emissions from the MR-7 Process
The MR-7 process includes film assembly, MR-7 monomer blending, curing, disassembly, and
associated activated carbon filters

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II.A.8 Exhaust Port 9
Vents emissions from the acid fan separator

II.A.9 Various Activated Carbon Filters
Used to control emissions from the MR-7 process

II.A.10 Acid Fan Separator
Used to control emissions from the sulfuric acid lens cleaning process

II.A.11 Various Polarized Lens Producing Equipment
Status: In Compliance. The equipment observed on site was consistent with that listed.
II.B Requirements and Limitations

II.B.1 Site Wide Requirements

II.B.1.a The activated carbon filter system shall control process streams from the Monomer Blending and
Curing operations of the MR-7 process. All exhaust air streams from the MR-7 process shall be
routed through the activated carbon filter system before being vented to the atmosphere. The
owner/operator shall operate and maintain the activated carbon filters to avoid any
breakthroughs, and shall replace the filter modules in accordance with the manufacturer's
recommendations and instructions. [R307-401-8]

Status: In Compliance. All exhaust air streams from the MR-7 process were observed to be
routed through the carbon filter system prior to being vented to the atmosphere. Based on
manufacturer's instructions and Roto Aire monitoring, the east and west filter modules are
replaced on a two-year schedule. The last replacement was done in March of 2022. Mr.
Martinez stated that it would show up on their PM schedule to replace the filters again
shortly.

II.B.1.b The acid fan separator shall control process streams from the sulfuric acid lens cleaning process.
All exhaust air streams from the sulfuric acid lens cleaning process shall be routed through the
acid fan separator before being vented to the atmosphere. The owner/operator shall operate and
maintain the acid fan separator in accordance with the manufacturer's recommendations and
instructions. [R307-401-8]

Status: In Compliance. All exhaust air streams from the sulfuric acid lens cleaning process
were observed to be routed through the acid fan separator prior to being vented to the
atmosphere. Acid fan separator filter pads were maintained and are recommended to be
replaced every two years. The last replacement was done in June of 2022. Mr. Martinez
also stated that the replacement of these filters would also generate on the PM schedule in
the next few months.

II.B.1.c Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10 percent opacity. [R307-401-8]

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

Status: In Compliance. No visible emissions were observed during the inspection.

II.B.2 VOC and HAP Limitations.

II.B.2.a The on-site emissions of VOCs and HAPs from the coating process, the activated carbon filter
system, the acid fan separator, and all other associated operations shall not exceed:

38.05 tons per rolling 12-month period for VOCs
2.28 tons per rolling 12-month period for methanol,
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148 pounds per rolling 12-month period for methyl isobutyl ketone,
0.45 tons per rolling 12-month period for glycol ether, and
2.82 tons per rolling 12-month period for all HAPs combined.

[R307-401-8]

II.B.2.a.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. [R307-401-8]

II.B.2.a.2 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,
thinners, 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

E. The amount of VOC and 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/2,000 lb)

HAP = [% HAP by Weight/100] x [Density (lb/gal)] x [Gal Consumed] x (1 ton/2,000 lb)

F. The amount of VOC or HAP emitted monthly from all materials used.

G. The amount of VOCs or HAPs reclaimed or controlled 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. VOC and HAPs are calculated as directed. The 12-month rolling
totals for the corresponding period are as follows:

7.54 tons of VOC
0.68 tons of methanol
20 pounds of MIK
0.02 tons of glycol ether
0.71 tons of combined HAPs

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Solvent Cleaning [R307-304]

Status: Exempt due to applicability of R307-353.

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Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No visible emissions were observed during the inspection. The grounds are
paved and landscaped.

Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. All VOC containing materials were properly stored. No spills were observed.

Plastic Parts Coatings [R307-353]

Status: In Compliance. All coatings used meet the 6.7 pounds/gallon for optical coatings. The coatings
are applied by flow coater. Records are kept and VOC materials are properly applied and stored.
The source uses the solvent Methyl Pyrrolidone which has a vapor pressure of 0.0024 mm Hg@ 20 C,
which meets the standard set in 353-7(2) of 1 mm Hg @ 20 C.

EMISSION INVENTORY:

Listed are the Actual Emissions Inventory provided from Specialty Lens Corporation - Polarized Lens
Production Facility. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN140300005-16, dated May 5, 2016 is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Volatile Organic Compounds 38.05 4.93482

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Glycol Ethers (CAS #EDF109) 900
Methanol (CAS #67561) 4560 1,366
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 180 34.14

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN140300005-16,
dated May 5, 2016: Specialty Lens Corp. should be considered in
compliance. The facility appeared to be well maintained and
operated properly. Records were made available for review at the
time of inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal. Eye protection is needed to tour the facility.
The source shuts down the last two weeks of October to conduct
inventory accounting.

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NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form.