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HomeMy WebLinkAboutDAQ-2024-006890State of Utah GARYR. HERBERT Govemor GREGBELL Lieutenant Govemor Do.run*ent of Environmental Quality Amanda Smith Exgcative Director DTVISION OF AIR QUALITY Bryce C. Bird Director cs DAQE-AN14t670007-13 February 12,2013 Daren Koldewyn Autoliv ASP, lncorporated 3350 Airport Road Ogden, UT 84405 DearMr. Koldewyn: Re: Approval Order: Modification and Combination of Approval Orders DAQE-AN0141670005-11 Dated August9,20l1 and DAQE-AN1602005-03 Dated May 20,2003 Project Number: N14167-0007 The attached document is the Approval Order for the above-referenced project. Future correspondence on this Approval Order should include the engineer's name as well as the DAQE number as shown on the upper right-hand corner of this letter. The project engineer for this action is Ms. Heather Mickelson, who may be reached at (801) 536-4014. Sincerely, 4*L/A/ ery6c.sira Director BCB:HM:dn cc: Weber-Morgan Health Department 195 North 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 1M820. Salt Lake City, UT 841144820 Telephone (801) 536-4000. Fax (801) 5364099. T.D.D. (801) 5364414 www.deq.utah.gov Printed on 1007o recycled paper STATE OF UTAH Department of Environmental Quality Division of Air Quality APPROVAL ORDER: Modification and Combination of Approval Orders DAQE-AN0141670005-11 Dated August 9, 20lL and DAQE-AN1602005-03 Dated May 20, 20A3 Prepared By: Ms. Heather Mickelson, Engineer Phone: (801) 536-4014 Email: hmickelson@utah.gov APPROVAL ORDER NUMBER DAQE-ANt4t670007-13 Date: Februaryl2r20l3 Autoliv ASP, Incorporated Source Contact: Daren Koldewyn, Environmental Coordinator Phone: (801) 620-8286 Email: DarenXoldewyn@autoliv.com 4r-c4/ Bryce C. Bird Director Abstract Autoliv ASP, Incorporated (Autoliv) is seeking a modification of its Approval Order (AO). It is adding a natural gas-fueled oven with afterburner with a combined rating of 0.39 MMBtulhr. The December 16, 2011 name and ownership change for the plastics laminate plant aggregated the airbag module manufacturing plant, plastic laminate plant, and automotive airbag manufacturing plant. They have the same owner, SIC code, and the plants are adjacent to each other. With this modification, the two AOs for the plastic laminate plant (DAQE-AN0141670005-11 dated August 9,2011) and the airbag module manufacturing plant (DAQE-AN16020005-03 dated May 20,2003) were combined into one AO. Autoliv has requested that the AO for the automotive airbag manufacturing plant (DAQE-ANI0025001 l- 1i dated November 29,2011) have a separate AO. When either of these two AOs is modified or amended, the cumulative emissions will be used to evaluate the source. The original AO for each piece of equipment is listed in the equipment list, and the limits specific to each plant are included in the requirements and limitation section of this AO. Methyl ethyl ketone was removed from the EPA's list of IIAPs on December 19,2005. Therefore, methyl ethyl ketone is being removed from the airbag module manufacturing plant's limit. The cumulative limit for the plant's tIAPs has not been altered. The adhesive spray booth was also removed with this modification. Autoliv is located in Ogden (Weber County). The location is in a nonattainment area for the NAAQS for PMro and PM2 5 and a maintenance area for CO. MACT (40 CFR Part 63 Subpart ZZZZ) regulations apply to this source. Currently, area sources subject to 40 CFR Part 63 Subpart ZZZZ are exempt from the Title V program. Therefore, Title V does not apply to this source. The emissions, in tons per year, will change as follows: NO,. (+) 0.004, SO, (+1 0.001, CO (+) 0.14, VOC (+) 0.01, PMro (+) 0.0i, PM2 5 (+) 0.01, CO2e (+; 201, and IIAPs (+) 0.003. The potential to emit totals for the two combined AOs and the additional equipment, in tons per year, are as follows: NO* : 4.92, SO2 : 0.11, CO : 16.92, VOC : 66.53, PMro : 2.71,PM25:231, CO2e : 7310, and HAPs = 20.64. The potential to emit totals for the entire site, including all AOs, and the new equipment, in tons per year, are asfollows: NO*:20.66,502:0.34,CO:52.26,VOC:7l.36,PMro:4.00,PM25:4.00,CO2e: 8,328, and HAPs : 22.35. PM2 5 emissions are a subset of PMle emissions. This air quality AO authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order. This AO is issued to, and applies to the following: Name of Permittee: Autoliv ASP, Incorporated 3350 Airport Road Ogden, UT 84405 UTM coordinates: SIC code: Permitted Location: Autoliv ASP, Incorporated 1000 West 3300 South Unit 7 Ogden, UT 84401 415,687 m Easting, 4,561,888 m Northing, UTM Zone 12 3 799 (Transportation Equipment, NEC) Section I: GENERAL PROVISIONS set forth in this AO shall not be exceeded without prior approval. [R307-401]I.1 The limits r.2 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] 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] 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] The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. 1R307-ls0l The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. |-R307- 1071 AII 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] Section II: SPECIAL PROVISIONS The approved installations shall consist of the following equipment: Autoliv Plastic parts coating plSnt and airbag module manufacturing plant Oven and After Burner Combined rating: 0.39 MMBtU/hr New equipment Coating Line Adhesion-promoter spray booth, ozonation-adhesion-promoter system, topcoat spray booth, curing oven, touch-up spray booth, and high-volume low-pressure spray guns Previously included in AO DAQE-ANO141670005-11, dated August 9,2011 Air Make-Up Unit Natural gas fueled: 6.084 MMBtU/hr Previously included in AO DAQE-AN0141670005-11, dated August 9,2011 Emergency Generator Engines Number of engines: Three (3) T,4 I.5 I.6 t.7 II.A II.A.I TT.A.2 II.A.3 II.A.4 II.A.5 DAQE-ANI41670007-1, Phge 4 Manufacturer: Kohler* Fuel: NaturalGas Output: 78 kW - Each Previously included in AO DAQE-ANI602005-03 dated May 20,2003 II.4.6 Emergency Generator Engine Number of engines: One (1) Manufacturer: Caterpillar* Fuel: Diesel Output: 230 kW Previously included in AO DAQE-AN1602005-03 dated May 20,2003 II.A.7 Paint Spray Booth Manufacturer: SprayKing* Particulate control: Fiberglass or polyester filters Previously included in AO DAQE-AN1602005-03 dated May 20,2003 II.A.8 Boilers Number of boilers: Two (2) Manufacturer: Lochinvar ** Fuel: Natural gas Rating: Less than 5 MMBtu/hr - each Previously included in Ao DAQE-AN1602005-03 dated May 2o,z0o3 II.A.9 Miscellaneous Natural Gas-Fueled Equipment boilers and space heaters ** Rating: Each less than 5 MMBtu/hr Combined rating: 10 MMbtu/tr Previously included in Ao DAQE-AN1602005-03 dated May 20,zoo3 II.A.10 Unconfined-Abrasive Blast Booth Number of units: one (l) Previously included in Ao DAQE-ANI602005-03 dated May 20,2003 II.A.l I Miscellaneous Equipment lnjection molding machines* * Parts washers** Airbag module production equipment* * Plant maintenance** Offices** Laboratories** Forklifts** and other non-road mobile equipment** (propane, gasoline, or diesel fueled) Previously included in Ao DAQE-ANI602005-03 dated May 20,2003 * This equipment-specific detail is listed for informational purposes onlyx* This equipment is listed for informational purposes only DAQE-AN141670007-13 Page 5 II.B Requirements and Limitations II.B.I Source-Wide Conditions i II.B.l.a Autoliv shall notifu the Director in writing when the new equipment listed has been installed II.B.l.a.l and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. [R307-401-18] If the construction and/or installation has not been completed within l8 months from the date of this AO, the Director shall be notified in writing on the status of the construction and/or installation. At that time, the Director shall require documentation of the continuous construction and/or installation of the operation and may revoke the AO. [R307-401-18] Visible emissions from any stationary point associated with the source or with the control facilities shall not exceed the following: A. Air Make-Up Unit - 5oh opacity B. Oven -10% opacity C. All natural gas-, propane-, and gasoline-fueled combustion-device exhaust stacks - 10% opacity D. All paint-booth exhaust stacks - l}%opacity E. All diesel-fuel-combustion exhaust stacks - 20% opacity F. Outdoor abrasive blasting operations - 20% opacity G. All natural gas-fueled emergency generator engines - 10% opacity H. All building exhaust stacks - 10% opacity I. All other points including fugitive emissions - 20% opacity. 1R307-305-3, R307-40 I -81 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9 or methods as approved by the Director. [R307-401-8] The VOC- and/or FlAP-containing materials shall be stored in covered containers (except when in use). VOC- and/or [IAP-laden rags shall also be stored in covered container. [R307-32s-3] Each HAP is limited to less than 8.19 tons per rolling l2-month period for the airbag module manufacturing plant and the plastic laminate plant combined. [R307-401-8] For each FIAP, the emissions from the airbag module manufacturing plant and the plastic laminate plant shall be combined to determine the rolling 12-month total. No later than 20 II.B.l.b II.B.1.b.1 II.B.1.c rLB.l.d II.B.1.d.l DAQE-ANl41670007-lo TT.B.2 II.B.2.a II.B.2.a.1 ILB.2.b II.8.2.b.1 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. [R307-401-8] Airbae Module Manufacturine Plant Limits (Previouslv Permit DAOE-AI[1602005-03 Dated Mav 20.2003) The following consumption limits in the airbag module manufacturing plan shall not be exceeded: 1,000 pounds of sand-blasting media per rolling l2-month period 6,000,000 gallons of propane per rolling l2-month period 3,000,000 gallons of gasoline per rolling 12-month period 3,000,000 gallons of diesel fuel #2 per rolling 12-month period 60,000,000 cubic feet of natural gas per rolling 12-month period 1R307-401-81 Compliance with each limitation shall be determined on a rolling l2-month total. No later than20 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of material supplier billing records. The records of consumption shall be kept on a monthly basis. [R307-401-8] The airbag module manufacturing plant VOC and HAP emissions shall not exceed: 5.84 tons per rolling l2-month period for VOCs 0.25 tons per rolling l2-month period for formaldehyde 0.25 tons per rolling l2-month period for glycol ethers 3.26 tons per rolling l2-month period for the combined following fIAPs: acetonitrile, benzene, cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, stlrrene, toluene, trichlorgethylene, and xylene.*** 3.76 tons per rolling i2-month period for all the above listed FIAPs *** Ary individual FIAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for in R307-410-4. The above VOC and HAP limits do not include the products of incomplete combustion generated by the emergency generator engines, boilers, or assorted fuel burning equipment items. [R307-401-8] 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 l2-month total shall be calculated using data from the previous l2 months. [R307-401-8] The VOC and FIAP 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: tr.8.2.b.2 DAQE-ANl 41670007-13 Page 7 II.8.2.b.3 II.B.3 II.B.3.a ILB.3.a.1 A. Name of the VOC- or [IAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used.(pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOC or FIAP emitted monthly by each material used shall be calculated by the following procedure: VOC: (% VOC by Weight)/I0O 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 tor/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 FIAP emissions. 1R307-401-81 To demonstrate compliance with those HAPs that have an emission limit less than its ETV, Autoliv shall compare the actual maximum emission rate to the ETV and maintain records of this comparison for each month of operation. This comparison shall be performed no later than 20 days after the end of each month. [R307-401-8] Plastic Laminate Plant Limits (Previous Permit DAOE-AN0141670005-11 Dated Aueust 9.2011) Emissions from the coating line (including but not limited to thinners, cleaning solvents, top coating, catalysts, and adhesion promoters) shall not exceed the following limits: 60.00 tons per rolling l2-month period for VOCs 4.44 tons per rolling l2-month period for toluene 12.44 tons per rolling l2-month period for combined HAPs, which include: cumene, ethyl benzene, methyl isobutyl ketone, and xylenes (isomers and mixture). [R307-401-8] 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 l2 months. [R307-401] The VOC or HAP emissions shall be determined by maintaining a record of VOC- or HAP- emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC- or HAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. 1I.8.3.a.2 DAQE-AN141670007- Page 8 II.B.4 II.B.4.a II.B.4.a.l 11.8.4.a.2 rI.B.4.b II.8.4.b.1 II.B.5 II.B.5.a B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or IIAP in each material used D. Gallons of each VOC- or FlAP-emitting material used E. The amount of VOC or HAP emitted monthly by each material used shall be calculated by the following procedure: VOC: (% VOC by Weight)/I00 x [Density (lb/gal)] x Gal Consumed x (l ton/2000 lb) HAP : (%HAP by Weight)/l00 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 fIAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monlhly total VOC or HAP emissions. [R307-401-8] Emergency Generator Engine Requirements Emergency generator engines shall be used for electricity-producing operation only during the periods when electric power from the public utilities is intemrpted. Each emergency generator engine shall not exceed 100 hours ofoperation for regular maintenance and testing. [R307-401-8,40 CFR 63 Subpart ZZZZ] Records documenting emergency generator engine usage shall be kept in a log; and they shall show the date the generator engine was used, the duration in hours of the generator engine usage, and the reason for each generator engine usage. [R3 07-40 1 -8] To determine compliance with the hour limitation for the emergency generator engine's maintenance and testing operations, a rolling l2-month total shall be calculated by the twentieth day of each month using data from the previous l2 months. [R307-401-8] The sulfur content of any fuel oil or diesel burned in any emergency generator engines shall not exceed l5 ppm by weight. [R307-401-8] The sulfur content shall be determined by ASTM Method D-4294-89,or approved equivalent. Certification of fuels shall be either by Autoliv's own testing, or test reports from the fuel marketer. [R307-401-8] Atrrasive Blasting Req uirement Autoliv shall comply with all applicable abrasive-blasting requirements. DAQE-AN1 41670007-r3 Page 9 Section trI: APPLICABLE FEDERAL REOUIREMENTS ln 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. MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating lnternal Combustion Engines PERMIT HISTORY This AO is based on the following documents: Supersedes Supersedes Is Derived From lncorporates lncorporates lncorporates Incorporates DAQE-AN0I4 1670005-1 I dated August 9, 20ll DAQE-ANI 602005-03 dated May 20, 2003 NOI dated May 2,2012 Additional Information dated July 6,2012 Additional lnformation dated August 30, 2012 Additional Information dated October 8,2012 Additional lnformation dated October 77,2012 ADMINISTRATI\TE CODING The following information is for UDAQ internal classification use only: Weber County CDS B MACT (Part 63), Nonattainment or Maintenance Area, t,DAeE-AN l4t6ioooi-rt Page 10 40 CFR AO BACT CAA CAJA.A CDS CEM CEMS CFR CMS CO Coz COze COM DAQ DAQE EPA FDCP GHG GWP HAP or FIAPs ITA LB/I{R MACT MMBTU NAA NAAQS NESHAP NOI NO* NSPS NSR PMro PMz s PSD PTE R307 R307-401 Soz Title IV Title V TPY UAC UDAQ VOC ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: Title 40 ofthe Code of Federal Regulations ApprovalOrder Best Available Control Technology Clean AirAct Clean Air Act Amendments Classification Data System (used by EPA to classifi sources by size/type) Continuous emissions monitor Continuous emissions monitoring system Code of Federal Regulations Continuous monitoring system Carbon monoxide Carbon Dioxide Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-l Continuous opacity monitor Division of Air Quality (typically interchangeable with UDAQ) This is a document tracking code for internal UDAQ use Environmental Protection Agency Fugitive dust control plan Greenhouse Gas(es) - 40 CFR 52.21(b)(49)(i) Global Warming Potential - 40 CFR Part 86.1818-12(a) Hazardous air pollutant(s) Intent to Approve Pounds per hour Maximum Achievable Control Technology Million British Thermal Units Nonattainment Area National Ambient Air Quality Standards National Emission Standards for Hazardous Air Pollutants Notice of lntent Oxides of nitrogen New Source Performance Standard New Source Review Particulate matter less than 10 microns in size Particulate matter less than 2.5 microns in size Prevention of Significant Deterioration Potential to Emit Rules Series 307 Rules Series 307 - Section 401 Sulfur dioxide Title tV ofthe Clean Air Act Title V of the Clean Air Act Tons per year Utah Administrative Code Utah Division of Air Quality (typically interchangeable with DAQ) Volatile organic compounds eNEw t::"., REVTEW sEcrroa SITE ID # AND PROJECT #: N141670007-13 COMPANY NAME: Autoliv ASP, Incorporated REGARDING: Modification and Combination of Approval Orders DAQE- AN0141670005-11 Dated August 9,2011 and DAQE- AN01602005-03 Dated May 20,2003 Completeness determination Modeling review of ITA Peer review ofproject Section Manager sign off Branch Manager sign off August 22,2012 December 5,2012 August 28,2012 December 19,2012 SE CHOOSE ON Heather Mickelson ModelerNSR Enqiang He Alan Humpherys Reginald Olsen S CATEGORIZED AS REVIEWED BY AND DOCUMENT SIGN OFF DATES: IHE AI IACHED DOUUMEN I I5 UA D AS: (PLEA E UNE NEWSPAPER NOTTCE (NN)Office Tech signs cover letter of Newspaper Notice INTENT TO A?PROVE (ITA)Cover letter and ITA signed by associated Section Manager Electronic Copv ofITA sent to Ron Reece APPROVAL ORDER (AO)Copy of purple sheet and cover letter of AO to Teri Weiss EXPERIMENTAL AO Copy of purple sheet and cover letter of AO to Teri Weiss CORRESPONDENCE Signatory varies SOIL REMEDIATION If associated fee, send copy of purple sheet and letter to Teri Weiss SALES TAX EXEMPTION (TAX) SMALL SOURCE EXEMPTION Copy of purple sheet and lefter to Teri Weiss EMISSIONS BANKING LETTER Copy of lefter to Camron Harry NAME CHANGE Copy of purple sheet and letter to Teri Weiss COPIES TO BE SENT TO THE FOLLOWING AKIIES: (PLEASE CHEUK AS IHHY APPL {Manila File Folder (working file)./Greens Folder Health Department (see letter for which)EPA - Mike Owens Compliance (associated Section Manager)Finance - Teri Weiss Name Change Letters: Deborah McMunrie Susan Weisenberg Dave Beatty Brett Wilding, Utah State Tax Commission, Technical Research Unit Offsets Used? Copy of document(s) to Camron Harry Enter final Name Change Letters in /engineer/aoname Copy To: Enter in /engineer/aocond & in AO Log: (AOs, AO not needed, Replacement in Kind) NEWSPAPER NOTICE _ COPIES TO: Cities, Counties, Gov. Agencies, & etc./& a copy of Public Official letter with self-addressed envelope E-Mail To: dvd.kvd@uno.com, Jodie Swanson, Lori Walker, Debbie Obemdorfer, Bill Sinclair, Beverly Rasmussen & Jen Burge, Donna Spangler, Ron Reece, and Kelly Beck E-Mail copy & Fax to Newspaper Agencies PSD PROJECTS: Copy the NOI, Engineering Review, ITA, NOTICE & AO Send to: Mike Owens, EPA Don Banks, Bureau of Land Management Chris Hocket, U.S. Forest Service Chris Shaver, National Park Service TITLE V: Check W NSR Engineer for which document(s) to be copied. @ ilils a SITE ID # AND PR COMPANY NAME: REGARDING: Completeness determ ination Modeling review of ITA Peer review ofproject Section Manager sign off Branch Manager sign off N141670007-12 Autoliv ASP, Incorporated Modification to Approval Order and Combination DAQE-AN0141670005- I 1 Dated August 9, 20ll DAQE-AN0 I 602005-03 Dated May 20, 2003 August 22,2012 of AOs and THE TT C REVIEWED BY AND DOCUMENT SIGN OFF DATES: Heather Mickelson ModelerNSR August 28,2012 ^ Enqiang He l1- i1 - I e - W* for -TimothY Andrus Reginald Olsen A ACHED DOCUMENT IS CATEGOR IZED AS: (PLEASE CHOOSE ONE {NEWSPAPER NOTICE (NIN)Otlice Tech signs cover letter of Newspaper Notice ./INTENT TO APPROVE OTA) Cover letter and ITA signed by associated Section Manager Electronic Copv of ITA sent to Ron Reece APPROVAL ORDER (AO)Copy of purple sheet and cover letter of AO to Teri Weiss EXPERIMENTAL AO Copy of purple sheet and cover letter of AO to Teri Weiss CORRESPONDENCE Signatory varies SOIL REMEDIATION Ifassociated fee, send copy ofpurple sheet and letter to Teri Weiss SALES TAX EXEMPTION (TAX) SMALL SOURCE EXEMPTION Copy of purple sheet and letter to Teri Weiss EMISSIONS BANKING LETTER Copy of letter to Camron Harry \z NAME CHANGE Copy of purple sheet and letter to Teri Weiss N3 COPIES TO BE SENT TO THE FOLLOWING PARTIES: (PLEASE CHECK AS THEY APPLY 1 Manila File Folder (working file)Greens Folder llealth Department (see letter lor which)EPA - Mike Owens Compliance (associated Section Manaser)f: ^^ii^,, t h ^\,, -l z. , t.Txtt a f--+'Finance - Teri Weiss NalieChangULetters: t -t I Deborah McMurtrie Susan Weisenbers Dave Beattv Brett Wilding, Utah State Tax Commission, Technical Research Unit Offsets Used? Copy of document(s) to Camron Harry Enter final Name Change Letters in /engineer/aoname ,Copy To:Enter in /engineer/aocond & in AO Log: (AOs, AO not needed, Replacement in Kind) NE.WSPAPER NOTICE _ COPIES TO: idelo... (owtf\ Cities. Counties. G&. Agencies. & etc./& a copy of Public Olficial letter with self-addressed envelone Nasdrh tto,r\ &q,*l a0^,,v,1 ' E-Mail To: dvd.kvd@.jYno.com. Jodie Swanson. Lori Walker, Debbie Oberndorfer, Bill Sinclair, Beverly Rasmussen & Jen Burge, Donna Spangler, Ron Reece, and Kelly Beck E-Mail copy & Fax to Newspaper Aeencies PSD PROJECTS: Copy the NOI, Engineering Review, ITA, NOTICE & AO Send to: Mike Owens, EPA Don Banks, Bureau of Land Management Chris Hocket, U.S. Forest Service Chris Shaver, National Park Service TITLE V: Check W NSR Engineer for which document(s) to be copied. f*o* o State of Utah GARYR. HERBERT Governor GREG BELL Lieulenant Governor Department of Environmental Quality Amanda Smith Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director ,Ftrlt,u{@v DAQE-rN141670007-12 December 20,2012 Daren Koldewyn Autoliv ASP, Incorporated 3350 Airport Road Ogden, UT 84405 Dear Mr. Koldewyn: Re: Intent to Approve: Modification and Combination of Approval Orders DAQE-AN0141670005- I 1 Dated August 9 , 2011 and DAQE-AN0 I 602005-03 Dated May 20, 2003 Project Number: N14167-0007 The attached document is the Intent to Approve for the above-referenced project. The lntent to Approve is subject to public review. Any comments received shall be considered before an Approval Order is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an Approval Order. An invoice will follow upon issuance of the final Approval Order. Future correspondence on this Intent to Approve should include the engineer's name as well as the DAQE number as shown on the upper right-hand corner of this letter. The project engineer for this action is Ms. Heather Mickelson, who may be reached at (801) 536-4014. Sincerely, lo'Timothy R. Andrus, Manager New Source Review Section TRA:HM:sa Weber-Morgan Health Department 195 North 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 144820. Salt Lake City, UT 841144820 Telephone (801) s364000 . Fax (801) 5364099. T.D.D. (801) 5364414 www.deq.ulah.gov hinted on 100% recycled paper STATE OF UTAH Department of Environmental Quality of Air Quality INTENT TO APPROVE: Modification and Combination of Approval Orders DAQE-ANOI 41670005-11 Dated August 9, 20ll and DAQE-AN01602005-03 Dated May 20,2003 Prepared by: Ms. Heather Mickelson, Engineer Phone: (801) 536-4014 Email: hmickelson@utah.gov INTENT TO APPROVE NUMBER DAQE-IN141670007-12 Date: December 2012012 Autoliv ASP, Incorporated Source Contact: Daren Koldewyn, Environmental Coordinator Phone: (801) 620-8286 d/r"^trM Timothy R. Andrus, Manager New Source Review Section Utah Division of Air Quality ABSTRACT Autoliv ASP, lncorporated (Autoliv) is seeking a modification of its AO. It is adding a natural gas-fueled oven with afterburner with a combined rating of 0.39 MMBtu/hr. The December 16, 201 1 name and ownership change for the plastics laminate plant aggregated the airbag module manufacturing plant, plastic laminate plant, and automotive airbag manufacturing plant. They have the same owner, SIC code, and the plants are adjacent to each other. With this modification, the two AOs for the plastic laminate plant (DAQE-AN0141670005-11 dated August 9,2011) and the airbag module manufacturing plant (DAQE-AN016020005-03 dated May 20,2003) were combined into one AO. Autoliv has requested that the AO for the automotive airbag manufacturing plant (DAQE- AN100250011-11 dated November 29,2011) have a separate AO. When either of these two AOs is modified or amended, the cumulative emissions will be used to evaluate the source. The original AO for each piece of equipment is listed in the equipment list, and the limits specific to each plant are included in the requirements and limitation section of this AO. Methylethyl ketone was removed from the EPA's list of HAPs on December 19,2005. Therefore, methyl ethyl ketone is being removed from the airbag module manufacturing plant's limit. The cumulative limit for the plant's HAPs has not been altered. The adhesive spray booth was also removed with this modification. Autoliv is located in Ogden (Weber County). The location is in a nonattainment area for the NAAQS for PMls and PMz s and a maintenance area for CO. MACT (40 CFR Part 63 Subpart ZZZZ) regulations apply to this source. Currently, area sources subject to 40 CFR Part 63 Subpart ZZZZ are exempt from the Title V program. Therefore, Title V does not apply to this source. The emissions, in tons per year, will change as follows: NO. (+) 0.004, SO2 (+1 0.001, CO (+) 0.14, VOC (+) 0.01, PMrg (+) 0.01, PMz s (+) 0.01, CO2e (+; 201, and HAPs (+) 0.003. The potential to emit totals for the two combined AOs and the additional equipment, in tons per year, are as follows: NO* = 4.92, SOz : 0.1 l, CO : 16.92, VOC : 66.53, PMro : 2.71,PM25:2.77, CO2e = 7310, and FIAPs :2A.64. The potential to emit totals for the entire site, including all AOs, and the new equipment, in tons per year, are as follows: NO* : 20.66, SO2 : 0.34, CO = 52.26, VOC : 71.36, PMro : 4.00, PM2 5 : 4.00, CO2e : 8,328, and HAPs : 22.35. PM2 5 emissions are a subset of PMls emissions. The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and./or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director of the Utah Division of Air Quality. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Ogden Standard Examiner on December 26,2012. During the public comment period the proposal and the evaluation of its impact on air quality will be available'for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7 . The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. DAQE-IN141670007-12 Page 3 Name of Permittee: Autoliv ASP, lncorporated 3350 Airport Road Ogden, UT 84405 UTM coordinates: SIC code: Permitted Location: Autoliv ASP, Incorporated 1000 West 3300 South Unit 7 Ogden, UT 84401 1.2 415,687 m Easting, 4,561,888 m Northing, UTM Zone 12 3799 (Transportation Equipment, NEC) Section I: GENERAL PROVISIONS The limits set forth in this AO shall not be exceeded without prior approval. [R307-a01] 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] 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] 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] The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. [R307- 1s0] The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. 1R307-1071 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] DAQE-rN141670007-12 Page 4 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Autoliv Plastic parts coating plant and airbag module manufacturing plant II.A.2 Oven and After Burner Combined rating: 0.39 MMBtulhr New equipment II.A.3 Coating Line Adhesion-promoter spray booth, ozonation-adhesion-promoter system, topcoat spray booth, curing oven, touch-up spray booth, and high-volume low-pressure spray guns Previously included in AO DAQE-ANO141670005-11, dated August 9,2011 II.A.4 Air Make-Up Unit Natural gas fueled: 6.084 MMBtu/hr Previously included in AO DAQE-AN0141670005-11, dated August 9,2011 II.A.5 Emergency Generator Engines Number of engines: Three (3) Manufacturer: Kohler* Fuel: NaturalGas Output: 78 kW - Each Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.6 Emergency Generator Engine Number of engines: One (l) Manufacturer: Caterpillar* Fuel: Diesel Output: 230 kW Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.7 Paint Spray Booth Manufacturer: SprayKing* Particulate control: Fiberglass or polyester filters Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.8 Boilers Number of boilers: Two (2) Manufacturer: Lochinvar ** Fuel: Natural gas Rating: Less than 5 MMBtu/hr - each Previously included in AO DAQE-AN16020005-03 dated May 20,2003 DAQE-IN14t67ooo7-12 Page 5 II.A.9 II.A.IO II.A.I1 II.B II.B.1.a rI.B.1.b Miscellaneous Natural Gas-Fueled Equipment boilers and space heaters ** Rating: Each less than 5 MMBtU/hr Combined rating: 10 MMbtu/hr Previously included in AO DAQE-AN16020005-03 dated May 20,2003 Unconfi ned-Abrasive Blast Booth Number of units: one (1) Previously included in AO DAQE-AN16020005-03 dated May 20,2003 Miscellaneous Equipment lnjection molding machines* * Parts washers** Airbag module production equipment** Plant maintenance** Offices** Laboratories** Forklifts** and other non-road mobile equipment** (propane, gasoline, or diesel fueled) Previously included in AO DAQE-AN16020005-03 dated May 20,2003 * This equipment-specific detail is listed for informational purposes only.** This equipment is listed for informational purposes only. Requirements and Limitations Source.Wide Conditions Autoliv shall notifr the Director in writing when the new equipment listed has been installed and is operational. To ensure proper credit when notiffing the Director, send your correspondence to the Director, attn: Compliance Section. [R307-401-18] If the construction and/or installation has not been completed within 18 months from the date of this AO, the Director shall be notified in writing on the status of the construction and/or installation. At that time, the Director shall require documentation of the continuous construction and/or installation of the operation and may revoke the AO. [R307-401-18] Visible emissions from any stationary point associated with the source or with the control facilities shall not exceed the following: A. Air Make-Up Unit - 5%o opacity B. Oven - 10%o opacity All natural gas-, propane-, and gasoline-fueled combustion-device exhaust stacks - 10% opacity All paint-booth exhaust stacks - 10% opacity C. D. E. All diesel-fuel-combustion exhaust stacks - 20% opacity DAQE-rN141670007-12 Page 6 II.B.l.b.1 II.B.1.c II.B.l.d II.B.l.d.1 II.B.2 ll.B.2.a 11.8.2.a.1 F. Outdoor abrasive blasting operations - 20% opacity G. All natural gas-fueled emergency generator engines - l0% opacity H. All building exhaust stacks - l0% opacity I. All other points including fugitive emissions - 20% opacity [R307-305-3, R307-40 I -8] Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9 or methods as approved by the Director. [R307-401- 8l The VOC- and/or HAP-containing materials shall be stored in covered containers (except when in use). VOC- and/or HAP-laden rags shall also be stored in covered container. [R307-325-3] Each HAP is limited to less than 8.19 tons per rolling l2-month period for the airbag module manufacturing plant and the plastic laminate plant combined. [R307-401-8] For each HAP, the emissions from the airbag module manufacturing plant and the plastic laminate plant shall be combined to determine the rolling 12-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. [R307-401-8] Airbas Module Manufacturins Plant Limits (Previouslv Permit DAOE-Ai\1602005-03 Dated Mav 20.2003) The following consumption limits in the airbag module manufacturing plan shall not be exceeded: 1,000 pounds of sand-blasting media per rolling l2-month period 6,000,000 gallons of propane per rolling i2-month period 3,000,000 gallons of gasoline per rolling l2-month period 3,000,000 gallons of diesel fuel#2 per rolling l2-month period 60,000,000 cubic feet of natural gas per rolling 12-month period 1R307-401-81 Compliance with each limitation shall be determined on a rolling l2-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of material supplier billing records. The records of consumption shall be kept on a monthly basis. [R307-401-8] The airbag module manufacturing plant VOC and IIAP emissions shall not exceed: 5.84 tons per rolling l2-month period for VOCs 0.25 tons per rolling l2-month period for formaldehyde II.B.2.b DAQE-IN141670007-12 Page 7 II.B.2.b.1 r1.8.2.b.2 0.25 tons per rolling l2-month period for glycol ethers 3.26 tons per rolling l2-month period for the combined following fIAPs: acetonitrile, benzene, cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene, toluene, trichloroethylene, and xylene.** + 3.76 tons per rolling l2-month period for all the above listed FIAPs *** Any individual FIAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for in R307-410-4. The above VOC and HAP limits do not include the products of incomplete combustion generated by the emergency generator engines, boilers, or assorted fuel burning equipment items. 1R307-401-81 Compliance with each limitation shall be determined on a rolling l2-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. [R307-401-8] 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- or flAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOC or FIAP emitted monthly by each material used shall be calculated by the following procedure: VOC = (%VOC by Weight)/l00 x [Density (lbigal)] x Gal Consumed x (l tor/2000 lb) HAP = (%HAP by Weight)i 100 x fDensity (lb/gal)] x Gal Consumed x (l 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] DAQE-rNr41670007-12 Page 8 II.B.2.b.3 To demonstrate compliance with those HAPs that have an emission limit less than its ETV, Autoliv shall compare the actual maximum emission rate to the ETV and maintain records of this comparison for each month of operation. This comparison shall be performed no later than 20 days after the end of each month. [R307-401-8] II.B.3 Plastic Laminate Plant Limits (Previous Permit DAOE-AI[014167000$11 Dated Aueust 9.2011) II.B.3.a Emissions from the coating line (including but not limited to thinners, cleaning solvents, top coating, catalysts, and adhesion promoters) shall not exceed the following limits: 60.00 tons per rolling 12-month period for VOCs 4.44 tons per rolling l2-month period for toluene 12.44 tons per rolling 12-month period for combined HAPs, which include: cumene, ethyl benzene, methyl isobutyl ketone, and xylenes (isomers and mixture) [R307-40 r -8] II.B.3.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 l2-month total shall be calculated using data from the previous 12 months. [R307-401] 11.8.3.a.2 The VOC or HAP emissions shall be determined by maintaining a record of VOC- or HAP- emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC- or HAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOC or FIAP emitted monthly by each material used shall be calculated by the following procedure: VOC: (%YOCby Weight)i 100 x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb) IIAP: (%HAP by Weight)/l00 x [Density (lb/gal)] x Gal Consumed x (l ton/2000 lb) F. The amount of VOC or FIAP 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 IIAP emissions. [R307-401-8] DAQE-rN141670007-12 Page 9 II.B.4 ILB.4.a II.B.4.a.l 11.8.4.a.2 II.B.4.b II.B.4.b.1 II.B.5 II.B.5.a Supersedes Supersedes Is Derived From Incorporates lncorporates Incorporates lncorporates 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. MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines PERMIT HISTORY The final AO will be based on the following documents: Emergencv Gengrator Engine Requirements Emergency generator engines shall be used for electricity-producing operation only during the periods when electric power from the public utilities is interrupted. Each emergency generator engine shall not exceed 100 hours of operation for regular maintenance and testing. [R307- 401-8,40 CFR 63 Subpart ZZZZI Records documenting emergency generator engine usage shall be kept in a log; and they shall show the date the generator engine was used, the duration in hours of the generator engine usage, and the reason for each generator engine usage. [R307-401-8] To determine compliance with the hour limitation for the emergency generator engine's maintenance and testing operations, a rolling l2-month total shall be calculated by the twentieth day of each month using data from the previous 12 months. [R307-401-8] The sulfur content of any fuel oil or diesel burned in any emergency generator engines shall not exceed l5 ppm by weight. [R307-401-8] The sulfur content shall be determined by ASTM Method D-4294-8g,or approved equivalent. Certification of fuels shall be either by Autoliv's own testing, or test reports from the fuel marketer. [R307-401-8] Abrasive Blastine Requirement Autoliv shall comply with all applicable abrasive-blasting requirements. [R307-306] Section tII: APPLICABLE FEDERAL REOUIREMENTS DAQE-AN0141670005-l I dated August 9,201I DAQE-AN0 I 602005-03 dated May 20, 2003 NOI dated May 2,2012 Additional lnformation dated July 6,2012 Additional Information dated August 30, 2012 Additional lnformation dated October 8,2072 Additional lnformation dated October 17,2012 - t, DAQE-IN141670007-12 Page 10 ADMINISTRATIVE CODING The following information is for UDAQ internal classification use only: Weber County CDS B MACT (Part 63), Nonattainment or Maintenance Area ACRONYMS The following lists commonly used acronyms as they apply to this document: 40 CFR AO BACT CAA CAJA.A CDS CEM CEMS CFR CMS CO COz CO2e COM DAQ DAQE EPA FDCP GHG GWP FIAP or HAPs ITA LBlHR MACT MMBTU NAA NAAQS NESHAP NOI NO* NSPS NSR PMro PMz.s PSD PTE R307 R307-401 SOz Title tV Title V TPY UAC UDAQ VOC Title 40 of the Code of Federal Regulations Approval Order Best Available Control Technology Clean Air Act Clean Air Act Amendments Classification Data System (used by EPA to classifo sources by size/type) Continuous emissions monitor Continuous emissions monitoring system Code of Federal Regulations Continuous monitoring system Carbon monoxide Carbon Dioxide Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 Continuous opacity monitor Division of Air Quality (typically interchangeable with UDAQ) This is a document tracking code for internal UDAQ use Environmental Protection Agency Fugitive Dust Control Plan Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(1) Global Warming Potential - 40 CFR Part 86.1818-12(a) Hazardous air pollutant(s) lntent to Approve Pounds per hour Maximum Achievable Control Technology Million British Thermal Units Nonattainment Area National Ambient Air Quality Standards National Emission Standards for Hazardous Air Pollutants Notice of lntent Oxides of nitrogen New Source Performance Standard New Source Review Particulate matter less than 10 microns in size Pirticulate matter less than 2.5 microns in size Prevention of Significant Deterioration Potential to Emit Rules Series 307 Rules Series 307 - Section 401 Sulfur dioxide Title IV of the Clean Air Act Title V of the Clean Air Act Tons per year Utah Administrative Code Utah Division of Air Quality (typically interchangeable with DAQ) Volatile organic compounds State of Utah GARY R. HERBERT Governor GREG BELL Lieutenant Governor Department of Environmental Quality Amanda Smith Exectttive Direclor DTVISION OF AIR QUALITY Bryce C. Bird Direclor rXLT CffiTY DAQE-NNi 41670007-12 December 20,2012 Ogden Standard Examiner Legal Advertising Dept. P.O. Box 12790 Ogden, UT 84412 RE: Legal Notice of lntent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard Examiner on December 26,2012. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions contact Sharon Anderson, who may be reached at (801) 536-4013. Sincerely, *m,w, Utah Division of Air Quality Enclosure cc: Weber County Wasatch Front Regional Council 195 North 1950 West. Salt Lake City, UT Mailing Address: P.O. Box 1M820 - Salt Lake City, UT 841144820 Telephone (801 ) 536-4000 . Fax (801) s364099. T.D.D. (801 ) s364414 ww.deq.utah.gov Printed on 100% recycled paper DAQE-NN14r6m007-t2 Page2 NOTICE A Notice of lntent for the following project submitted in accordance with $R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director, Utah Division of Air Quality: Company Name: Location: Project Description: Autoliv ASP, Incorporated Autoliv ASP, lncorporated - 1000 West 3300 South, Unit 7, Ogden, UT, Weber County Autoliv ASP, lncorporated (Autoliv) is seeking a modification of its Approval Order (AO). It is adding a natural gas-fueled oven with afterburner with a combined rating of 0.39 MMBtu/hr. The December 16, 2011 name and ownership change for the plastics laminate plant aggregated the airbag module manufacturing plant, plastic laminate plant, and automotive airbag manufacturing plant. They have the same owner, SIC code, and the plants are adjacent to each other. With this modification, the two AOs forthe plastic laminate plant (DAQE-AN0141670005-11 dated August 9, 2011) and the airbag module manufacturing plant (DAQE-AN016020005-03 dated May 20,2003) were combined into one AO. Autoliv has requested that the AO for the automotive airbag manufacturing plant (DAQE-AN100250011-11 dated November 29,2011) have a separate AO. When either of these two AOs is modified or amended, the cumulative emissions will be used to evaluate the source. The original AO for each piece of equipment is listed in the equipment list, and the limits specific to each plant are included in the requirements and limitation section of this AO. Methyl ethyl ketone was removed from the EPA's list of HAPs on December 19,2005. Therefore, methyl ethyl ketone is being removed from the airbag module manufacturing plant's limit. The cumulative limit for the plant's HAPs has not been altered. The adhesive spray booth was also removed with this modification. Autoliv is located in Ogden (Weber County). The location is in a nonattainment area for the National Ambient Air Quality Standards (NAAQS) for PMle and PMz s and a maintenance area for CO. Maximum Achievable Control Technolory (MACT) (40 CFR Part 63 Subpart ZZZZ) regulations apply to this source. Currently, area sources subject to 40 CFR Part 63 Subpart ZZZZ are exempt from the Title V program. Therefore, Title V does not apply to this source. The emissions, in tons per year, will change as follows: NO. (+1 0.004, SO2 (+) 0.001, CO (+1 0.14, VOC (+) 0.01, PMrg (+) 0.01, PMz s (+) 0.01, CO2e (+) 201, and FIAPs (+) 0.003. The potential to emit totals for the two combined AOs and the additional equipment, in tons per year, are as follows: NO* : 4.92, SO2 : 0.11, CO :16.92, VOC = 66.53, PMro: 2.71,PMzs=2.77, CO2e: 7310, and HAPs :20.64. The potential to emit totals for the entire site, including all AOs, o 2DAQE-NN141670007-1 Page 3 and the new equipment, in tons per year, are as follows: NO" : 20.66, SOz : 0.34, CO :52.26, VOC: 71.36, PMro:4.00, PM25 :4.00, CO2e: 8,328, and HAPs :22.35. PM2.5 emissions are a subset of PMro emissions. The completed engineering evaluation and air quality impact analysis showed that the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an AO pending a30-day public comment period. The project proposal, estimate ofthe effect on local air quality and draft AO are available for public inspection and comment at the Utah Division of Air Qualrty, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before January 25,2013 will be considered in making the final decision on the approvaUdisapproval of the proposed project. Email comments will also be accepted at hmickelson@utah.gov. If anyone so requests to the Director at the Division in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: December26,2012 I Heather Mickelson - Signed Source PIan Review Page I of I From: Daren Koldewyn <Daren.Koldewyn@autoliv.com> To: "Heather Mickelson (hmickelson(@utah.gov)" <hmickelson(Eutah.gov> Date: 1012412012 2:35 PM Subject: Signed Source Plan Review Attachments: Signed Source Plan Review l0-24-12.pdf Heather, I faxed the signed front page of the Source Plan Review to the 801 536 4099 fax number, but I thought l'd better email you a copy too just in case. Thanks for your help with this project. Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 daren. koldewyn@autoliv. com *************************************************************** Consider the environment before printing this message. To read Autoliv's Informati-on and Confidentiality Notice, fol1ow this l-ink: l::y;((HI;?ll?ilI;::Tl:i::i:iT::;::T1... ** * ** * * * * *** ** * ******* file:i/C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\5O87FCABEQDOMAINEQ.. . 1012412012 Daren Kolderwn Autoliv ASP, lncorporated 3350 Airport Road Ogden. U'l'84405 RF]: Revierv Engineer: Date: Notice of Intent Suhnritted Plant Contact: Phone Number: Far Nurnbtr: Source Lrrcation: UTAH prvrsroN oF ArR ouALlTY SOURCB PLAN RDVIEW t000 West 3300 South Webcr Courrty 4.-561,888 m Northing. I I"fl\4 I)nlrrm: Nr\l)l? Project Number: N 141670007 Moriification to Approval Order rnd Combinatiorr *f AOs DAQE-AN0141670005-l I Dated August 9, ?01 I and DAQE-4NO1602005-0] Datcrl May 20, 2003 Weber County; CDS B; MACT (Part 63). Nonattainrnent and Maintenanee Area I\'ls. Heather Mickelson October ll.20l2 April 25, 2012 Daren Kolderwn (tJ0l ) 62u-EZ86 (801i 620-tt276 [-Jrrit 7, Ogden, l-11' 415,687 rn Easting. Ul'lvl Zone ll D,{.Q requests that a cornpany,/curporation ulllcial rcad the attached draft/proposed Plarr Revierv rvilh Recornn ended Approval Order C]orrditicxrs. ll'this person does not understand or docs not agrec r,vith the conditions" the rcvierv engineer should he contacted within five days after receipt nf the Plan Revieu,. If this person agrees u,,ith tht Plan Rerr,ie."v an<l Reeom*rended Approv*l Order C-'onditions, this persoll shonld sign belorv and return {FAX # 801-536-.10?9) ivithin l0 days after receipt nf the conditions. If the revierv elgineer is not contacted within l0 da3's, the revierv engineer shall assume that the companly'cotpr:ration offrsial agrees with this Plan Revicrv and rvill ;lrocess the Plan Review torvards {'inal approval. A puhlic commenl period rvill be required bef'ore the Approval Order can be issued. Applicant Contact rl" "'_1.-_-_ {Signature rf'l)ette) Enginetring Rcvierv N I I l6:0ft0?: r\uttrliv ;\$P. lncorpr:raterl - I.lodiljcalion to i\ppr=oval (Jrdcr and Combination of ,.\$s DAQE-AN0 I4ltiT0lltli-l I l]aled August 9,3O1 I and DAQ]i-ANOlt;t]llr05-0.1 lJated lilay 20.'J0{13 f]ctober 21, ?01? Page I UTAH DIYISION OT AIR OUAIJITY souRC.[.rtAN R{"$u,w Daren Koldervyn Autoliv ASP. lncr:rporated 3350 Airporl Road Ogclen, LIT 8:1405 RE: Reyierv Engineer: Date: Notice of Intent Subinitted: Plant Contact: Phonc N*mbr.'r: Ir'ar Nnlrrber: Source l,ocation: F'ro_iect Nunrber: N 141670007 tuloclification to Approval Order and Combinalion of AOs DAQE-AN0141670005-l I Dated August 9, ?01I ;rnd DAQ[-r\N01602005-03 Datec! May 20, 2003 Wetrer Countv. CDS B; MAC:|" (Par* 63). Nr:rtattainment or Maintenance Area, Ms. ileathcr Mickclson November 2 1, 3012 April25. ?012 Daren Koldervyn (801) 620-8?86 (80 r ) 6?0-8276 i000 West 3i00 South, Urrit 7. Ogtlc'n, tiT Weber flountv 4.56:.88S rn Northirrg, 41 5.687 nr Easting. IJTM Zone l] t-iT'r"Lt Detum: NADIi D.,\Q requests that a cornpanv/corporation official read the attached draft/5rroposed ['lan Revierv rvith Recorlrnended Approval Order Condltions. [f this person does not understancl or does not agree u'itlr th* conditions, thc revierv eagineer shouhi be contacted rvithin five days zrlier receipt of the Plan Revierv" If tlris person agrees with the Flan Review and Recomlncnded Approval Order C-onditions, this persorr shr:uld sign belorv and return (FAX # 801-536-4099) within l0 da1,'s after rrccipt of the conditions. If the revie$,cngineerisnotcontactedwithin l0days.thereviewengineershallassunrethatthe companv/corporation olEcial agrecs with this Plan Rcvic*' and r,l'ill proccss thc Plan Rcviclv torvards final approval. A public coinrnent period lvill be required beftrre the ;\pproval Order can br issued. Applicant (irntacl FingineeringReviervNl4l6T0D0?: Autolivl\SP, lncnrporatcd-ModificationtoApprovnl OrdcranelConrhinaiionofAOs DAQE-AN0ld 1670005-l I Llated Augusl 9, 2{}l I and DAQI|-ANOl(10!005-03 Dattd Vlay 20, ?001 Novernt er 2l , 201 ? Pagr I ABSTRACT Autoliv ASP, Incorporated (Autoliv) is seeking a modification of its Approval Order (AO). It is adding a natural gas-fueled oven with afterburner with a combined rating of 0.39 MMBtu/hr. The December 16, 201 I name and ownership change for the plastics laminate plant aggregated the three AOs for Autoliv. They have the same owner, SIC code, and the plants are adjacent to each other. With this modification, the two AOs, DAQE-AN0141670005-l I dated August 9,2011 and DAQE- ANO16020005-03 dated May 20,2003, were combined into one AO. The AO for the third plant, DAQE- ANI0025001l-11 dated November 29,201l, was not combined with this AO. When either of these two AOs is modified or amended, the cumulative emissions will be used to evaluate the source. The original AO for each piece of equipment is listed in the equipment list, and the limits specific to each plant are included in the requirements and limitation section of this AO. Methyl ethyl ketone was removed from the EPA's list of HAPs on December 19, 2005. Therefore, methyl ethyl ketone is being removed from the airbag module manufacturing plant's limit. The cumulative limit for the plant's HAPs has not been altered. The adhesive spray booth was also removed with this modification. It was originally included in AO DAQE-AN016020005-03 dated May 20,2003. Autoliv is located in Ogden (Weber County). The location is in a nonattainment area for the NAAQS for PMls and PM2 5 and a maintenance area for CO. Maximum Achievable Control Technology (MACT) (40 CFRPart63SubpartZZZZ)regulationsapplytothissource. Currently,areasourcessubjectto 40CFR Parr 63 Subpaft ZZZZ are exempt fiom the Title V program. Therefore, Title V does not apply to this source. The emissions, in tons peryear, willchange as follows: NO" (+) 0.004, SO2 (+) 0.001, CO (+) 0.14, VOC (+) 0.01 , PM ro (+) 0.01, PM2 5 (+) 0.01 , CO2e (+) 201 , and HAPs (+) 0.003. The potential to emit totals for the two combined AOs and the additional equipment, in tons per year, are as follows: NO* : 4.92, SOr:0.1l, CO:16.92, VOC: 66.53, PMro:2.J1,PM25:2.J1, COue:7310, and FIAPs:20.64. The potential to ernit totals for the three previous AOs and the new equipment, in tons per year, are as follows: NO*:20.66, SO2:0.34, CO :52.26, VOC: 11.36, PMro:4.00, PMzs:4.00, COze:8,328, and HAPs : 22.35. PM2 5 emissions are a subset of PMro emissions, and are, therefore, not additive SOURCE SPECIFIC DESIGNATIONS Applicable Programs: MACT (Part 63), Subpart A: General Provisions applies to Autoliv MACT (Part 63), Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines applies to Emergency Generator Engine MACT (Part 63), Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines applies to Emergency Generator Engines Ogden City CO Maintenance Area applies to Autoliv Ogden City PMls NAA applies to Autoliv Weber County PM2 5 NAA applies to Autoliv Engineering Review N141670007: Autoliv ASP, Incorporated - Modil'ication to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9,2011and DAQE-ANO1602005-03 Dated May 20,2003 November 21,2012 Page 2 Permit History: When issued, the approval order shall supersede or will be based on the following documents: Supersedes Supersedes Is Derived From Incorporates Incorporates Incorporates Incorporates DAQE-AN0 141670005-1 1 dated August 9, 20ll DAQE-AN0 I 602005-03 dated May 20, 2003 NOI dated May 2,2012 Additional Information dated July 6,2012 Additional Information dated August 30, 2012 Additional lnformation dated October 8,2012 Additional lnformation dated October 17,2012 Nonattainment or Maintenance Areas Impacted: Ogden City CO Maintenance Area Ogden City PMro NAA Weber Counfy PM2 5 NAA SUMMARY OF NOTICE OF INTENT INFORMATION Description of Proposal: Autoliv is proposing to add an oven and afterburner with a combined rating of 0.39 removing an adhesive spray booth. Summary of Emission Totals: The emissions Iisted below are an estimate of the total potential emissions from the rounding of emissions is possible. Estimated Criteria Pollutant Potential Emissions C02 Equivalent Carbon Monoxide Nitrogen Oxides Particulate Matter - PM,o Particulate Matter - PMz s Sulfur Dioxide Volatile Organic Compounds Estimated Hazardous Air Pollutant Potential Emissions Formaldehyde (CAS #50000) Glycol Ethers (CAS #EDFl09) Toluene (CAS #108883) Total HAPs (CAS #THAPS) Total hazardous air pollutants MMBtu/hr. Autoliv is source. Some 73 10.00 tons/yr 16.92 tons/yr 4.92 tons/yr 2.71 tons/yr 2.11 tons/yr 0.11 tons/yr 66.53 tons/yr 500 lbs/yr 500 lbs/yr 4.44 tons/yr 15.70 tons/yr 20.64 tons/yr Engineering Review N I 41670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 November 21,2012 Page 3 Review of Best Available Control Technology: 1. BACT review regarding BACT for Oven and Afterburner NSR recommends the following for BACT 1. Natural gas fueled 2. Emission control technology is the afterburner 3. Visible emissions are limited to lUYo opacity The emissions resulting from the oven and afterburner are very small (all less than 0.14 tons per year for the criteria pollutants and 6.30 pounds per year of combined HAPs). It is not economically feasible to add on additional control technologies to further reduce the emissions. [Last updated August 23,20121 Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l l Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 November 21,2012 Page 4 RECOMMENDED APPROVAL ORDER CONDITIONS The intent is to issue an air quality Approval Order (AO) authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. The AO will be issued to and will apply to the following: Name of Permittee:Permitted Location: Autoliv ASP, Incorporated Autoliv ASP, Incorporated 3350 Airport Road 1000 West 3300 South Ogden, UT 84405 Unit 7 Ogden, UT 84401 UTM coordinates: 415,687 m Easting,4,561,888 m Northing, UTM Zone 12 SIC code: 3799 (Transportation Equipment, NEC) Section I: GENERAL PROVISIONS I.l The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] 1.2 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-l] I.3 All records referenced in this AO or in other applicable rLrles, 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.4 At alltimes, 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.5 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. 1R307- r s0l 1.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. 1R307-r 071 1.7 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-l0l] Engineering ReviewNl41670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANOr4r670005-r I Dated o,*,',13;33f:.Ti?f3t*N0r602005-03 Dated May 20,2003 Page 5 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Autoliv Plastic parts coating plant and airbag module manufacturing plant ll.A.2 Oven and After Burner Combined rating: 0.39 MMBtu/hr New equipment Il.A.3 Coating Line Adhesion-promoter spray booth, ozonation-adhesion-promoter system, topcoat spray booth, curing oven, touch-up spray booth, and high-volume low-pressure spray guns Previously included in AO DAQE-AN0141670005-l l, dated August 9,2011 II.A.4 Air Make-Up Unit Natural gas fueled: 6.084 MMBtu/hr Previously included in AO DAQE-AN0141670005-11, dated August 9,2011 II.A.5 Emergency Generator Engines Number of engines: Three (3) Manufacturer: Kohler* Fuel: Natural Gas Output: 78 kW - Each Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.6 Emergency Generator Engine Number of engines: One (l) Manufacturer: Caterpillar* Fuel: Diesel Output: 230 kW Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.7 Paint Spray Booth Manufacturer: SprayKing* Particulate control: Fiberglass or polyester filters Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.8 Boilers Number of boilers: Two (2) Manufacturer: Lochinvar ** Fuel: Naturalgas Rating: Less than 5 MMBtU/hr - each Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.9 Miscellaneous Natural Gas-Fueled Equipment boilers and space heaters ** Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANor4r670005-r I Dated o*r'i,3;"r3,n:#ilfff*No160200s-03 Dated May 20,2003 Page 6 II.A.IO II.A.I I II.B II.B.I ll.B.l .a Rating: Less than 5 MMBtU/hr Combined rating: 10 MMbtu/hr Previously included in AO DAQE-AN 16020005-03 dated May 20,2003 Unconfined-Abrasive Blast Booth Number of units: one (l) Previously included in AO DAQE-AN16020005-03 dated ll4ay 20,2003 Miscellaneous Equipment Injection molding machines** Parts washers** Airbag module production equipment* * Plant maintenance** Offices** Laboratories** Forklifts** and other non-road mobile equipment** (propane, gasoline, or diesel fueled) Previously included in AO DAQE-AN 16020005-03 dated May 20,2003 * This equipment specific detail is listed for informational purposes only** This equipment is listed for informational purposes only Requirements and Limitations Source-Wide Conditions Autoliv shall notiflz the Director in writing when the installation of the new equipment listed has been completed and is operational. To ensure proper credit when notifuing the Director, send your correspondence to the Director, attn: Compliance Section. [R307-401-18] If the construction and/or installation has not been completed within l8 months from the date of this AO, the Director shall be notified in writing on the status of the construction and/or installation. At that time, the Director shall require documentation of the continuous construction andlor installation of the operation and may revoke the AO. [R307-401-18] Visible emissions from any stationary point associated with the source or with the control facilities shall not exceed the following: A. Air Make-Up Unit - SYo opacity B. Oven - l0% opacity C. All natural gas-, propane-, and gasoline-fueled combustion-device exhaust stacks - 10% opacity D. All paint-booth exhaust stacks - 10% opacity E. All diesel-fuel-combustion exhaust stacks -20% opacity F. Outdoor abrasive blasting operations - 20% opacity G. All naturalgas-fueled emergency generator engines - 10% opacity H. All building exhaust stacks - l0% opacity II.B.1.a.1 rr.B. r.b Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-11 Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 November 21,2012 Page 7 I. All other points including fugitive emissions -20% opacity. [R307-305-3, R307-401-8] II.B.l.b.l Opacity observations of emissions from stationary sources shallbe conducted in accordance with 40 CFR 60, Appendix A, Method 9 or methods as approved by the Director. [R307-401-8] II.B.l .c The VOC- and/or HAP-containing materials shall be stored in covered containers (except when in use). VOC- and/or HAP-laden rags shall also be stored in covered container. [R307-325-3] II.B.l .d Each HAP is limited to less than 8.19 tons per rolling l2-month period. [R307-401-8] II.B.l .d.I For each HAP, the emissions from the three plants shall be combined to determine the rolling 12-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous l2 months. [R307-401-8] II.B.2 Airbae Module Manufacturine Plant Limits (Previouslv Permit DAOE-AN1602005-03 Dated Mav 20.2003) ll.B.Z.a The following consumption limits shall not be exceeded: 1,000 pounds of sand-blasting media per rolling l2-month period 6,000,000 gallorrs of propane for the entire plant per rolling l2-month period 3,000,000 gallons of gasoline for the entire plant per rolling l2-month period 3,000,000 gallons of diesel fuel #2 for the entire plant per rolling l2-month period 60,000,000 cubic feet of natural gas for the entire plant per rolling 12-month period tR307-401-81 II.B.2.a.l Compliance with each limitation shall be determined on a rolling l2-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous l2 months. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of material supplier billing records. The records of consumption shall be kept on a monthly basis. [R307-401-8] II.B.2.b The airbag module manufacturing plant-wide VOC and HAP emissions slrall not exceed: 5.84 tons per rolling l2-month period for VOCs 0.25 tons per rolling l2-month period for formaldehyde 0.25 tons per rolling l2-month period for glycol ethers 3.26 tons per rolling I 2-month period for the combined following HAPs: acetonitrile, benzene, cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, sffrene, toluene, trichloroethylene, and xylene. * Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANo14167000s-l I Dated "*,.r13;flf:#? ?f3r*N0r602005-03 Dated May 20,2003 Page 8 3.76 tons per rolling l2-month period for all the above listed HAPs * Any individual HAP included in this list shall have an emission limit less than the Ernission Threshold Value (ETV) for that chemical, as provided for in R307-410-4. The above VOC and HAP limits do not include the products of incomplete combustion generated by the emergency generator engines, boilers, or assofted fuel burning equipment items. IR307-401-8] II.B.2.b.I Compliance with each limitation shall be determined on a rollirrg 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 l2 months. tR307-401-81 11.8.2.b.2 The VOC and HAP emissions shall be deterrnined 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- or I-lAPs-erritting material, such as: paint, adhesive, solverrt. thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOC or HAP emitted morrthly by each material used shall be calcr"rlated by tlre fol lowing procedure: VOC: (%VOC by Weight)/I00 x [Density (lb/gal)] x Gal Consumed x (l ton/2000 lb) HAP : (% HAP by Weight)/l00 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 em issions. tR307-401-81 II.B.3 Plastic Parts Coatine Line Plant Limits (Previous Permit DAOE-AN0141670005-Il Dated Aueust 9,2011) II.B.3.a Emissions frorn the coating line (including but not limited to thinners, cleaning solvents, top coating, catalysts, and adhesion promoters) shall not exceed the following limits: EngineeringReviewNl4l6T000T: AutolivASP, Incorporated-ModificationtoApproval OrderandCombinationofAOs DAQE-AN0r41670005-1r Dated o*,113;.r3f:3i ?f3t^N0r602005-03 Dated May 20,2003 Page 9 60.00 tons per rolling l2-month period for VOCs 4.44 tons per rolling l2-month period for toluene 12.44 tons per rolling l2-month period for combined HAPs, which include: cumene, ethyl benzene, methyl isobutyl ketone, and xylenes (isomers and mixture). [R307-401-8] II.B.3.a.l Compliance with each limitation shall be determined on a rolling l2-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous l2 months. tR307-40 r l 11.8.3.a.2 The VOC or HAP emissions shall be determined by maintaining a record of VOC- or HAP- emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC- or HAPs-emittirrg material, such as: paint, adhesive, solvent, thinner, reducers, chemical compourrds. toxics, isocyanates, and etc. B. Density of each rnaterial used (pounds per gallon) C. Percent by weight of all VOC or HAP in each rnaterial used D. Callons of each VOC- or HAP-ernitting rnaterial used E. The amount of VOC or HAP ernitted rnonthly by each material used shall be calculated by the fol lowing procedure: VOC: (% VOC by Weight)/l00 x [Density (lb/gal)] x Gal Consumed x (l ton/2000 lb) HAP - (% HAP by Weight)/100 x [Density (lb/gal)] x Cal Consumed x (1 tonl2000 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 em issions. tR307-401-81 II.B.4 Emergencv Generator Engine Requirements II.B.4.a Emergency generator engines shall be used for electricity-producing operation only during the periods when electric power from the public utilities is interrupted. Emergency generator engines shall each be limited to 100 hours for regular maintenance and testing. [R307-401-8, 40 CFR63 Subpart ZZZZI II.B.4.a.l Records documenting emergency generator engine usage shall be kept in a log; and they shall E,ngineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANOr41670005-r r Dated o*,113;.?f:3i?tSr ^N0r602005-03 Dared May 20,2003 Page l0 11.8.4.a.2 il.8.4.b II.B.4.b.l II.B.5 II.B.5.a show the date the generator engine was used, the duration in hours ofthe generator engine usage, and the reason for each generator engine usage. [R307-401-8] To determine compliance with the hour limitation for the emergency generator engine's maintenance and testing operations, a rolling l2-month total shall be calculated by the twentieth day of each month using data from the previous 12 months. [R307-401-8] The sulfur content of any fuel oil or diesel burned in any emergency generator engines shall not exceed l5 ppm by weight. [R307-401-8] The sulfur content shall be determined by ASTM Method D-4294-89, or approved equivalent. Certification of fuels shall be either by Autoliv's own testing, or test reports from the fuel marketer. [R307-401-8] Abrasive Blasting Requirement Autoliv shall comply with all applicable abrasive-blasting requirements. IR307-206] 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. MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANO141670005-l I Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 November 21,2012 Page I I RBVIEWER COMMENTS The AO will be based on the following documents: Supersedes Supersedes Is Derived From Incorporates Incorporates lncorporates Incorporates DAQE-AN0141670005-l I dated August 9,2011 DAQE-ANO I 602005-03 dated May 20, 2003 NOI dated May 2,2012 Additional Information dated July 6,2012 Additional Information dated August 30, 2012 Additional lnformation dated October 8,2072 Additional Information dated October 17,2012 Comment regarding 40 CFR Part 63 Subpart HHHHHH: The activities that would make this MACT applicable to Autoliv are (as given in the subpart): I . Perform paint stripping using MeCl for the removal of dried paint (including, but not limited to, paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic, and other substrates. 2. Performsprayapplicationofcoatings,asdefinedin$63.lll80,tomotorvehiclesandmobile equipment including operations that are located in stationary structures at fixed locations, and rnobile repair and refinishing operations that travel to the custorner's location, except spray coating applications that meet the definition of facility maintenance in $63.1 I 180. However, if you are the owner or operator of a motor vehicle or mobile equipment surface coating operation, you may petition the Administrator f,or an exemption from this subpart if you can demonstrate, to the satisfaction of the Administrator, that you spray apply no coatings that contain the target HAP, as defined in $63.1 1 180. Petitions must include a description of the coatings that you spray apply and your certification that you do not spray apply any coatings containing the target HAP. If circumstances change such that you intend to spray apply coatings containing the target HAP, you must submit the initial notification required by 63.1 I 175 and comply with the requirements of this subpart. 3. Perform spray application of coatings that contain the target HAP, as defined in $63.1 1 1 80, to a plastic and/or metal substrate on a part or product, except spray coating applications that meet the definition of facility maintenance or space vehicle in $63.1 I 180. (Target HAPs are chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd)) onto their product.) Autoliv does not meet the applicability activities for this MACT. [Last updated July 10,2012) Comment regarding 40 CFR Part 63 Subpart This MACT does not apply because Autoliv 20121 Comment regarding 40 CFR Part 63 Subpart This MACT does not apply because Autoliv 20121 is an area source of HAPs. ILast updated July HHHHH: is an area source of HAPs. [Last updated July Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANo I 4 1670005- 1 I Dated August 9, 20ll and DAQE-AN01 602005-03 Dated May 20, 2003 November 21,2012 Page 12 4. 7. Comment regarding PMz s and CO2e emissions for the module manufacturing plant DAQE- AN 1602005-03, dated May 20,2003: PMz s and CO2e emissions have not been evaluated for the module manufacturing plant. These emissions were estimated in order to list the source-wide PTE's in this AO. PM2 5 emissions were set equal to PMle emissions. PM2 5 emissions are a subset of PMro emissions. CO2e was estimated with the current module manufacturing plant's natural gas consumption limit and AP-42 emission factors. The yearly emission of PMzs is 1.37 tons and COze is 3,601 tons. When the Approval Order for the module manufacturing plant is modified these emissions will be evaluated further and added to the module manufacturing plant's Approval Order. [Last updated July 10, 20121 Comment regarding Parking lot size: The number of parking lot stalls has been removed from the AO, which was previously included DAQE-AN16020005-03 dated May 20,2003. The rule that regulated parking lot size has been eliminated from R307-400. Also, "or use of the parking lot" was removed from VOC and HAP limit for the Airbag Module Manufacturing Plant. This wording was used to describe the products of incomplete combustion that were not used to calculate VOC and HAP emissions calculations. [Last updated November 21,2012] Comment regarding Mobi le Equipment: Forklifts and other non-road mobile equipment are no longer accounted for in AOs as point sources. This equipment was previoLrsly included in AO DAQE-AN 16020005-03 dated May 20, 2003. This equipment is included in this AO for informational purposes only. [Last updated Novernber 21.20121 Comment regarding Aggregation of Autoliv's Approval Orders: The ApprovalOrders DAQE-AN0141670005-l I and DAQE-AN016020005-03 were combined with this modification. Autoliv's Approval Order for the Ogden facility, DAQE-AN100250011- I l, was not combined with this Approval Order. All three sources have the same SIC code, same owner and are adjacent to each other. Therefore, they are considered one source and would typically have been combined into one Approval Order. However, the source has informed DAQ that the Ogden facility has a separate purpose, separate management, and separate EPA ID numbers from the parts coating line and airbag module plants. Autoliv has requested that they have two Approval Orders. The DAQ will have two Approval Orders for this source; one of them is the Approval Order resulting from this Engineering Review/Source Plan Review. However, when one of them is modified or amended, emissions from both Approval Orders must be considered. The potential to emit totals for the two resulting AOs, in tons per year, are as follows: NO*: 20.66, SOz: 0.34, CO: 52.26, VOC :71.36, PMro : 4.00, PM2 5 : 4.00, COze : 8,328, and HAPs :22.35. ILast updated November 21,2012] 8. Comment regarding Adhesive Spray Booth: The adhesive spray booth that was originally included on the AO DAQE-AN016020005-03 dated May 20,2003 was removed from the equipment list with this modification. The source has removed this piece of equipment. The opacity limit for the booth's stack and the vinyl adhesive limit were also removed. [Last updated October 23,2012] Engineering Revierv N I 4l 670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANor41670005-11 Dated ^*,'i,3;.?fl#i ?f3t*N0r602005-03 Dated May 20.2003 Page 13 5. 6. 9.Comment regarding HAP Limits: Two FIAP limits are listed in this AO modification, one set of limits for the Airbag Module Manufacturing Plant and one for the Plastic Parts Coating Line Plant. It is typical for only one set of limits to be inclLrded in an AO. With this modification, two AOs are being consolidated, the source has not requested an increase or decrease in previously approved limits, and each set of limits includes a limit with a combination of HAPs, so two sets of limits are listed. It would not be possible to combine the limit sets without increasing or decreasing a HAP limit. For instance, the airbag module manufacturing plant has a combined HAP limit of 3.26 tons per year, which includes toluene, and the Plastic Parls Coating Line has a toluene limit of 4.44 tons per year. The limits recommended with this modification are given below. Airbag Module Manufacturing Plant 5.84 tons per rolling l2-month period for VOCs 0.25 tons per rolling l2-month period for formaldehyde 0.25 tons per rolling l2-rnonth period for glycol ethers 3.26 tons per rolling l2-rnonth period for the combined following HAPs: acetonitrile, benzene, cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, rnethylene chloride. methanol, methyl isobutyl ketone. naphthalene, perchloroethylene, phenol, styrene, toluene" trichloroethylene. and xylene. * 3.76 tons per rolling l2-rnonth period tbr all the above listed HAPs Plastic Parts Coating Line Plant 60.00 tons per rolling 12-month period for VOCs 4.44 tons per rolling l2-month period for toluene 12.44 tons per rolling 12-month period for combined HAPs, which inclr-rde: cumene, ethyl benzene, methyl isobLrtyl ketone, and xylenes (isomers and mixture). ILast updated November 21,2012) Comment regarding Requirement Removal: The requirement "Plastic parts coating line plant shall use only pipeline qLrality natural gas as fuel. If any other fr"rel is to be used, a modification of this AO shall be reqLrired." was removed with this AO rnodification as only natural gas fuel for the plastic parts coating line. The requirement "Autoliv shall comply with all applicable fugitive dust requirements for sources in the PMle nonattainment area." was removed with this AO modification as Autoliv does not mine or store aggregate on their property. [Last updated November 21,2012] Engineering Revierv N I 4 | 670007: Autoliv ASP, lncorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9.2011and DAQE-AN01602005-03 Dated May 20,2003 November 21.2012 Page 14 10. ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO ApprovalOrder BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by sizeltype) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous rnorritoring system CO Carbon monoxide COz Carbon Dioxide CO:e Carbon Dioxide Equivalent - 40 CFR Part 98, SLrbpart A, Table A- I COM Continuous opacity monitor DAQ Division of Air Quality (typically interchangeable with UDAQ) DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Clobal Warming Potential- 40 CFR Par186.l8lB-12(a) HAP or HAPs Hazardous air pollLrtant(s) ITA Intent to Approve LB/HR Pounds per hour MACT Maximum Achievable Control Technology MMBTU Million British Thennal Units NAA Nonattainnrent Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Irrtent NO* Oxides of r-ritrogen NSPS New Source Performance Standard NSR New Source Review PMro Particulate matter less than 10 microns in size PM, r Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 RLrles Series 307 - Section 401 SO: SLrlfirr dioxide Title lV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code UDAQ Utah Division of Air Quality (typically interchangeable with DAQ) VOC Volatile organic compounds Engineering Review N I 4l 670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-ll Dated August 9.2011and DAQE-AN01602005-03 Dated May 20,2003 November 21,2012 Page 15 Oct.24-2012 02:35 \ Pl'l Autol i L-620-8?73v80o Lll ,XlH.t''-f-fnU^tf" uul 2 E 2012 DaronKoldcwyn Autoliv ASP, hoorporatcd 3350 Airport Road Odoo,IIT 84405 RE: RoviowBnginocr: Dato: Nodoo of htcmt Eubmittad; PlmtConhot: PhoneNumben FaxNumber: Soutc Looation: UTAII DTVISIION O['AIR OUALIIYDIVISION OF AIR AUAUTY hqicct Numbcm Nl41670007 Ivlodifioationto Appoval Gdar sod Conbinad@ ofAos DAQE-AI.I0 14 1 670005-l I Dated August 9, 20 I I aud DAQEAN0I60200543 Datcd Mry 20, 2003 Wcbcr Counfiy; CDS Bl lvlAgf Part 63), Noautbiumcnt ond lvlaiatmenoc.fma Mr.IlctthaMiclccloon Ootobq 39,2012 hyril25,2012 DamKoldazyn (801) 620-8285 (801) 620.8276 1000 Wcst 3300 Sorrttr, Unit 7, Ogden, UT WcbrCounty d5 6 1,8 88 n Northhg 4 I 5,687 m Basting IJTIT'I Zots L2 UTltdDatum: }.IAD27 DAQ rcquc* firt a oompary/oorporation official rcad 6c athchcd drrfi/proposcdPhn Rcvicw witl Rccommcnalcd Approval Ordo Corulitioas. If thic panon docc not unthrcfiid or docs nct agtc wl*t thc conditione, thc rwicw cnginca should bc ooatastcd within fiw dryr aftcr roooipt of the Plan Rsvicw. If this pooon rgrres with tho Plan ReviErn, and Rscoumendsd Appooval order Condtdore, $is pereon shoildsignhlowandrctumFA)f#801.5364099)withinl0dayraftlrrlcoiptofthoconditions, Ifthc roviow onghoer is rot contaoted within l0 days, tho rwisw ouginoor shall assumc thd thc cmpaoy/corporrtim oftciql agrcas with this Plao Rsvicw aurl will prooccs thc Phtr Rsrriow tovnrds ftral approval. A publio oommcnt puiod wtll bc rcquirsd bcforc trc Approral Or{c/ oen bc iccucd. Aprpliornt Conact Bngino.rtrgRrvicrrNl4l6?00071 AunlvASP,lacorpormd.ModificsllontoApplovalOdrrrndCornblnrdonofAos DAQ&AN0141670005-I 1 Datrd Ausr8tl, 20l l fl:r?if" ol6m00t{3 Datod }/ay 20, 2003 Pagc I SOI,RSE PLAITIREYIE ABSTRACT Autoliv ASP, lncorporated (Autoliv) is seeking a modification of its ApprovalOrder. It is adding a natural gas-fueled oven with afterburner with a combined rating of 0.39 MMBtu/hr. The December 16, 201 I name and ownership change for the plastics laminate plant aggregated the three Approval Orders for Autoliv. They have the same owner, SIC code, and the plants are adjacent to each other. With this modification, the two Approval Orders from DAQE-ANO141670005-11 dated August 9, 201 I and DAQE-ANO16020005-03 dated May 20,2003 were combined into one Approval Order. The Approval Order for the third plant, DAQE-ANI0025001 l-11 dated November 29,201I was not combined with this Approval Order. When either of these two Approval Orders is modified or amended, the cumulative emissions will be used to evaluate the source. The original AO for each piece of equipment is listed in the equipment list and the limits specific to each plant are included in the requirements and limitation section of this AO. Methyl ethyl ketone was removed from the EPA's list of HAPs on December 19,2005. Therefore, methyl ethyl ketone is being removed from the airbag module manufacturing plant's limit. The cumulative limit for the plant's HAPs has not been altered. The adhesive spray booth was also removed with this modification. It was originally included in the AO DAQE-AN016020005-03 dated l/,'ay 20,2003. Autoliv is located in Ogden (Weber County). The location is in a nonattainment area for the NAAQS for PM;s and PM2 5 and a maintenance area for CO. Maximum Achievable Control Technology (MACT) (40 CFR Part 63 Subpart ZZZZ) regulations apply to this source. Currently, area sources subject to 40 CFR Part 63 Subpart ZZZZ are exempt from the Title V program. Therefore, Title V does not apply to this source. The emissions, in tons per year, will change as follows: NO- (+) 0.004, SO, (+1 0.001 , CO (+) 0. 14, VOC (+) 0.01, PMro (+) 0.01, PM25 (+) 0.01, COze (+) 201, and HAPs (+) 0.003. The potential to emittotals for the two combined AOs and the additional equipment, in tons per year, are as follows: NO* : 4.92, SOz = 0.1 l, CO : 16.92, VOC : 66.53, PMro: 21l,PM2s:2.71, CO2e :7310, and HAPs :20.64. The potential to emit totals for the three previous AOs and the new equipment, in tons per year, are as follows: NO*:20.66,SO2:0.34,CO:52.26,VOC:71.36,PMr0:4.00,PM2s:4.00,CO2e:8,328,and HAPs : 22.35. PM2 5 emissions are a subset of PMro emissions, and are, therefore, not additive SOURCE SPECIFIC DESIGNATIONS Applicable Programs: MACT (Part 63), Subpart A: General Provisions applies to Autoliv MACT (Part 63), Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines applies to Emergency Generator Engine MACT (Part 63), Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines applies to Emergency Generator Engines Ogden City CO Maintenance Area applies to Autoliv Ogden City PMr0 NAA applies to Autoliv Weber County PM2 5 NAA applies to Autoliv Engineering Review NI41670007: Autoliv ASP, lncorporated - Modification to Approval Order and Combination of AOs DAQE-ANo14r67000s-l I Dated or*r"&;oo:l;f;tQt*N01602005-03 Dated May 20,2003 Page2 Permit History: When issued, the approval order shall supersede or will be based on the following documents: Supersedes Supersedes Is Derived From Incorporates Incorporates Incorporates Incorporates DAQE-AN0141670005-l I dated August 9,2011 DAQE-AN0l 602005-03 dated May 20, 2003 NOI dated ll4ay 2,2012 Additional Information dated July 6,2012 Additional Information dated August 30, 2012 Additional Information dated October 8,2012 Additional Information dated October 17,2012 Nonattainment or Maintenance Areas Impacted: Ogden City CO Maintenance Area Ogden City PMro NAA Weber County PM2 5 NAA SUMMARY OF NOTICE OF INTENT INFORMATION Description of Proposal: Autoliv is proposing to add an oven and afterburner with a combined rating of 0.39 MMBtu/hr.Autoliv is removing an adhesive spray booth. Summary of Emission Totals: The emissions listed below are an estimate of the total potential emissions from rounding of emissions is possible. Estimated Criteria Pollutant Potential Emissions CO2 Equivalent Carbon Monoxide Nitrogen Oxides Particulate Matter - PMro Particulate Matter - PMz s Sulfur Dioxide Volatile Organic Compounds Estimated Hazardous Air Pollutant Potential Emissions Formaldehyde (CAS #50000) Glycol Ethers (CAS #EDFl09) Toluene (CAS #108883) Total HAPs (CAS #THAPS) Total hazardous air pollutants the source. Some 7310.00 tons/yr 16.92 tons/yr 4.92 tons/yr 2.71 tons/yr 2.71 tons/yr 0.1 I tons/yr 66.53 tons/yr 500 lbs/yr 500 lbs/yr 4.44 tons/yr 15.70 tons/yr 20.64 tons/yr Engineering Review N I 4 I 670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 October 23,2012 Page 3 o o Review of Best Available Control Technology: 1. BACT review regarding BACT for Oven and Afterburner NSR recommends the following for BACT l. Natural gas fueled 2. Emission controltechnology is the afterburner 3. Visible emissions are limited to 10%o opacity The emissions resulting from the oven and afterburner are very small (all less than 0.14 tons per year for the criteria pollutants and 6.30 pounds per year of combined HAPs). It is not economically feasible to add on additional control technologies to further reduce the emissions. [Last updated August 23,2012) Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANO141670005-l I Dated August 9,2011and DAQE-ANO1602005-03 Dated May 20,2003 October 23,2012 Page 4 RECOMMENDED APPROVAL ORDER CONDITIONS The intent is to issue an air quality Approval Order (AO) authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. The AO will be issued to and will apply to the following: Name of Permittee: Permitted Location: Autoliv ASP, Incorporated Autoliv ASP, Incorporated 3350 Airport Road 1000 West 3300 South Ogden, UT 84405 Unit 7 Ogden, UT 84401 UTM coordinates: 415,687 m Easting,4,56l,888 m Northing, UTM Zone 12 SIC code: 3799 (Transportation Equipment, NEC) Section I: GENERAL PROVISIONS I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] 1.2 Modifications to the equipment or processes approved by this AO that could affect tlre emissions covered by this AO must be reviewed and approved. 1R307-401 - I l I.3 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] 1.4 At alltimes, 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.5 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. 1R307-ls0l 1.6 The owner/operator shallcomply with UAC R307-107. General Requirements: Breakdowns. [R307-107] 1.7 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] Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANO141670005-l I Dated August 9,2011 and DAQE-AN01602005-03 Dated May 20,2003 October 23,2012 Page 5 II.A II.A.I tr.A.2 II.A.3 II.A.4 lI.A.5 II.A.6 tI.A.7 II.A.8 Section II: SPECIAL PROVISIONS The approved installations shall consist of the following equipment: Autoliv Plastic parts coating plant and airbag module manufacturing plant Oven and After Burner Combined rating: 0.39 MMBtu/hr New equipment Coating Line AdhesLn-promoter spray booth, ozonation-adhesion-promoter system, topcoat spray booth, curing oven, touch-up spray booth, and high-volume low-pressure spray guns Previously included in AO DAQE-AN0141670005-11, dated August 9,2011 Air Make-Up Unit Natural gas fueled: 6.084 MMBtu/hr Previously included in AO DAQE-AN0141670005-11, dated August 9,2011 Emergency Generator Engines Number of engines: Three (3) Manufacturer: Kohler* Fuel: Natural Gas Output: 78 kW - Each Previously included in AO DAQE-AN16020005-03 dated May 20,2003 Emergency Generator Engine Number of engines: One (1) Manufacturer: Caterpillar* Fuel: Diesel Output: 230 kW Previously included in AO DAQE-AN16020005-03 dated May 20,2003 Paint Spray Booth Manufacturer: SprayKing* Particulate control: Fiberglass or polyester filters Previously included in AO DAQE-AN16020005-03 dated llay 20,2003 Boilers Manufacturer: Lochinvar ** Fuel: Natural gas Rating: Less than 5 MMBtU/hr - each Previously included in AO DAQE-AN16020005-03 dated May 20,2003 II.A.9 Miscellaneous Natural Gas-Fueled Equipment boilers and space heaters ** Rating: Less than 5 MMBtu/hr Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-11 Dated August 9,2011and DAQE-ANO1602005-03 Dated May 20,2003 October 23,2012 Page 6 il.A.10 II.B Combined rating: l0 MMBbtu/hr Previously included in AO DAQE-AN 16020005-03 dated May 20,2003 Unconfi ned-Abrasive BIast Booth Number of units: one (l) Previously included in AO DAQE-AN 16020005-03 dated May 20,2003 M iscellaneous Equipment Injection molding mach ines* * Parts washers** Airbag module production equipment** Plant maintenance** Offices+* Laboratories** Forklifts** and other non-road mobile equipment** (propane, gasoline, or diesel fueled) Previously included in AO DAQE-AN16020005-03 dated May 20,2003 * This equipment specific detail is listed for informational purposes only** This equipment is listed for infbrrnational purposes only Requirements and Limitations Source-Wide Conditions ALrtoliv shall notify the Director in writing when the installation of the new equipment listed has been completed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. [R307-401- I 8] If the construction and/or installation has not been completed within l8 months from the date of this AO, the Director shall be notified in writing on the status of the construction and/or installation. At that time, the Director shall require documentation of the continuous construction and/or installation of the operation and may revoke the AO. [R307-401-18] Visible emissions l'rom any stationary point associated with the source or with the control facilities shall not exceed the following: A. Air Make-Up Unit - 50 opacity B. Oven - 10% opacity C. All natural gas-, propane-, and gasoline-fireled combustion-device exhaust stacks - l0% D. All paint-booth exhaust stacks - l0% opacity E. All diesel-fuel-combustion exhaust stacks - 20% opacity F. Outdoor abrasive blasting operations - 20% opacity G. All naturalgas-fueled emergency generator engines - 10% opacity H. All building exhaust stacks - l0% opacity L All other points including fugitive emissions -20% opacity. [R307-305, R307-401-8] Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 October 23.2012 Page 7 l.a l.b II.B.l.b.l II.B.l.c il.B.r.d II.B.1.d.l 1.8.2 ll.B.2.a 11.8.2.a.1 II.B.2.b Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9 or methods as approved by the Director. [R307-305] The VOC- and/or HAP-containing materials shall be stored in covered containers (except when in use). VOC- and/or HAP-laden rags shall also be stored in covered container. [R307-401-8] Each HAP is limited to less than 8.1 9 tons per rolling 12-month period. [R307-401-8] For each HAP, the emissions from the three plants shall be combined to determine the rolling l2-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. [R307-401-8] Airbae Module Manufacturine Plant Limits (Previouslv Permit DAOE-AN1602005-03 Dated Mav 20.2003) The following consumption limits shall not be exceeded: I ,000 pounds of sand-blasting media per rolling l2-month period 6,000,000 gallons of propane for the entire plant per rolling l2-month period 3,000,000 gallons of gasoline for the entire plant per rolling l2-month period 3,000,000 gallons of diesel fuel #2 for the entire plant per rolling l2-month period 60,000,000 cubic feet of natural gas for the entire plant per rolling 12-month period tR307-401-81 Compliance with each limitation shall be determined on a rolling l2-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. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of material supplier billing records. The records of consumption shall be kept on a monthly basis. [R307-401-8] The airbag module manufacturing plant-wide VOC and HAP emissions shall not exceed: 5.84 tons per rolling l2-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde 0.25 tons per rolling l2-month period for glycol ethers 3.26 tons per rolling l2-month period for the combined following HAPs: acetonirile, benzene, cumene, dichlorobenzene, ethylbenzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene, toluene, trich loroethylene, and xylene. * 3.76 tons per rolling l2-month period for all the above listed HAPs EngineeringReviewNl4l6T000T: AutolivASP, Incorporated-ModificationtoApproval OrderandCombinationofAOs DAQE-AN0141670005-l I Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 October 23,2012 Page 8 * Any individual HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for in R307-410-4. The above VOC and HAP limits do not include the products of incomplete combustion generated by the emergency generator engines, boilers, assofted fuel burning equipment items, or use of the parking lot. [R307-401-8] II.B.2.b.l 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 l2-month total shall be calculated using data from the previous l2 months. 1R307-401-81 11.8.2.b.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 followingdata for each material used: A. Name of the VOC- or HAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOC or HAP emitted monthly by each material used shall be calculated by the following procedure: VOC : (% VOC by Weight)/[O0 x [Density (lb/gal)] x Gal Consumed x (l ton/2000 lb) HAP : (% HAP by Weight)/I00 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. tR307-40r -81 II.B.3 Plastic Parts Coatinq Line Plant Limits (Previous Permit DAOE-AN0141670005-11 Dated Aueust 9.2011) II.B.3.a Emissions from the coating line (including but not limited to thinners, cleaning solvents, top coating, catalysts, and adhesion promoters) shall not exceed the following limits: 60.00 tons per rolling 12-month period for VOCs 4.44 tons per rolling 1 2-month period for toluene Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0r4r670005-r I Dated or*r"&;oo:l;y;tft*Nor602005'03 Dated May 20,2003 Page 9 II.B.3.a.l 11.8.3.a.2 II.B.3.b II.B.4 ll.B.4.a 12.44 tons per rolling l2-month period for combined HAPs, which include: cumene, ethyl benzene, methylisobutylketone, and xylenes (isomers and mixture). [R307-401-8] 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. 1R307-4011 The VOC or HAP emissions shall be determined by maintaining a record of VOC- or HAP- emitting materials used each month. The record shall include the followin g data for each material used: A. Name of the VOC- or HAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOC or HAP emitted monthly by each material used shall be calculated by the following procedure: VOC: (%YOC by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (l ton/2000 lb) HAP: (%HAP by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (l 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 FIAP emissions. tR307-40 r-81 parts coating line plant shall use only pipeline quality natural gas as fuel. If any other to be used, a modification of this AO shall be required. [R307-401] Emergency Generator Engine Requirements Emergency generator engines shall be used for electricity-producing operation only during the periods when electric power from the public utilities is interrupted. Emergency generator engines shall each be limited to 100 hours for regular maintenance and testing. [R307-401-8, 40 CFR 63 Subpart ZZZZI Engineering Review N141670007: Autoliv ASP, lncorporated - Moditlcation to Approval Order and Combination of AOs DAQE-ANO141670005-11 Dated August 9,2}ll and DAQE-AN01602005-03 Dated May 20,2OO3 October 23,2012 Page l0 Plastic fuel is O o II.B.4.a.1 Records documenting emergency generator engine usage shall be kept in a log; and they shall show the date the generator engine was used, the duration in hours ofthe generator engine usage, and the reason for each generator engine usage. [R307-401-8] 11.8.4.a.2 To determine compliance with the hour limitation for the emergency generator engine's maintenance and testing operations, a rolling l2-month total shall be calculated by the twentieth day of each month using data from the previous l2 months. [R307-401-8] ILB.4.b The sulfur content of any fuel oil or diesel burned in any emergency generator engines shall not exceed I 5 ppm by weight. [R307-401-8] ll.B.4.b.l The sulfur content shall be determined by ASTM Method D-4294-89, or approved equivalent. Certification of fuels shall be either by Autoliv's own testing, or test reports from the fuel marketer. [R307-401 -8] II.B.5 Roads and Fugitive Dust Reouirements II.B.5.a Autoliv shall comply with all applicable fugitive dust requirements for sources in the PMle nonattainment area. IR307-309] II.B.5.b Autoliv shall comply with all applicable abrasive-blasting requirements. [R307-206] Section III: APPLICABLE FEDERAL REOUIREMENTS 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. MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating lnternal Combustion Engines Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0 I 4 I 670005- I I Dated August 9, 20ll and DAQE-AN0 I 602005-03 Dated May 20, 2003 October 23,2012 Page I I REVIEWER COMMENTS The AO will be based on the following documents: Supersedes DAQE-AN0141670005-l I dated August 9,2011 Supersedes DAQE-AN01602005-03 dated May 20,2003 Is Derived From NOI dated May 2,2012 Incorporates Additional Information dated July 6,2012 Incorporates Additional Information dated August30,20l2 Incorporates Additional Information dated October 8,2012 Incorporates AdditionallnformationdatedOctoberlT,2012 L Comment regarding 40 CFR Part 63 Subpart HHHHHH: The activities that would make this MACT applicable to Autoliv are (as given in the subpart): 1. Perform paint stripping using MeCl for the removal of dried paint (including, but not limited to, paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic, and otlrer substrates. 2. Perfonnsprayapplicationofcoatings,asdefinedin$63.lll80,tomotorvehiclesandmobile equipment including operations that are located in stationary structures at fixed locations, and mobile repair and refinishing operations that travel to the customer's location, except spray coating applications that meet the definition of facility maintenance in $63.1 I 180. However, if you are the owner or operator of a motor vehicle or mobile equipment surface coating operation, you may petition the Administrator for an exemption from this subpart if you can demonstrate, to the satisfaction of the Administrator, that you spray apply no coatings that contain the target HAP, as defined in $63.1 1 180. Petitions must include a description of the coatings that you spray apply and your certification that you do not spray apply any coatings containing the target HAP. If circumstances change such that you intend to spray apply coatings containing the target HAP, you must submit the initial notification required by 63.11175 and comply with the requirements of this subpart. 3. Perform spray application of coatings that contain the target HAP, as defined in $63.11180, to a plastic and/or metal substrate on a part or product, except spray coating applications that meet the definition of facility maintenance or space vehicle in $63.1 I 180. (Target HAPs are chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd)) onto their product.) Autoliv does not meet the applicability activities for this MACT. [Last updated July 10,20121 2. Comment regarding 40 CFR Part 63 Subpart PPPP: This MACT does not apply because Autoliv is an area source of HAPs. [Last updated July 10, 20121 3. Comment regarding 40 CFR Part 63 Subpart HHHHH: This MACT does not apply because Autoliv is an area source of HAPs. [Last updated July 10, 20121 Engineering Review N 141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-ANor4r670005-r I Dated or*r',&;ro:l;;:;tat**o1602005-03 Dated May 20,2003 Page 12 4.Comment regarding PM2 5 and CO2e emissions for the module manufacturing plant DAQE- AN1602005-03, dated May 20,2003: PM2 5 and CO2e emissions have not been evaluated for the module manufacturing plant. These emissions were estimated in order to list the source-wide PTE's in this AO. PM2 5 emissions were set equal to PMle emissions. PM2 5 emissions are a subset of PMro emissions. CO2e was estimated with the current module manufacturing plant's natural gas consumption limit and AP-42 emission factors. The yearly emission of PM2 5 is 1.37 tons and COze is 3,601 tons. When the Approval Order for the module manufacturing plant is modified these emissions will be evaluated further and added to the module manufacturing plant's Approval Order. [Last updated July 10, 20t21 Comment regarding Parking lot size: The number of parking lot stalls has been removed from the AO, which was previously included DAQE-AN 16020005-03 dated May 20,2003. The rule tlrat regulated parking lot size has been eliminated from R307-400. [Last updated July 30,2012] Comment regardi ng Mobi le Equipment: Forklifts and other non-road mobile equipment are no longer accounted for in AOs as point sources. This equipment was previously included in AO DAQE-AN16020005-03 dated May 20, 2003. This equipment is included in this AO for informational purposes only. [Last updated July 30,20121 Comment regarding Aggregation of Autoliv's Approval Orders: The ApprovalOrders DAQE-AN0141670005-11 and DAQE-AN016020005-03 were combined with this modification. Autoliv's Approval Order for the Ogden facility, DAQE-AN 10025001 l- 1 1, was not combined with this Approval Order. AII three sources have the same SIC code, same owner and are adjacent to each other. Therefore, they are considered one source and would typically have been combined into one Approval Order. However, the source has informed DAQ that the Ogden facility has a separate purpose, separate management, and separate EPA ID numbers from the parts coating line and airbag module plants. Autoliv has requested that they have two Approval Orders. The DAQ will have two Approval Orders for this source, one of them is the Approval Order resulting from this Engineering Review/Source Plan Review. However, when one of them is modified or amended, emissions from both Approval Orders must be considered. The potential to emit totals for the two resulting AOs, in tons per year, are as follows: NO* : 20.66, SO2 : 0.34, CO:52.26, VOC :71.36, PMro:4.00, PM2 5 :4.00, CO2e: 8,328, and HAPs :22.35. fl-ast updated October 9,2012] Comment regarding Adhesive Spray Booth: The adhesive spray booth that was originally included on the AO DAQE-AN016020005-03 dated May 20,2003 was removed from the equipment list with this modification. The source has removed this piece of equipment. The opacity limit for the booth's stack and the vinyl adhesive limit were also removed. [Last updated October 23,2012) Engineering Review N141670007: Autoliv ASP, Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9,2011and DAQE-AN01602005-03 Dated May 20,2003 October 23,2012 Page 13 6. 5. t. 40 CFR AO BACT CAA CAAA CDS CEM CEMS CFR CMS CO COz COze COM DAQ DAQE EPA FDCP GHG GWP ITA LB/HR MACT MMBTU NAA NAAQS NESHAP NOI NO* NSPS NSR PMro PMz s PSD PTE R307 R307-401 SO: Title IV Title V TPY UAC UDAQ VOC ACRONYMS The following Iists commonly used acronyms and associated translations as they apply to this document: Title 40 of the Code of Federal RegLrlations Approval Order Best Available Control Technology Clean Air Act Clean Air Act Amendments Classification Data System (used by EPA to classifo sources by sizeltype) Continuous emissions morritor Continuous emissions rnonitoring system Code of Federal Regulations Continuous monitoring system Carbon monoxide Carbon Dioxide Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-l Continuous opacity monitor Division of Air Quality (typically interchangeable with UDAQ) This is a document tracking code for internal UDAQ use Environmental Protection Agency Fr-rgitive dust corrtrol plan Greenhouse Gas(es) - 40 CFR 52.21 (b)(49xi) Global Warming Potential- 40 CFR Paft 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) Intent to Approve Pounds per hour Maximurn Achievable Corrtrol Technology Million British Therrnal Units Nonattainment Area National Ambient Air QLrality Standards National Emission Standards for Hazardous Air Pollutants Notice of lntent Oxides of rritrogen New Source Performance Standard New Source Review Particulate matter less than l0 microns in size Particulate matter less than 2.5 microns in size Prevention of Signifi cant Deterioration Potential to Emit RLrles Series 307 Rules Series 307 - Section 401 Sulfur dioxide Title IV of the Clean Air Act Title V of the Clean Air Act Tons per year Utah Adrninistrative Code Utah Division of Air Quality (typically interchangeable with DAQ) Volatile organic compounds Engineering Revierv N I 4 I 670007: Autoliv ASP. Incorporated - Modification to Approval Order and Combination of AOs DAQE-AN0141670005-l I Dated August 9, 20ll and DAQE-AN01602005-03 Dated May 20,2003 October 23,2012 Page l4 o o Page I of4 Heather Mickelson - RE: HAP Limit From: Daren Koldewyn <Daren.Koldewyn@autoliv.com> To: Heather Mickelson <hmickelson(@utah.gov> Date: 1011712012 2:35 PM Subject: RE: HAP Limit Attachments: Adhesive Emission Reduction.pdf; Adhesive Emission.pdf Heather, I had a meeting with the facility engineer to make sure I was correct on what I told you yesterday. I wish I would have talked to him first because although I was right on the vinyl adhesive process being removed, I was wrong on the paint spray booth and abrasive blast booth. The changes that need to be made from my previous list should only pertain to the adhesive spray booth. I researched my old NOls and permits and found out that the adhesive emissions were partially reduced for AO Original emissions applied to the adhesive spray booth in TPY (from the copy of the NOI emission worksheet provided to Autoliv from Yes Environmental lnc., February 6, 2001): PM10 2.4, VOC 9.6, HAPs 9.6. Adhesive fmissions removed by A.0. DAQE-AN1602005-03, May 20, 2003: PM10 -]..7L, VOC -7.97, HAPs -9.6. Adhesive Emissions to be removed from the Airbag Module Manufacturing Plant Limits: PML0 0.69, VOC 1.63, HAPs 1.71.. I apologize for not catching this earlier. Sincerely, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 da ren. koldewyn@autol iv. com From: Heather Mickelson [mailto:hmickelson@utah.gov] Sent: Tuesday, October 16,2072 4:27 PM To: Daren Koldewyn Subject: RE: HAP Limit Daren, This email is sufficient. I will need to know how the emissions and limits for Autoliv will change with the equipment removal. This can also be done through email. Heather > > > Da ren Koldewyn < Daren.Koldewvn@autoliv.com > 10 /L6/2072 4:15 PM > > > Hi Heather, I have reviewed the Source Plan Review and have a couple of changes that need to be made, but I hope we can do it through email. file://C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\507EC2IBEQDOMAINEQ.. . 1012312012 Page 2 of 4 1. Front page Plant Contact should be: Daren Koldewyn Phone (801) 520-8286 Fax (801) 620-8276 2. Section ll.A.7. We do not have the paint spray booth listed on the old AO, so should be removed. 3. Section tt.A.B. We do not have the adhesive spray booth listed on the old AO, so should be removed. 4. Section 11.A.12. We also don't have the abrasive blast booth listed on the old AO, so this piece of equipment should be removed too. 5. Section ll.B.1.b item D should be removed since it referencesthe paint and adhesive booth exhaust 6. Section ll.B.2.a The limits for the vinyl adhesive and sand blasting media should be removed as well. Ithinkthatisall. Pleaseletmeknowifyoucanmakethechangesoriflneedtobemore"official"aboutit. I appreciate your help, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 daren. koldewvn@autoliv.com From : Heather M ickelson Imailto : hm ickelson@ utah.qov] Sent: Tuesday, October 09,2012 1:58 PM To: Daren Koldewyn Subject: RE: HAP Limit Daren, Here is the Engineering Review/Source Plan Review for Autoliv with the modifications that we have discussed. Please look over it and let me know if you have any questions or comments. If not, please sign and return the first page. I think that I found an error for the limit given in II.B.2.b. The previous 2003 AO listed a limit for acetonirile. I believe that this is incorrect and changed it to acetonitrile. Please let me know if this is incorrect. Heather Mickelson Heather Mickelson, PE Environmental Engineer Division of Air Quality Utah Department of Environmental Quality Direct (801) 536-4014 hmickelson@ utah.gov > > > Daren Koldewyn < Daren.Koldewvn@autoliv.com > 10/8/2072 10:54 AM > > > Heather, On second or maybe third thought, let's go back to the 8.19 tons per year so we don't need to open up the file://C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\507EC2IBEQDOMAINEQ.. . 1012312012 Page 3 of4 Ogden facility AO. Thanks, Daren From: Heather Mickelson [mailto:hmickelson@utah.qov] Sent: Thursday, October 04,20L27:54 PM To: Daren Koldewyn Subject: Re: HAP Limit Daren, I am fine with that limitation. I will need a signed letter from Autoliv requesting the change. You can send it by mail or email. This allows me to open up the Ogden facilities AO for a quick amendment. Let me know if you have additional questions or comments. Heather >>> Daren Koldewyn <Daren.Koldewyn@autoliv.com> 10/4/20L2 4:04 PM >>> Heather, After looking at my emissions from the Ogden facility I want to increase the HAP limit at the Module facility from 8.19 to 9.0 tons per year. Because the HAP emissions from the Ogden facility are so minute, I think it would be better to have more flexibility at the Module facility. Let me know if that will work. Thanks, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 d a ren. ko ldewyn@ a utol iv. com *************************************************************** Consider the environment before printing this message. To read Autoliv's Information and Confidentiality Notj-ce, fol1ow this link: ht tp : ,/ ,/ www . autol iv . c om/ d i s c 1a ime r . html*************************************************************** * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * rr * * * * * )k * * * * * * * * * * * * * * * * * * * * * * * * * * Consider the environment before printi-ng this message. To read Autoliv's rnformation and Confidentiality Notice, fo]1ow this link: http : / /www. autoliv. com,/disclaimer. html- *********************************rr***************************** * * * * * * * * * * * * * * * * * * * * * * * * * * * * * rr * * * * * * * * * * * * * * * * * * tt * * * * * * * * * * * * * * Consider the environment before prinLing this message. To read Autoliv's Information and Confidentiality Notice, fo11ow this l-ink: http : / /www. autoliv. com/disclaimer. html * * * ** * * * * * * * * * * * * * * * * * * * ** * * * * * * )k * ** * * * * * * * ** *)t r( rt * * * * * * ** * * ** * * file://C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\507EC21BEQDOMAINEQ... 1012312012 Page 4 of 4 *************************************************************** Consider the environment before printing this message. To read Autoliv's fnformation and Confidentiality Notice, fo11ow this link: http : / /wvrw . autoliv. com/disclaimer. html-*************************************************************** file:i/C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\507EC21BEQDOMAINEQ... 1012312012 oo $ qgo;e -..xY,rBt sE fis;i EF eu *itrltoG>:fruoc.LLdrEr ,tE cE*i*36 Etr AfiE-;EE ;t .{;E*HEe:E[ *teIE8gfi Bs i rE' E 3 a* *: r * E ? =*{F*; .f$*r I*g$; r t+{s EiEEEE I*#.EI:i$g€EEEii se i a E E I E,g f g i*5p*;:Er,5E F16*;if;itE?(J.5.6,* E.ET "€(56!l=(0:':bE"E=s 5EE;$ r*;-.g3; it r] t1 lsiti li tl I(}Ilzl L] nliii l-l , $:*$r #xs*s EEg #*E** s 6 E E gt r fi E .g gc+ *;E*iltEEE ;;85$ f+i;EiEE*E#gE;fiEi$I;$E $*;gEtEi*?t s[rrEs*E$eg AE$;rEtgTEl .,ig$[Hf;.$E*EEfHE* $ T tr 6Ul- c,ESJEFOs*EC]trl tr"tlLU}tsOz-grrodG&o-3o o.-ls E a!o- (,l- o NH ffmffi ui'' ,J' #. r mnnil l"l t ] rf, ffiffinn Fi tll_-__ +Ol$)ro(](J(J***urN 6to(.r (9O JJ ))ll.1r LLlL ffinn [,] l*llli*lililltttLJ LJ Eqq()()$ rf)fo.?q\ OnF * (1::>i.i o U NC ,fE mnnH El)E ll a 3o-a.n6{E -2trE!,:,836<c G;;T;!e O AIFIic! o olalit_lI-o=lIq r: ${l loFFllN ,n -l I ___l tl lEl t1 I-l ilti: 16lEIJI.g lSidtxt* lr{t6 l-*.1 FIHIllt le[ " lall-l l,tt r*l;toretld l.i l=FllLI lnl-lio tDlltltttItl tl I _lEI}{E l--tolol Et lolo ltl la lE I lo IJE 6 tlo llFll"il6ixlrtvtzlF-l ,Irrl d l$l*io'rlalElJl 6lsiE l&1e trlvtxll$ Iu4 o T.T;I l==[]ls slL]E. ;T;td 6 6tdt l-" '[ 188 elles''lllt---Ttt't'l Ur,lltlILJlt ltl. , . .tlt L___l mtlL_lr*:;l;lI' 3 sliFIUI *elI '3'lll I IoI loI l.> IXX- XBl:s h>tal6 o a 6lri-l- .= .l; Its888IF l^ - *'-l' nIIit il_I ld)I lE 6 ll$-fia IIUEEEl(n,* * )l I I$ts s,B Ilkl ecr*l{$1(} O O (}lsi:: f :) ) I*JLL u- lr- Ir f €BH [ " "l=l treUri T:*ll*Il'8 8l ti:l T:1 IIuttttt,, ,tltItr---nt.,t,tttl UIl1tl LI f-s qial l="*1"'iIEHlcoolI ONII ni oltlttll l--l g I ' lf l. ail{ I C l-!I EEi{I sl€ll* n ilt: o I t outi6< -I lttt;l ,.> l'.al€ r 3 l$l; E 5 l;)] !, F Eli) I 3r a.El3l'o > i$l* F e o &atN6,r: ul{q c 1,o : (, ca -d Ioa EU oaGtr- Clr!f, ci ti cj oo(} osNNdr(}-{'i- nor: r.oo oooo&s,(!lo le{ l' l*ic, | (., t- [&$ 1* ke t&t * ,J i*u $-,i"*f!ff g i!-s.E ti)x* {": Abstract Arttoliv ASP, Incorporated (Autoliv), owner and opcrator af the airbag module manufacturing plant located at lCI{}{) West 3300 South, Ogden, Weber Cou.nty, has requested pertnission to modily DA$$- 340'W, by installing {our ncw emergenc! generators, I'hree a}'these gen€rators are natural gas taeted(78 kW - eaeh) and the other is diesel fueted (23CI kW). The 1,211 stall parking area originally appraved by DAQE-262-96 will be consolidated into fftis.40. The modyle m.an*{acturtng plant anil tke adiacent intlatar *anufccluring plant are considered a siaglr soilrce of ertksians {or the purp{rsel af determining Titte Y appt*ability. Based on potential.to*emit vala.es contained in thc rel*yant AOs (DAOE'340'01 and DAAE-623-AI) tho combined HAP emissions from these two plants aru great*r than 25 tons pcr jear. As sach, these plnnts wauld be wbject to the provisions of the Tirte V operoting permit plogram. Autoliv plaw,s to reducs use at * particular adhesive at the modwle plant So *ilth fln txten thot tlrc coa$ined ftrdfs *missions {rorn ltoth plants are less than 25 tot s psr yefi.r, fry redw*ing the use of lhis adhesive, the associated PMN and VOC emission estimates will also decrease. Ogden is a non-attainment aroa of the Naticnal. Amhient Air Quality Standards (NA.ApS) for Pil!* rYaw Source Performance Standards {NSPS), N*ianal frmission Standards for Haryrdoas .4jr Pollutants (NESHAP) and Maximum Available Cw$ral Tethnology (MACT) regulations da not appty to this $uurce. Title V of the I99O Clean Air AeI does ffor appl! to this source- The emi-csisns frarn the module mannfacturing plant in tons per lear, wilt ehange as fotlows: PM n(- 1.71),lf0, {+ 0.33), SOz ft 0.A2), CO (t 0.08), VOC (- 7.97}, HA?s {- 7.59). The changes in emissiorxs rvdl result in the follawing potential to emit totals for the module manu.facturing plafit: PbIn 1.37, NO.4,86, SOt 0.09, CO I'l.Sg, VOC d.52, I{APs j.76 The prr:ject has been evaluated arrd lburrd tu tre consistent with the requirements of the Urah Administrarive Code Rule 307 (tlAC R307). A public commen{ peri<xl r*"as held in accorclance wirh tlAC R307401-l and no commeflts were received. This air quality Approval Order (AO) authorizes the pro.!ect with the following cronditions. and failure to comply rvith any of the conditions may constitute a violation of this order. Gtneral Conditions: l. This Approval Order {AOi applies to the fcrllowing cornpany: Site office Autoliv ASP, Inc. 1000 West 3300 South Ogden, Utah 84401 Phone Number: (801) 629-9898 Fax Number: (801) 629-97A2 Cprporate 0ttic g*_L_ss3tlAl Autoliv ASP,Inc. 3350 Airport Road Ogden, Utah 84405 (80r) 62s-4960 (B0r) 625-fi601 The equipment listed in this AO shall be operated at the following location: 1000 West 3300 South Ogden, lYeber County universal rransverse Mercator (LlrM) Coordinate system: urM Datum NAD2T 4.56I"95 kilometers Northing, 4t5.94 kilomerers Easting, 'lnne 12 Page I of2 Heather Mickelson - RE: Engineering Review For Autoliv From: To: Date: Subject: CC: Daren Koldewyn <Daren.Koldewyn@autoliv.com> Heather Micke lson <hmickel son(@utah. gov> 81301201210:37 AM RE: Engineering Review For Autoliv Leonard Barton <Leonard.Barton(@autoliv.com> Heather, I just reviewed the Autoliv source plan review. I don't like the idea of aggregating all three Approval Orders. lt makes sense to aggregate the two ApprovalOrders {DAQE-AN0141670005-11and AN01602005-03}from the Module facility because they are for the same facility. But the other Approval Order (AN100250013.-11) is for the Ogden faciiity. The Module facility and Ogden facility have separate purposes, separate management and separate EPA lD numbers. Managing the Approval Orders would be a lot easier for me if they weren't aggregated. It would worl< best for me if Approval Order AN100250011-11 remained as it currently is and the other two be aggregated. I would like to know what you think about this situation before I reply with my other comments. Since relv, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 daren. koldewyn@autoliv. com From: Heather Mickelson [mailto:hmickelson@utah,gov] Sent: Tuesday, August 28, 2012 2:25 PM To: Daren Koldewyn Subject: Engineering Review For Autoliv Hello Daren, Here is the Engineering/Source Plan Review for Autoliv's AO modification. Please review it and let me know if you have any questions or comments. Since the AO's were combined, I was not sure about the address. I google mapped the addresses and they all appear to be on top of each other. If you don't have any questions or comments, please sign and return the first page. You can return it via mail, email or fax. file://C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\503F426DEQDOMAINEQA... 9llll2012 Page2 of2 Thanks, Heather Heather Mickelson, PE Environmental Engineer Division of Air Quality Utah Department of Environmental Quality Direct (801) 536-4014 hmickelson@utah.qov *************************************************************** Consider the environment before printing this message. To read Autoliv's Information and Confidentiality Notice, follow this link: http : / /www. autoliv. com,/disc]aimer. html*************************************************************** f,rle://C:\Users\hmickelson\AppData\Local\Temp\XPgrpwise\503F426DEQDOMAINEQA... 9lll12012 Page 1 of2 Heather Mickelson - RE:iv Burnoff Oven Additional In From: DarenKoldewyn <Daren.Koldewyn@autoliv.com> To: Heather Mickelson <hmickelson@utah.gov> Date: 7161201210:05 AM Subject: RE: Autoliv Burnoff Oven Additional Information From: Heather Mickelson fmailto:hmickelson@utah.gov] Sent: Tuesday, July 03, 2A72 4:37 PM To: Daren Koldewyn Subject: Re: Autoliv Burnoff Oven Additional Information Daren,. I have reviewed the information that was sent on June 5th. The CO2e was not given for the entire source. CO2e was only estimated for the oven and after burner combination. I have done a quick calculation for the CO2e from the air make-up unit on the spreadsheet that you sent. It is on the page titled 8760 hr per year. Could you take a look at it and let me know if you agree with the overall emission estimate? It is highlighted in yellow. I will use this source-wide emission estimate in the Approval Order. Please let me know if there are additional equipment pieces that emit CO2e or its constituents. These will need to be added to the AO. Thanks, Heather Mickelson Heather Mickelson, PE Environmental Engineer Division of Air Quality Utah Depaftment of Environmental Quality Direct (801) 536-4014 hmickelson@utah.qov Please note: Starting Tuesday, September 6, 2011, our agency hours will be 8am-5pm, Monday- file://C:\Documents and Settings\Hmickelson\Local Settings\Temp\XPgrpwise\4FF6885C... 7ll0l20l2 o Autol o format ron ., Page2 of2 Friday. >>> <Dalen.,Kp!-dewyn@autoliv.com> 6/5l20LZ 2:07 PM >>> Hi Heather, I have finally compiled the additional information you requested for the burnoff oven permit. Please see the attached word and excel file. Let me know if you need more information. Sincerely, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 da ren. koldewyn @autol iv. com (See attached file: Oven Emissions.xlsx)(See attached flle: Addendum to Burnoff Oven NOI.doc<)********************x****************r<x*x*x**x**x**x*x***x***** Consider the environment before printing this message. To read Autoliv's Information and Confidentiality Notice, follow this link: http :l/www.autoliv.comldisclaimer. htmlx**************xx*************xx******************************* *************************************************************** Conslder the environment before prlnting this message. To read Autoliv's Information and Confidentiality Notice. follow this link: http : / /www.autofiv. com/disclaimer. html *******+**********************++++++++*+++****+*++***++*+++++++ file://C:\Documents and SettingsVlmickelson\Local Settings\TempU(Pgrpwise\4FF6B85C... 7ll0l20l2 Operating Gapacity (BTU/hr) Natural Gas Heat Gontent (BTU/ft3)" Natural Gas Usage (ft3/hr) Hours of Operation (hr/yr) Natural Gas Usage (scf/yr) 390,000 1,020 382 8,760 3,346,320 Table 1 Burn-Off Oven Emissions 382 Ec 1. Cr 2. (h 3. U: 4. 2t *l Ta \V-r'a"f- \r€a,..Y! ')-( <1 --1 -{-),'i ;.v-. ' - 1 .. '-'.'\ ,', (1. ,-u-\'.J*a. ,r r i -.- "-L ,4 -^ . '''i,n-,;7 ,r-- 3,349,412 (BTU/hr) / Natural Gas Heat (ft3/hr) x Hours of Operation / 1,000,000)x Annual Gas ethane Emissions (lbs/yr) x .4 - Natural Gas Combustion, or CO, which is from Table Pollutant Emission Factor (lb/l06 scfl* Annual Gas Usage (scf/vr) Emissions (lbs/yr) Emission (tons/yr) Lead 0.0005 3,346,320 0.00167 0.00000084 NO,2.2 3,346,320 7.3t 0.00368 PMro 7.6 3,346,320 25.4 0.0127 SO,0.6 3,346,320 2.01 0.0010c voc 5.5 3,346,320 18.4C 0.0092 o B4 3,346,320 281.0S 0.141 CO,120,000 3,346,320 401,55€200.78 Methane 2.3 3,346,320 7.7C 0.00385 Oze 3,346,320 401,74 200.87 HAPs Benzene 0.0021 3,346,320 0.007c 0.0000035 Dichlorobenzene 0.0012 3,346,320 0.004c 0.000002c Formaldehvde 0.075 3,346,320 0.21 0.0001 Hexane 1.8 3,346,320 6.02 0.003c Naohthalene 0.00061 3,346,320 0.002c 0.000001c Toluene 0.0034 3,346,320 0.011 0.0000057 Air Make-up Unit - emission factors from AP-42 Table 1.4-2 Operating Capacity (BTU/hr) 6,804,000 NaturalGas Heat Content (BTU/ft3) 1,020 Natural Gas Usage (tt3ttrr) 6670.5882 Annual Gas Usage (scf/yr) 58,434,353 58,434,353 Hours of Operation (hr/yr) 8,760 Emissions (lbs/yr) 7,012,122 134.40 7,015,348 Natural Gas Usage (scf/yr) 58,434,353 Emission (tons/yr) 3506.06 0.06720 3507.67 Pollutant EmissionFactor (lb/106 scf) co2 methane CC2e 1 20000 2.3 CO2e from oven and air make up unit \-\ 1.,11 c.\Cu(1't.1vr- 3708.55 't Nox CO so2 VOC PMlO PM2.5 HAPs CO2e 14167 2011 0.06 2.19 0.02 40.14 1.32 1.32 12.18 3708.55 Total 14167 0.06 2.33 0.02 40.15 1.33 1.33 12.18 3708.55 Total AIIAO 20.66 52.26 0.34 51.50 3.99 2.62 17.65 4726.55 Current AO 1 0025 2011 116022003 15.74 4.86 35.34 14.59 0.23 0.09 4.83 6.52 1.29 1.37 1.29 Not Estimated 1.71 3.76 1018 Not Estimated 0.004 0.14 0.001 0.01 0.01 0.01 0.003 see 14167 k\ (q, c \al!..,--.-2)h r-vratc 1' ,t,o - Autoliv Burnoff Oven Additional lnformation <Daren.Koldewyn@autoliv.com> <hm ickelson@utah.gov> 61512012 2:08 PM Autoliv Burnoff Oven Additional lnformation Oven Emissions.xlsx; Addendum to Burnoff Oven NOl.docx Page 1 From: To: Date: Subject: Attachments: Hi Heather, I have finally compiled the additional information you requested for the burnoff oven permit. Please see the attached word and excel file. Let me know if you need more information. Sincerely, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801 -620-8286 daren. koldewyn @autoliv.com (See attached file: Oven Emissions.xlsx)(See attached file: Addendum to .'.vr.".T:9 vE.t?.i *::1... "....... Consider the environment before printing this message. To read Autoliv's lnformation and Confidentiality Notice, follow this link: http://www.autoliv.com/disclaimer. html May 30,2012 Additional Information for the Autoliv Module Facility NOI 1. Emissions Estimate for the bum oven assuming operation of 8760 hours per year. See Table 1 (attached). 2. The combined rating of the oven and the after burner is 0.39 MMBTU/hr. They are not each individually rated at 0.39 MMBTU/hr. CO2e emissions for the entire Module Facility. Emission factors from GHG Protocol See HAPs section of Table 1 (attached). J. 4. Table 1 Burn-Off Oven Emissions Equations Used: 1. Natural Gas Usage (ft3/hr)= Operating Capacity (BTU/hr)/ Natural Gas Heat Content (BTU/ft3) 2. Natural Gas Usage (scf/yr) = Natural Gas Usage (ft3/hr) x Hours of Operation (hr/yrl 3. Emissions (lbs/yr) = (Emission Factor (lb/106scf)/ 1,000,000) x Annual Gas Usage (scflyr) 4. COre (lbs/yr) = (CO2 Emissions (lbs/yr) x 1)+ (Methane Emissions (lbs/yr)x 24) xNote: Emissions factors are from AP-42 Section 1.4 - Natural Gas Combustion, Table 1..4-2 and 1.4-3, except the emission factor for CO, which is from Table Operating Capacity (BTU/hr) Natural Gas Heat Content (BTU/ft3). Natural Gas Usage (ft3/hr) Ho urs Operation (hr/yr) of Natural Gas Usage (scf/yr) 390,000 1,020 382 8,760 3,346,320 Pollutant Emission Factor Ilh/{ O6 sr:fl* Annual Gas Usage (scf/yr) Emissions (lbs/yr) Emission (tons/yr) -ead 0.0005 3.346,320 0.00167 0.0000008r ro,2.2 3,346,320 7.3e 0.0036t )M.,0 7.6 3,346,320 25.4 0.0121 SOz 0.6 3,346,320 2.01 0.0010i /oc 5.5 3,346,320 18.4C 0.009, 30 84 3,346,320 281.0€o.141 3oz 120,000 3,346,320 401,55€200.7t Methane 2.3 3,346,320 7.7C 0.0038t SOze 3,346,320 401,743 200.8i {APs 3enzene 0.0021 3,346,320 0.007c 0 000003f )ichlorobenzene 0.0012 3,346,320 0.004c 0.000002c Eormaldehvde 0.075 3,346,320 o.2r 0.0001 'lexane 1.8 3,346,320 6.02 0.003c !aphthalene 0.00061 3,346,320 0.002c 0.000001c loluene 0.0034 3,346,320 0.0'11 0.0000057 Michael O. kavitt CrOvcma Diame R. Nielson, Ph.D. Exmtirc Dircctor Richard W. Sprott Dirrcror Whete ideas annect Deparfnent of Environmental Quality Division ofAirQualrty 150 North 1950 West P.O. Box 1,14820 sdr Lskc city, utah 841144820 (801) 5364099 Fax (801) 5364414 T.D.D. www.deq.utah.gov DAQE-ANr60200s-03 iuflay20,2003 Daren Koldwyn AUTOLry ASP, Inc./Auto Safety 3350 Airport Road Ogden, Utah 84405 Dear Mr. Koldwyn: Re: Approval Order: Modification of Approval Order DAQE-340-01, by krstalling Four New Emergency Generators, Adding a Parking LoL and Decreasing IIAP Emissions, Weber County -CDS SM; NA; HAPs. Project Code: N1602-005 The attached document is the Approval Order (AO) fol the above-referenced project. Future correspondence on this Approval Order should include the engineefs name as well as the DAQE number as shown on the upper right-hand corner of this letter. Please direct any technical questions you may have on this project to Mr. Tim De Julis. He may be reached at (801) 5364012. Sincerely, Richard W. Sprott, Executive Secretary Utah Air Qualrty Board . RWS:TD:re cc: Weber-Morgan Health Department Mike Owens, EPA Region VIII STATE OF UTAH Department of Environmental Quality Division of Air Quality APPROVAL ORDER: MODIFICATION OF APPROVAL ORDER DAQE-340-01, BY INSTALLING FOUR NEW EMERGENCY GENERATORS, ADDING A PARKING LOT ANID DECREASING HAP EMISSIONS Prepared By: Tim De Julis, Engineer (80r)s36-4012 Email: tdeiulis@utah.eov APPROVAL ORDER NUMBER DAQE-AI\160200$03 Date: May 20,2003 AUTOLIV ASP, Inc./Auto Safety Source Contact Daren Koldewyn (801) 62s-4960 Richard W. Sprott Executive Secretary Utah Air Quality Board Abstract Autoliv ASP, Incorporated (Aulolif , owner and operator of the airbag module monufacturing plant located at 1000 llest 3300 Soath, Ogden, lYeber County, has requested permission to modify DAQE- 340-01, by installingfour new emergency generalors. Three of these generalors are natural gasfueled (78 kW - each) and the other is diesel fueled (230 kry). The 1,211 stall parking area originally approved by DAQE-262-96 will be consolidated into this AO. The module manufacturing plont and the adjacent inflator manufucturing plant are considered a single source of emissions for the purposes of determining Title V applicability. Based on potential-to-emit values contained in the relevant AOs (DAQE-340-01 and DAQE-623-01) the combined HAP emissions from these two plants are greater than 25 tons per year. As such, these plants would be subject to the provisions of the Title V operating permit progrom. Autoliv plans to reduce use of a porticular adhesive at the module plant to such an extent that the combined HAPs emissions from both plants are less than 25 tons per year. By reducing the use of this adhesive, the associated PMto and VOC emission estimates will also decrease. Ogden is a non-attainment area of the National Ambient Air Quality Standards (NAA$S) for PMls New Source Performance Standards (N,SPS), National Emission Standards for Hazardous Air Pollutants (NESHAP) and Moximum Available Control Technologt (MACD regulations do not apply to this source. Title V of the 1990 Clean Air Act does not apply to this source. The emissions from the module manufacturing plant, in tons per year, will change as follows: PMp C 1.71), NO* (+ 0.33), SO2 t 0.02), CO (+ 0.08), VOC (- 7.97), HAPs (- 7.89). The changes in emissions will result in the following potential to emit totals for the modale manufacturing plant: PMru 1.37, NO,4.86, SO2 0.09, CO 14.59, VOC 6.52, HAPs 3.76 The project has been evaluated and found to be consistent with the requirements of the Utah Administrative Code Rule 307 (UAC R307). A public comment period was held in accordance with UAC R307-401-4 and no comments were received. This air quality Approval Order (AO) authorizes the project with the following conditions, and failure to comply with any of the conditions may constitute a violation of this order. General Conditions: 1. This Approval Order (AO) applies to the following company: Site Office Autoliv ASP, Inc. 1000 West 3300 South Ogden, Utah 84401 Phone Number: (801) 629-9898 Fax Number: (801) 629-9702 The equipment listed in this AO shall 1000 West 3300 South Ogden, Weber County Corporate Office Location Autoliv ASP, Inc. 3350 Airport Road Ogden, Utah 84405 (80r) 62s-4960 (801) 62s-8601 be operated at the following location: Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 4,561.95 kilometers Northing, 415.94 kilometers Easting, Zone 12 DAQE-AN1602005-03 Page 3 5. 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. 3. The limits set forth in this AO shall not be exceeded without prior approval in accordance with R307-401. 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. 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 the following minimum periods: Emission lnventories Five years All records Two years Autoliv shall install and operate the new emergency generators and shall conduct its operations of the airbag module manufacturing plant in accordance with the terms and conditions of this AO, which was written pursuant to Autoliv's Notice of lntent submitted to the Division of Air Quality (DAQ) on October 22,2002 and additional information submitted to the DAQ on March 12,2003. 7. This AO shall replace the AOs (DAQE-340-01) dated May 30,2001, and (DAQE-262- 96) dated March 7,1996. 8. The approved installations shall consist of the following equipment (or equivalent*): A. Three (3) Emergency Generator Engines NEW ***Manufacturer: Fuel: Output: Kohler Natural Gas 78 kW - each B. One (l) Emergency Generator Engine NEW ***Manufacturer: Fuel: Output: C. One (1) Paint Spray Booth Manufacturer: Particulate Control: Caterpillar Diesel 230 kw SprayKing 6. * rt( {< Fiberglass or Polyester Filters oo DAQE-AN1602005-03 Page 4 D. E. One (l) Adhesive Spray Booth Particulate Control: Two (2) Boilers Manufacturer: Fuel: Rating: Parking Lot Number of stalls:l,2ll Miscellaneous Natural Gas boilers and Space Heaters, having ratings less than 5,000,000 Btu/hr - each, with combined heat outputs of up to 10,000,000 Btu/hr. ** One (l) Unconfined Abrasive Blast Booth Forklifts and other non-road mobile equipment (powered by propane, gasoline, or Fiberglass or Polyester Filters ** Lochinvar Natural Gas Less than 5,000,000 Btu/trr - each F. G. H. I. J. 9. * Equivalency shall be determined by the Executive Secretary. ** This equipment is listed for informational purposes only. *** This equipment specific detail is listed for informational purposes only. Autoliv shall notifu the Executive Secretary in writing when the installation of the equipment listed in Condition #8-A and #8-B has been completed and is operational, as an initial compliance inspection is required. To insure proper credit when notifring the Executive Secretary, send your correspondence to the Executive Secretary, atln: Compliance Section. diesel) Various Equipment Items, Production emissions to the ambient environment: Injection Molding Machines Parts Washers Airbag Module Production Equipment Plant Maintenance Equipment Maintenance Offices Laboratories Processes, and Activities with negligible ** has not been completed within eighteen months from the Secretary shall be notified in writing on the status of the Executive Secretary shall require documentation of the If installation of said equipment date of this AO, the Executive installation. At that time, the continuous installation of the R307-401-l r. equipment and may revoke the AO in accordance with DAQE-AN1602005-03 Page 5 Limitations and Tests Procedures Visible emissions from the following emission points shall not exceed the following values: A. All natural gas, propane, and gasoline fueled combustion device exhaust stacks - l0o/o opacity B. All paint and adhesive booth exhaust stacks - l0% opacity C. All diesel fuel combustion exhaust stacks - 20% opacity D. Outdoor abrasive blasting operations - 20% opacity E. All other points -20% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. I l. The following consumption limits shall not be exceeded: A. 625 gallons of vinyl adhesive per rolling l2-month period B. 1,000 pounds of sand blasting media per rolling l2-month period C. 6,000,000 gallons of propane for the entire plant per rolling l2-month period D. 3,000,000 gallons of gasoline for the entire plant per rolling l2-month period E. 3,000,000 gallons of diesel fuel #2 for the entire plant per rolling l2-month period F. 60,000,000 cubic feet of natural gas for the entire plant per rolling l2-month period To determine compliance with a rolling l2-month total the owner/operator shall calculate a new l2-month total by the twentieth day of each month using data from the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of material supplier billing records. The records of consumption shall be kept on a monthly basis. 12. Emergency generators shall be used for to produce electricity only during the periods when electric power from the public utility is intemrpted, or for regular maintenance of the generators. Records documenting each generator engines usage shall be kept in a log and they shall show the date each generator engine was used, the duration in hours of each generator engine's usage, and the reason for each generator engine's usage. Roads and Fusitive Dust t3. The owner/operator shall abide by all applicable requirements of R307-206, Abrasive Blasting Requirements. The.owner/operator shall abide by all applicable requirements of R307-309 for PMle non- attainment areas. The owner/operator shall use natural gas as fuel in the Kohler emergency generators, the boilers, and the other fuel burning devices listed in condition #8-G. 10. Fuels 14. 15. o DAQE-AN1602005-03 Page 6 16. The sulfur content of any fuel oil or diesel burned shall not exceed: 0.5 percent by weight for diesel fuels consumed in all other equipment. The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent. Certification of fuel oil or diesel fuels shall be either by Autoliv's own testing or test reports supplied by the fuel marketer. Volatile Oreanic Compound (VOC) and Hazardous Air Pollutants (IIAPs) Limitations 17. The plant-wide emissions of VOCs and IIAPs from the Ogden module manufacturing plant shall not exceed: 5.84 tons ner rollins l2-month period for VOCs 0.25 tons per rolling l2-month period for Formaldehyde 0.25 tons per rolling l2-month period for Glycol Ethers *3.26 tons per rolling l2-month period for the combined following HAPs: Acetonirile, Benzene, Cumene, Dichlorobenzene, Ethylbenzene, Ethylene Glycol, Hexane, Methylene Chloride, Methyl Ethyl Ketone, Methanol, Methyl Isobutyl Ketone, Naphthalene, Perchloroethylene, Phenol, Styrene, Toluene, Trichloroethylene, and Xylene. 3.76 tons per rolling l2-month period for all the above listed HAPs * Any individual HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for in R307-410-4. The above VOC and HAP limits do not include the products of incomplete combustion generated by the emergency generator engines, boilers, assorted fuel burning equipment items, or use of the parking lot. Compliance with each/the limitation shall be determined on a rolling l2-month total. Based on the twentieth day of each month, a new l2-month total shall be calculated using data from the previous 12 months. 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: Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. Density of each material used (pounds per gallon) Percent by weight of all VOC and FIAP in each material used Gallons of each VOC and HAP emitting material used A. B. C. D. o o DAQE-AN160200s-03 Page 7 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 (100) (eal) I ton 2000Ib HAP: % HAP by Weight x [Density ( lb )] x Gal Consumed x I ton (100) (eal) 20001b The amount of VOC or FIAP emitted monthly from all materials used. The amount of VOCs or fIAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or FIAP emissions. Records & Miscellaneous 18. 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 Approval Order 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. 19. The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. 20. The owner/operator shall comply with R307-107. General Requirements: Unavoidable Breakdowns. The Executive Secretary shall be notified in writing if the company is sold or changes its name. 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 R307. A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting the Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of Intent (NOI) guide, and other air quality documents and forms may also be obtained on the lnternet at the following web site: http /iwww.deq.state.ut.us/eqair/aq_home.htm The annual emission estimations below include point source, fugitive emissions, tail pipe emissions, and do not include, fugitive dust, road dust, or grandfathered emissions. These emissions are for the purpose of determining the applicability of Prevention of Significant Deterioration, non-attainment area, maintenance area, and Title V source requirements of the R307. They are not to be used for determining compliance, except for VOC and HAPs with the limits listed in condition #17. F. G. DAQE-AN1602005-03 Page 8 The Potential To Emit (PTE) emissions for the Ogden airbag module manufacturing plant are currently calculated at the following values: Approved By: Richard W. Sprott, Executive Secretary Utah Air Quality Board oO ? State of Utah GARYR. HERBERT Govcmor GREGBELL Lieutenant Govermor Department of Environmental Quality Amanda Smith Executivc Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-AN014167000s-11 August 9,2011 Don Bolt A&KFinishing,Inc. P.O. Box 888159 Grand Rapids, MI49548 DearMr. Bolt: Re: Approval Order: Modification to Approval Order (DAQE-AN0141670@-10) Project Number: Nl4l67-0005 The attached document is the Approval Order for the above-referenced project. Future correspondence on this Approval Order should include the engineer's name as well as the DAQE number as shown on the upper right-hand corner of this letter. The project engineer for this action is Ms. Heather Mckelson, who may be reached at (801) 5364014. Sincerely, Bryce C. Bird, Executive Secretary Utah Air Quality Board BCB:HM:dn Weber-Morgan Health Department 195 Nonh 1950West. Salt kke City, UT Mailing Address: P.O. Box 144820. Salt Lakc Ciry, LIT 841144820 Telephone (801) 536-4000. Fax (801) 5364099. T.D.D. (8Ol) 536,1414 w.deq.umh,gov Prinled on 100% recyclcd paper STATE OF UTAH Department of Environmental Quality Division of Air Quality APPROVAL ORDER: Modification to Approval Order (DAQE-ANo141670004-10) Prepared By: Ms. Heather Mickelson, Engineer Phone: (801) 536-4014 Email: hmickelson@utah.gov APPROVAL ORDER NUMBER DAQE-AN0141670005-11 Date: August9,20ll A & K Finishing,Inc. Source Contact: Don BoIt, Vice President of Operations Phone: (616) 949-9f00 Bryce C. Bird Executive Secretary Utah Air Quality Board r, rl '!] Abstract A & K Finishing, Inc., a plastic parts coating line plant, is seeking a modification of its Approval Order, DAQE-AN01416700M-10, dated June 3, 2010. They have requested an increase in their VOC and HAP limitations due to increased production and reformulation of the applied coatings. A & K Finishing, Inc. is located in Ogden (Weber County), Utah. Weber County is a nonattainment area of the NAAQS for PMro and PM2.5 and Ogden is a maintenance area for CO. NSPS, NESHAPS, and MACT do not apply to this source. Title V of the 1990 Clean Air Act does not apply to this source. The emissions, in tons per year, will change as follows: VOC (+) 20.00 and total HAPs (+) 4.36. The source-wide potential to emit totals, in tons per year, will be as follows: PMls = 1.33, PMz.s - 1.33, CO = 2.19, NO* = 0.06, SO2 = 9.92, VOC = 60.00, and total HAPs = 16.54. PM2.5 emissions are a subset of PMle emissions, and are, therefore, not additive. This air quality AO authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order. This AO is issued to, and applies to the following: Name of Permittee: A & K Finishing,Inc. P.O. Box 888159 Grand Rapids, MI49548 UTM coordinates: SIC code: Permitted Location: 1000 West 3300 South Unit 7 Ogden, UT 84401 I,I r.2 I.3 415,687 m Easting,4,56l,888 m Northing, UT1l4Znne 12 3799 (Transportation Equipment, NEC) Section I: GENERAL PROVISIONS The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307401-l] 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 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. 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] 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. 1R307-401-41 r.4 at , DAQE-AN0141670005-l l Page3 I.5 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. 1R307-1s01 I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable Breakdowns. [R307-107] I.7 All definitions, terns, 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] Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.I A & KFinishinglnc. Plastic parts surface coating plant tI.A.2 Coating Line Adhesion promoter spray booth, ozonation adhesion promoter system, topcoat spray booth, curing oven, touch-up spray booth, and high-volume low-pressure spray guns II.A.3 Air Make Up Unit Natural gas fueled - 6.084 MMBtU/hr II.B Requirements and Limitations II.B.1 Source-Wide Conditions II.B.1.a Visible emissions from any stationary point associated with the source or with the control facilities shall not exceed the following: A. Air Make Up Unit - 5Vo opacity B. All other points including fugitive emissions - 20Vo opacity. [R307-305] II.B.1.a.l Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9 or as approved by the Executive Secretary. 1R307-30s1 II.B.l.b The VOC- and/or HAP-containing materials shall be stored in covered containers (except when in use). VOC- andi/or HAP-laden rags shall also be stored in covered container. 1R307-401-81 II.B.2 Coatine Line Conditions II.B.2.a Emissions from the coating line (including but not limited to thinners, cleaning solvents, top coating, catalysts, and adhesion promoters) shall not exceed the following limits: 60.00 tons per rolling 12-month period for VOCs 4.44 tons per rolling 12-month period for toluene DAQE-ANOI4r670005-l l Page 4 11.8.2.a.1 TI.B.3 II.B.3.a Is Derived From Supersedes NOI dated May 2,2011 DAQE-AN0141670004-10 dated June 3, 2010 12.44 tons per rolling l2-month period for combined HAPs, which include: cumene, ethyl benzene, methyl isobutyl ketone, and xylenes (isomers and mixture). [R307-401-8] Compliance with each limitation shall be determined on a rolling l2-month total. No later than 20 days after the end of each month, a new l2-month total shall be calculated using data from the previous 12 months. The VOC or HAP emissions shall be determined by maintaining a record of VOC- or HAP- emitting materials used each month. The record shall include the following data for each material used: 1. Name of the VOC or HAPs emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. 2. Density of each material used (pounds per gallon) 3. Percent by weight of all VOC or HAP in each material used 4. Gallons of each VOC- or HAP-emitting material used 5. The amount of VOC or HAP emitted monthly by each material used shall be calculated by the following procedure: VOC = (VoYOC by Weight/l00) x [Density (lb/gal)] x Gal Consumed x 1 ton/2000lb HAP = (Vo H,\P by Weight/IO0) x [Density (lbigal)] x Gal Consumed x I tor/2000 lb 6. The amount of VOC or HAP emitted monthly from all materials used. The amount of VOCs or HAPs reclaimed or "recovered" 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] Air Make Un Unit Conditions Fuel: A & K FinishinS, Ing. shall use only pipeline quality natural gas as fuel. If any other fuel is to be used, an AO shall be required. [R307-401] PERMIT HISTORY This AO is based on the following documents: DAQE-AN0I41670005-l l Page 5 ADMINISTRATIYE CODING The following information is for UDAQ intemal classification use only: Weber County CDS B Nonattainment or Maintenance Area DAQE-ANOI41670005-11 Page 6 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR AO BACT CAA CAAA CDS CEM CEMS CFR CO Coz C02e COM DAQ DAQE EPA FDCP GHG GWP HAP or HAPs ITA LB/HR MACT MMBTU NAA NAAQS NESHAP NOT NO" NSPS NSR PMro PMz.s PSD PTE R307 R307-401 Soz Title IV Title V TPY UAC UDAQ voc Title 40 of the Code of Federal Regulations Approval Order Best Available Control Technology Clean Air Act Clean Air Act Amendments Classification Data System (used by EPA to classify sources by size/type) Continuous emissions monitor Continuous emissions monitoring system Code of Federal Regulations Carbon monoxide Carbon Dioxide Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 Continuous opacity monitor Division of Air Quality (typically interchangeable with UDAQ) This is a document tracking code for internal UDAQ use Environmental Protection Agency Fugitive dust control plan Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) Global Warming Potential - 40 CFR Part 86.1818-12(a) Hazardous air pollutant(s) Intent to Approve Pounds per hour Maximum Achievable Control Technology Million British Thermal Units Nonattainment Area National Ambient Air Quality Standards National Emission Standards for Hazardous Air Pollutants Notice of Intent Oxides of nitrogen New Source Performance Standard New Source Review Paniculate matter less than 10 microns in size Particulate matter less than 2.5 microns in size Prevention of Significant Deterioration Potential to Emit Rules Series 307 Rules Series 307 - Section 401 Sulfur dioxide Title IV of the Clean Air Act Title V of the Clean Air Act Tons per year Utah Administrative Code Utah Division of Air Quality (typically interchangeable with DAQ) Volatile organic compounds State of Utah GARY R. IIERBERT Govemor GREGBELL Licutenant Goverror Department of Environmental Quality Aman& Smith Exccutivc Director DrvlsroNoFArR QUALTTY Bryce C. Bird Dircctor DAQE-ANl002500ll-11 November 29,2011 Daren Koldewyn Autoliv ASP, Incorporated 3350 Airport Road Ogden, LIf 8,$405 DearMr. Koldewyn: Re: Approval Order: Administrative Amendment to DAQE-AN0025008-03 by Removing Equipment Project Number: N10025-001 I The attached document is the Approval Order for the above-referenced project. Future correspondence on this Approval Order should include the engineer's name as well as the DAQE number as shown on the upper righrhand comer of this letter. The project engineer for this action is Tim DeJulis, who may be reached at (801) 5364012. Sincerely, Bryce C. Bird, Executive Secretary Utah AirQuality Board BCB:TD:dn Weber-Morgan Health Department 195 North 1950 West . Sdr Lake Ciry, Uf Mailing Address: P.O. Box 144820 . SaIt kke City, UT 8/1144820 Telephone (801) 53640fi). Fax (801) 5364099 . T.D.D. (801) 53G441 w.deq.utaLgat Pr'rmed m 1009[ mycled paper o o' STATE OF UTAH Department of Environmental Quality Division of Air Quality APPROVAL ORDER: Administrative Amendment to DAQE-AN0025008-03 by Removing Equipment Prepared By: Tim DqIuIis, Bngineer Phone: (801) 5364012 Email: tdejulis@utah.gov APPROVAL ORDER NUMBER DAQE-ANI00250011-11 Date: November29,20ll Autoliv ASP, Incorporated Ogden Plant Source Contact: Daren Koldewyn, Environmental Coordinator Phone: (801) 625-4960 Bryce C. Bird Executive Secretary Utah Air Quality Board Abstract The Autoliv ASP, Incorporated (Autoliv), owner and operator of the automotive airbag manufacturing plant in Ogden, Weber County, has asked to amend the existing AO (DAQE-AN0025008-03) by removing equipment. The listed MIG welding stations, generant loading stations, foil ribbon application stations, electric ovens, and paint coating units will be removed. The reduction in emissions associated with the removal of these equipment items fits the definition in UAC R307401-12. The inflator plant will change to a research and development and product quality assurance testing (R&D/QA) operation. This R&D/QA operation and the adjacent module manufacturing plant are considered a single source of emissions. This combined source is considered as synthetic minor because of limits on VOC/HAPladen manufacturing product use imposed on the module manufacturing plant. Emissions totals that appear throughout this document are associated with the R&D/QA operations. Weber County is a nonattainment area of the NAAQS for PM2.5. Ogden is a maintenance area for CO. NSPS, NESHAP regulations (40 CFR 61) and Title V of the 1990 Clean Air Act do not apply to this source. MACT regulations apply to this source. The emissions, in tons per year, will change as follows: PMro (- 7.12),PM2.5( 7.12), VOC (- 19.00), HAPs C18.79) The potential to emit totals, in tons per year are as follows: PMls = 1.29,PM2.5= 1.29, NO* = 15.74, SO2 = Q./1, CO = 35.34, VOC = 4.83, HAPs = 1.71, CO2e = 1,018 PM2.5is a subset of PM1s. This air quality AO authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order. This AO is issued to, and applies to the following: Name of Permittee: Autoliv ASP, Incorporated 3350 Airpot Road Ogden, UT 84405 UTM coordinates: SIC code: Permitted Location: Ogden Plant 3350 Airport Road Ogden, UT 84405 I.t 416,354 m Easting, 4,561,673 m Northing, UTMZnne 12 3714 (Motor Vehicle Parts & Accessories) Section I: GENERAL PROVISIONS 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] The limits set forth in this AO shall not be exceeded without prior approval. [R307401]r.2 DAQE-AN100250011-l l Page 3 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. [R307401-l] 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 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. 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. [R307401-8] 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 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. 1R307-401-41 The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable Breakdowns. [R307-107] The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and Monitoring. [R307-150] Section II: SPECIAL PROVISIONS The approved installations shall consist of the following equipment: Ogden Plant Research, development, and product quality assurance testing Laser Fabric Cutting Devices (2) Boiler One (1) rated at less than five (5) MMBtU/hr Fuel: natural gas For information purposes. Emergency Generator Engines (3) One (1) rated at 110 kW Fuel: natural gas One (1) rated at 50 kW Fuel: natural gas One (l) rated at 27 k\l Fuel: natural gas r.6 r.7 II.A II.A.1 IT.A.2 TI.A.3 IT.A.4 o llDAQE-AN10025001r- Page 4 II.A.5 II.B II.B.I II.B.l.a tr.B.1.b.1 II.B.l.c II.B.1.c.1 Comfort Heating Devices Various devices rated less than at five (5) MMBtu/hr each Fuel: natural gas For information purposes. Requirements and Limitations The Oeden Plant shall be subiect to the followine Visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities shall not exceed: All boilers - 107o opacity All generator engines - llVo opacity All building exhaust stacks - l0Vo opacity All other points -20Vo opacity Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307401-8] The following consumption limit shall not be exceeded: 100,000,000 cubic feet of natural gas consumption per rolling 12-month period 1R307-401-81 A new l2-month total shall be calculated on a monthly basis by summing the monthly totals for the previous consecutive 12-months. Monthly calculations shall be made no later than 20 days after the end of each month. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of company andL/or customer billing records. The records of consumption shall be kept on a monthly basis. 1R30740r-81 The plant-wide emissions of VOCs and HAPs from research and development, quality assurance laboratories, and associated operations shall not exceed the following: 4.83 tons per rolling l2-month period for VOCs 1.71 tons per rolling l2-month period for all HAPs combined. 1R307-40r-81 To determine compliance with a rolling l2-month total, the owner/operator shall calculate a new l2-month total on a monthly basis by summing the monthly totals for the previous consecutive l2-months. Monthly calculations shall be made no later than 20 days after the end of each month. The VOC and HAP emissions shall be determined by maintaining a record of VOC- and HAP-emitting materials used each month. Records shall include all materials purchased that contain VOCs and HAPs. The records shall include the following data for each material used: DAQE-ANl002s00l l-l l Page 5 A. Name of the VOC- and HAP-emitting material, such as: 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 E. The amount of VOC and HAP emitted monthly by each material used shall be calculated by the following procedure: VOC = f%oYOC by Weight/1001 x [Density Qb/gal)] x [Gal Consumed] x (1 ton/2,000Ib) HAP = lVo HAP by Weight/1001 x [Density (lb/gal)] x [Gal Consumed] x (1 torl2,000 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. [R307401-8] Il.B.2 The Emersencv Generator Eneines shall be subiect to the following Il.B.Z.a The emergency generators shall be used for electricity producing operations only during the periods when electric power from the public utilities is intemrpted, or for regular maintenance of the generators. Records documenting generator usage shall be kept in a Iog and they shall show the date the generator was used, the duration in hours ofthe generator usage, and the reason for each generator usage. [R307-401-8] SectiOn III: APPLICABLE FEDERAL REOUIREMENTS 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. MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines PERMIT HISTORY This AO is based on the following documents: Incorporates Additional information dated October 4,2011 Incorporates Additional information dated September 12,2011 Is Derived From NOI dated August 30, 2011 Supersedes DAQE-AN0025008-03 dated December 11, 2003 oo DAQE-ANI00250011-11 Page 6 ADMIMSTRATIVE CODING The following information is for UDAQ internal classification use only: Weber County CDS SM MACT (Part 63), Nonattainment or Maintenance Area, Synthetic minor ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAirqA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by sizeltype) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CO Carbon monoxide COz Carbon Dioxide COze Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ Division of Air Quality (typically interchangeable with UDAQ) DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOt Notice of Intent NO* Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PMro Particulate matter less than 10 microns in size PMz.s Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SOz Sulfur dioxide Title IV Title IV of the clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code UDAQ Utah Division of Air Quality (typically interchangeable with DAQ) VOC Volatile organic compounds Autoliv April24,2012 Mr. Bryce Bird, Director Utah Division of Air Quality 195 North 1950 West Salt Lake City, Utah 84114 Subject: Notice of lntent Daren Koldewyn Environmental Engineer 1/ ^'S-\) 4,gd N Autoliv ASP, lnc. Ogden Assembly Facility 1 0C0 \Alest 3?CC Soilth Og.ien. Litah, LISA ti4401 7b*r*v/fa lqt{ 7 - u IAt,r Di.pr\BilrrENI (! NVlFio \.lt,,i :rt",1l /rl otJAl rl.rll? ? 5 lilfl I)]ViSJIOIv OF AIR QUALITY Dear Mr. Bird, We are sending this notice of intent for the modification of approval order DAQE- AN0141670005-11, dated August 9,2011 located at the Autoliv Module Facility in Ogden, UT. Autoliv is planning to install a burn-off oven to support the airbag cover painting operations. By installing a burn-off oven, the painting racks will be able to be cleaned on site instead of being shipped to an oven located offsite. We have included $2,300 for the review of the modification of this minor source; $500 for the filing fee and $1,800 for a modification to a minor source permit. Please contact me if you have any questions regarding the attached notice of intent. [, a.{ L I Notice of Intent for the Installation of a Burn-off Oven Autoliv, Module Facility 1000 West 3300 South Ogden, UT 84401 April 2012 at Autoliv Autoliv Asp, lnc. Ogden Assembly Facility 1000 West 3300 South Osden, Utah, USA 84401 TABLE OF CONTENTS Introduction Form I Notice of Intent (NOD Appendix Al - Process Description Appendix ,A.2 - Flow Diagram AppendixB-SitePlan Appendix C - Emission Calculations Appendix D - DAQ Form la APPENDICES Page2 Form I Notice of Intent l Utah Division of Air Quality New Source Review Section Form 1 Notice of lntent (NOl) er," sttat12 Applicationfor: ntnitiatApprovalOrder [Approval Order Modification APPROVAL ORDER MUST BE ISSUED BEFORE ANY CONSTRUCTION OR INSTALLATION CAN BEGIN. This iS not a stand alone document; please refer to UAC R307-401and the published NOI guidebook for information on requirements of the specified information below. Please print or type all information requested. All outlined information requested must be accurate and completed before DAQ can determine that an NOI is complete and an engineering review can be initiated. lf you have any questions, contact the Division of Air Quality at (801) 536-4000 and ask to speak with a New Source Review Engineer. Written inquiries may be addressed to: Division of Air Quality, New Source Review Section, P.O. Box 144820, Salt Lake City, Utah 84114-4824. ?ffiI\V,AYIE&w General Owner and Facility lnformation 4. Company** contact for environmental matters: Daren Koldewyn Phone no.: Bot G2o-8296 Email: daren.koldewyn@autol-iv.com ** Company contact only; consultant or independent contractor contact information can be provided in a cover lefter 3. Company name and address:Autoliv, Module Facility 1000 w 3300 s Ogden, UT 8440L Phone No.: Bo1 G29 9B9B Fax No.: 6. Owners name and address:Autoliv 3350 Airport Road Ogden, UT 84405 Phone no.: 801 62s-82oo Fax no.: 5. Facility name and address (if different from above): Phone no.: Fax no.: 7. Property Universal Transverse Mercator coordinates (UTM), including System and Datum: Easting: 41G. o Northing: 4s6o .9 System: UfMZone 12 Datum: Unknown 8. County where the facility is located in: Weber 9. Standard lndustrial Classification Code: 37L4 DAQ Form 'l Notice of lntent 1of 3 Updated: 11130111 10. Designation of facility in an attainment, maintenance, or nonattainment area($: Weber Co PM2.5 NAA Ogden City PM10 NAA Ogden City CO Maint Area 11. lfrequestformodification,AO#tobemodified: DAQE#aNo1416zooos-11 Date: B/9/11 12. ldentify any current Approval Orde(s) for the facility not being modified with this request: AO#ame oz oos - 03 AO# Date AO# Date AO# Date 13. Application for: nUew construction Ifxisting equipment operating without permit ECnange of permit condition XModification EPermanent site for Portable Approval Order ECnange of location 14. Construction or modification estimated start date:asap Estimated completion date:asap 15. Does this application contain justifiable confidential data? Eyes X tlo 16. Current Title V (Operating Permit) ldentification: none ino an enhanced Title V oermit with this AO modification 17. Brief (50 words or less) description of project to post on DAQ web for public awarenessInstallation of a burn oven with afterburner to cl-ean painting racks. Process lnformation Appendix A: Detailed description of project including process flow diagram (See Forms 2-23) XFuels and their use ffiEquipment used in process EDescription of product(s) f]Raw materials used EDescription of changes to process (if applicable) nStacX parameters EOperation schedules f]Production rates (including daily/seasonalvariances) * 3o7_4o1_ Appendix B: Site plan of facility with all emission points and elevations, building dimensions, stack parameters included R307-401 DAQ Form 1 Notice of lntent 2ot 3 Updated: 11130111 Emissionslnformation v 20. Appendix C: Emission Calculations that must include: XEmissions per new/modified unit for each of the following: PM1e, PMz.s, NO,, SO", CO, VOC, and HAPs nDesignation of fugitive and non fugitive emissions XUajor GHG Sources: Emissions per new/modified unit for GHGs (in CO2e short tons per year) XReferences/assumptions for each Emission Factor used in calculating Criteria pollutant, HAP, and GHG emissions nUnp emissions (in pounds per hour and tons per year) broken out by specific pollutant and summed a;.Br9l?15(r).o) 21. Appendix D: DAQ Form 1a or equivalent (comparison of existing emissions to proposed emission and resulting new totalemissions) 22. Appendix E: Source Size determination (Minor, Synthetic Minor, Major, or PSD) E lf an Existing Major Source: Determination of Minor, Major or PSD modification 23. Appendix F: Offset requirements (nonattainmenUmaintenance areas) EAcquired required offsets R307 401 -420 & R307-401 -42'l Air Po!!ution Control Equipment lnformation 24. Appendix G: Best Available Control Technology (BACT) analysis for the proposed source or modification N? T Ff t,t/ttrAtl Ll I V fFA4tAl F R307401-5(2Xd) Appendix H: Detailed information on all new/modified equipment controls. lt is strongly recommended using DAQ forms as they outline required information, but something equivalent to the DAQ forms is acceptable. R3o7_401_5(2xc) 25. 26. Appendix l: Discussion of Federal/State requirement applicability (NAAOS, SlP, NSPS, NESHAP, etc) Modelinq lnformation Appendix J: Emissions lmpact Analysis (if applicablel n ,,27. A??LI(A9LE R307-41 0-4 R307401-5(1) Electronic NO! 28. A complete and accurate electronic NOI submitted I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. signaturg,T-u, -, 7 Z-1/,g"-' T itle : snv i ronm ent a 1 Eng i ne e r Daren Koldewyn Name (print) 801 620-8285 Telephone Number: 4/20/201,2 Date: *with the exception of Federal Agencies who will be billed at completion of the project DAQ Form 'l Notice of lntent 3of3 Updated: 'l1l3ol11 Introduction Autoliv, Module Facility is planning to install a burn-offoven at the cover painting operation in Ogden. The purpose of the burn-off oven is to clean off excess paint residue from the painting racks used in the operation. The addition of the burn-off oven will eliminate the need to transport the painting racks to an oven in Salt Lake City where they are currently being cleaned. The site address is 1000 W 3300 South, Ogden, Weber County. The operation is on the existing Autoliv facility property located at the same street address. Ogden City is a non-attainment area for PMro and a maintenance area for CO. Weber County is a non-attainment area for PMz.s The Module Facility is an existing minor source. The modification is a minor modification. The Air Quality New Source Review Forms have been used to describe the proposed operation. Form I Notice of Intent (NOI) TheapprovalordertobemodifiedisDAQEAN0l4l6T0005-11datedAugust9,2011. This approval order was first obtained by A&K Painting and then transferred to Autoliv by a name and ownership change on December 1,2071. Approval order DAQE-AN1602005-03, also associated with the Autoliv Module facility is not being modified. Form la (Appendix D) Emissions Information Emissions listed on Form 1a include the permitted emissions from DAQE AN0141670005-11 and the emissions increases from the addition of the bum-off oven. Emissions from the bum-off oven are related to the combustion of natural gas. There are no HAPs or VOCs emitted from the burn-off oven. t t) :-\\\r-).,) 'ti.,.:>---. c)i- ( --.,,..,-rv :l,. :n..),. ,) t ,,-:r. 1. ,J tr,r:\ i , f) i :., \ Page 3 APPENDIX A1 PROCIiSS I}fiSC RII{TIfi }\J Jackson Orrcn Batch Burn-Off Ovens *re &signed to ffimoTrc cumd trydrncarbon materials such fis paint, gmanq mil" vsrnish aad small emouBts of rubber foom h**:ks, racks, fixtur r *nd p*rts, Removsl of a rnat*rial is accomplistrd by heating the matrrials ta be stripprd to 65OY- S0S5. Tlre roating is rrdr:md tn a ftrm" Xight urh and furnes. The funrcs pruduced are yentrd thxNrgh an afie*arrner charnfoer which raises ttre furue temperal*:rs to 14005 or highmr firr a minimum of, |1 second Tlp rre.sultar* ofltmnt discharged to atnreinphtte cnnxists ef watnr vapor (H2O) and carbar dimxidr (COz). A.qh reduelinn rcmains inside ths aven and ttrnsirBi primarily of innrganic pigmentr. Axh is rernqrwd &rom tlle aven and dixposed trf in accordanx with locnl codsn The basic nrr*n consirts of a steel enclosure with inxulated interior wslls flud ronf and a rcfrartary floor. A cornbustion chamber is prnvided ta dfutrir"uk heat nvr.mly thruughout the. ovrn. eri{mry burnrr and controls arc nwunted s* tte rear wall" A jack mount afterburner iu includcd with higlr tsmpslature rtack, urealtrer cap and ruof flnnga A mrt is pr,ovided frx lnading and unloading tlre r:r.sn" Page 5 APPENDIX A2 PROCESS FLOW DIAGRAM APPENDIX B SITE PLAN rl t] }] il il fl tflir lltit t+t 1r-*l -t t r a a t attia*EEW H #- ftt+tr+*l+r*ttt++ ffi r tt n rrir r r rn 37 st {xpre APPENDIX B SITE PLAN {=}E t_ rrlE E} ..:rf -{ H trr Tl]}trlr -{+ Page 8 APPENDIX C EMISSIONS CALCULATIONS Burn-off Oven Emissions Pollutant Emission Factor (tb/l05 scf). Annual Gas Usage (scf/yr) Emissions (lbs/yr) Emission (tons/yr) Lead 0.0005 476 736 0.00024 0.00000012 NOx 2.2 476 736 1.05 0.00052 PMlO 7.6 476 736 3.6 0.0018 so2 0.6 476 736 0.29 0.00014 voc 5.5 476 736 2.62 0.0013 co 84 476 736 40.05 0.020 co2 120 000 476 736 57 208 28.60 Methane 2.3 476 736 1.10 0.00055 CO2e 476 736 57 235 28.62 -ir /r) b l-S -1.r' ft FY\'o" Q^e-< _-eo 4 t,-f l-}U' O, C)\ 11. L)('l' L-. L)c--1o.\t 2o\ O ,:o 4- - 4o\ Equations Used: 3 1. Natural Gas Usage (ft /hr) : Operating Capacity (BTU/hr) / Natural Gas Heat Content (Bru/ft ) 2. Natural Gas Usage (scf/yr) : Natural Gas Usage (t'n r) x Hours of Operation (hr/yr) 3. Emissions (lbs/yr): (Emission Factor (lb/106scf) x1,000,000) x Annual Gas Usage (scf/yr) 4. COre (lbs/yr): (COz Emissions (lbs/yr) x 1) + (Methane Emissions (lbs/yr) x 24) *Note: Emissions factors are from AP-42 Section 1.4 - Natural Gas Combustion, Table 1.4-2, except the emission factor for CO, which is from Table 1 .4.1 of the same AP-42 section. Operating Capacity (BTU/hr) NaturalGas Heat Content {BTU/ft3)* NaturalGas Usage (ft3/hr) Hours of Operation (hr/yr) NaturalGas Usage (scf/yr) 390 000 1 020 382 1 248 476 736 Page 9 APPENDIX D DAQ Form la Page 10 ocompany_ Site/Source tr'l c Dt'u€ Date 03/2"1//2 - Please print neatly or type all information requested. All information must be truthful, accurate and complete before we can process your application. lf you have any questions, call (801) 536-4000 and ask to speak with a New Source Review engineer. Written inquiries may be addressed to: Division of Air Quality, NSR Section, P.O. Box 144820, Salt Lake City, Utah 841144820. UIA'IrGIiLl4lle R\*r"-H Utah Division of Air Quality New Source Review Section Form la Emissions lnformation Au'TcttV able 1.Emissions Pollutants Permitted Emissions (tons/vearl Emissions lncreases Itons/vearl Proposed Emissions (tons/vear) Griteria Pollutants PMro i.73 u. L'L' I t,I .33 PMz.s i33 Lt . ct''l I t.3j NO,D,Db 0 ooc,5z O . t2L'l SOz c .07 O . A?t-'11 0. o'L CO z, l'l O.DLO Z zl voc 1r1; . oC D.O0t3 bD. oc Greenhouse Gases Mass basis CO,e Mass basis CO,e lVlass basis CO,e Carbon dioxide (COz)LTEeC"JTLY /v/t ?eFAtT€t Zfr t, Zt,b Methane (CHa)COE:l-EN-rL,/ {y O'T ? E?r^t1rtD D.DcD55 . O t3 Nitrous oxide (NzO) Hydrofl uorocarbons (IIFCs) Perfluorocarbons (PFCs) Sulfur hexafl uoride (SFe) Tota! Hazardous Air Pollutants lb.5q o ll",5L1 Hazardous Air Pollutants (list individually) (attach additional sheet if needed) T,UUTNE.qqq U L1 Ll Ll ( t, .rvt Lnt € ') €1rrYy gf N7(_Nf ( tz.L/Ll \ tz qq /14tSK XYLL/vE9 ) Use additional sheets for other pollutants if needed. Page I of4 Utah Division of Air Quality Approva! Order Application Form ld Emissions Information Table 2. Controlled and Uncontrolled Emissions Pollutant Controlled Emissions (tons/year)Uncontrolled Emissions (tons/year) Criteria Pollutants PMro PMz.s NO, SOz CO voc Greenhouse Gases (GHGs)Mass basis CO,e Mass basis COee Carbon dioxide (COz) Methane (CtIa) Nitrous oxide (N2O) Hydrofl uorocarbons (FIFCs) Perfluorocarbons (PFCs) Sulfur hexafl uoride (SF6) Total GHG Emissions Total Hazardous Air Pollutants Hazardous Air Pollutants (list individually) (attach additional sheet if needed) Use additional sheets for other pollutants if needed Page2 of 4 Utah Division of Air Quality Approval Order Application Form 1d Emissions lnformation Table 3.HAP Emissions Hazardous Air Pollutants (!ist individually)Maximum emission rate (!bs/hour) Page 3 of4 PROCESS DESCRIPTION Jackson Oven Batch Burn-Off Ovens are designed to remove cured hydrocarbon materials such as paint, grease, oil, vamish and small amounts of rubber from hooks, racks, fixtures and parts. Removal of a material is accomplished by heating the materials to be stripped to 650"F- 800T. The coating is reduced to a fine, light ash and fumes. The fumes produced are vented through an afterburner chamber which raises the fume temperatures to 1400oF or higher for a minimum of Yz second. The resultant effluent discharged to atmosphere consists of water vapor (HzO) and carbon dioxide (COz). Ash reduction remains inside the oven and consists primarily of inorganic pigments. Ash is removed from the oven and disposed of in accordance with local codes. The basic oven consists of a steel enclosure with insulated interior walls and roof and a refractory floor. A combustion chamber is provided to distribute heat evenly throughout the oven. Primary burner and controls are mounted on the rear wall. A jack mount afterburner is included with high temperature stack, weather cap and roof flange. A cart is provided for loading and unloading the oven. JACKSON OVEN SUPPLY, INC. lndustrial Ovens Parts Service ro |r, c.! c!oo Is ootlNoo o)N r trooooi-(o $ oz I IUo o al, tL I 6 oF rO,*'r3e=Orr,Ol.-oo(o o tf, -NN$oo -tOOO--zzz Itt+ LU tU trj;oaav<<<<ooo PROCESS FLOW DIAGRAM JACKSON OYEN BATCH BURN.OFF J83 BURhTERS _ 780,000 BTU/TOTAL TO ATHOSPHERE AF'TERBURNER 39o,ooo aril,rgn f tMAtr. ) 90cFr{ MAIN BURNER 390,000 B?U,/I{R {MAX^ ) r I I I I I I t'Lrftlr?of r T=750 F STEET PAI}IT HOOKS T{ITH DRIED PAINT Table 1 Batch Burn-Off Oven Emissions operaung Capacity (BTU/hr) Natural Gas Heat Content (BTU/ft3) NATUTAI GAS Usage (ft3thr) Hours of Operation (hr/yD Natural Gas Usage (scflyr) 390 000 1 020 382 1 248 476 736 Pollutant Emission Factor ,rhr,r06 scfl Annual Gas Usage (scf/vr) Emissions (lbs/yr) Emission (tonslyr) Lead 0.0005 476 736 0.00024 0.00000012 NO,2.2 476736 1.05 0.00052 PMnn 7.6 476 736 3.€0.0018 Soz 0.6 476 736 0.29 0.00014 uoc 5.5 476 736 2.62 0.0013 co 84 476 736 40.05 0.02c 3507 Wayland Dr' J ACKSOfV OVEN Sl}P LY,'IVC, lndustrial Equipment. Parts . Service Jackson'Ml. 49202. Phone 517.784-9660. Fax 517.784-9670 www.iacksonoven.com February 27,2012 DeJason Meyerhoffer Paint facility AMG Autoliv North America 1000 West 3300 South Ogden, Utah, 84401 SIIBJECT:Jackson Oven Supply Proposal for Batch Burn-Off Oven Model4505 REFERENCE: PhoneConversation Dear Mr. Meyerhoffer: In accordance with our conversation please find below our specifications and pricing for a New Batch Burn-Off Oven. The design of our oven is environmental driven by incorporating hardware for a hi-low fire arrangement on both burners. The other strong point is the "One-Touch" user-friendly controls. There are no menus for the operator to select and no input required regardless of the size of load in the oven See attached sketch for overall exhaust stack height, additional exhaust stack is available. FURNACE INCLUDES Two (2) 60" long sections of insulated chimney, one (i) roof flashing, one (1) weather collar, one (1) free flow rain cap, carl and exterior cart tracks. OVEN SPBCIFICATIONS: Dimensions width lleisht Depth Nom nal Interior Inside 60,75"72" Nominal Exterior Footprint 72"l23u 84', Nominal Cart Area 48"63" (above cart)60" Electrical 1201U60 Natural Gas 390,000 BTU/Hr. 15" WC Pressure Water J som @ 40 PSI Min. & 100 PSI Max. NOTE: Oven specifications are conceptual and may vary after engineering has completed the final design. PROCBSS DBSCRIPTION The Batch Burn-Off Oven is designed to remove surface coatings of cured hydrocarbon materials such as paint, grease, oil, varnish etc. from hooks, racks, fixtures and pafts. Removal of a material is accomplished by heating the materials to be stripped to 800oF. The material is reduced to a fine, light ash and fumes. The fumes produced are vented through an afterburner chamber which raises the fume temperatures to 1500 oF and higher for a minimum of % second. The resultant effluent discharged to atmosphere consists of water vapor (H2O) and carbon dioxide (COr). Ash reduction remains inside the oven and consists primarily of inorganic pigments. Ash is removed from the oven and disposed of in accordance with local codes. NOTE: Halogen materials are excluded and cannot be thermally destroyed. The basic oven consists of a steel enclosure with insulated interiorwalls and roof and arefractory floor. A refractory plenum is provided to distribute heat evenly throughout the oven. Primary burner and controls are mounted on the rear wall of the unit. Jack mount afterbumer is included. PROCESS CONTROL After properly loading the oven the operator pushes the start button and the oven does the rest. To eliminate the possibility of smoke to the outside the afterburner rises in temperature first with the oven butner off. When the afterburner achieves temperature the oven burner proves pilot and initiates flame. Throughout the cycle the oven automatically monitors the rate of temperature rise. When an unacceptable rate of temperature rise is detected water misting system is activated. The water mist turns to steam, absorbs oxygen and slows the rate of temperature rise. This happens automatically with no operator input. There are no menus for the operator to select and no input required regardless of the size of load in the oven. The cycle time automatically adjusts relative to the amount of combustible material in the oven. When smoke and fumes diminish and temperatures return to normal the oven automatically shuts off and sounds alarm. If the afterburner fails for any reason, the water sprays activates to cool the load to prevent smoke from going up the stack. The optional cool down circuit automatically shuts off when the furnace is cool. STANDARD FEATURES 4- Laye r Wal I P rote cti o n Corrosion-resistant barier 1/8"thick is applied to furnace walls prior to installing insulation, adding years to the useful life of the fumace. The moisture barrier also makes the oven enclosure air tight promoting an inert like atmosphere during the burn process. a a a a 1" layer rnd rz tayer rrd rJ layer 4'l'layer Anti-moisture coating 1/8" thick hi-temperature rubber like sheetinq 4" thick B lb density block insulation Expanded metal JACKSON OI,'EN SUPPLY, INC. IndLrstrial Ovens l'alts Service CONSTRUCTION The outside walls will be made from 14 gauge hot roll steel, properly reinforced and with described insulation material pressed onto weld studs and retained with hearry expanded metal panels and 7Yr" x 7t/2" retainer clips. WALL INSULATION & FLOOR lined duty The oven will be insulated with 1200"F rated mineral fiber blanket 4" thick on the sidewalls and roof. The floor of the oven will be a 2300"F poured castable refractory, providing a hard durable surface for cleaning and service. DOORS Heary duty doors constructed with 4" structural steel channel insulated and furnished with cam lock door hardware top and bottom. The cam lock arrangement is essential for sealing the doors airtight during the heating cycle. Doors include high temperature gaskets around door perimeter and at closure point. PRESSURE RELIEF All ovens are required by NFPA 86 to have pressure relief provisions. This allows excess pressure on the inside of the oven to equalize with outside pressures without danger to equipment, operators or facilities. Oven includes hinged pressllre relief panels in the roof of the oven that allows adequate pressure relief by swinging open and then closing immediately by gravity. CONTROL SYSTEM The standard system includes state-of-the-art microbased controls used to control temperature, water misting system and cycle time. A dual-element temperature-sensing unit, placed in both the oven chamber and exhaust stack, senses temperature and will provide a digital read-out on the corresponding instrument mounted in the control panel door. CONTROL PANEL Oven includes NEMA-12 rated control panel, complete with door hardware. Mounted inside the cabinet on a removable panel insert will be a 20-amp circuit breaker, control relays, interlocks, timers and teminal strips. Mounted on the control panel door will be pushbr:ttons, indicating lights, oven temperature controller and afterburner temperature c.ontroller. The control panel will be factory pre-wired prior to shipment. JACKSON O''EN SUPPLI', ]NC lndLrstrial Ovens Parts S!-rvice BURNER Oven is equipped with gas burners featuring direct main flame spark ignition and solid state electronic flame detection. The self-contained electronic system produces instantaneous spark ignition. Continuous monitoring by our solid state system verifies flame or the burner automatically locks out. The ignition trial period is a positive and meaningful safety feature. With the direct spark model, we have practically eliminated the problem of pilot outage. Other standard features is the quiet permanently lubricated motor-driven high output blower, with an automatic self-cooling system that inhibits damage from heat back-up. The burner exclusive design features modular flame safeguard components and associated wiring outside the blast tube and blower housing, away from the heat, providing for a longer life, ease of service, and reduced maintenance costs. GAS PRESSURE AND FLOW Gas pressure to the oven should be regulated to 15" W.C. INSURANCE JOS will submit necessary drawings to Purchaser's insurance approval source upon request. Should Purchaser's insurance underwriters, local codes or plant specifications require additional safety equipment, it can be provided for an additional expense. EPA PERMIT ASSISTANCE JOS will supply all pertinent equipment information and exhaust stack data for the air quality permit. PAINTING After completion of construction, the equipment will be thoroughly cleaned of oil, dirt and dust. One (1) coat of prime paint and one (1) coat of finish paint shall be applied prior to shipment. Standard color is OSHA safety blue, unless otherwise specified. OSHA color-coding will be used where applicable. JACKSON OVEN SUPPLY, INC. Industrial Ovens Parts SL-rvice INSTALLATION SERVTCE (OPTIONAL) Jackson Oven Supply will provide installation service for the equipment described in this proposal. The following is an outline of the work required for installing a Batch Burn-Off Oven with non-union labor. CONTRACTOR The installation contractor shall be Jackson Oven Supply (hereinafter named "Jackson Oven") his authorized subcontractor and shall solely be responsible for installing this system accordance with these specifications. ACCESS Prior to the commencement of work, Purchaser shall provide a clear level, solid site for the equipment, and remove all existing pipe lines, foundations and other obstructions, which may be floor level or overhead, which would interfere with the construction, installation or operation of the equipment. FACILITIES Purchaser is to provide an enclosed building of adequate size equipment will be installed. Free access to all areas including work is to be performed must be maintained at all times. Purchaser will provide parking areas for the use of Jackson Oven employees. PERMITS with finished floor into which adequate door openings where or Jackson Oven sub-contracted Purchaser is responsible of this equipment. UNLOADING for all local and state permits required for the installation and operation Jackson Oven will supervise the recerving, inspection and unloading equipment at the job site. Any damage or shortage claims must be filed with the Carrier immediately by the purchaser. RIGGING AND ERECTION JOS will unload, move into position and set all equipment as indicated on the drawings. All power rigging equipment will be furnished by Purchaser at the job site. Any shifting or relocating of equipment because of unforeseen circumstances shall be approved by Purchaser and Jackson Oven prior to execution of such work. Changes or modifications may require a cost adjustment to the contract price. JACKSON O''EN SUPPLY, INC Industrial C)vcns Paris - Servicc ELECTRICAL Jackson Oven will reconnect all pre-wired components disconnected for shipping. Electrical feed from Purchaser's bus duct fused disconnect to the control panel is not included in this proposal. The work described above can be provided by Jackson Oven as a field order item at time of installation. PIPING Jackson Oven will reconnect all pre-piped gas, air and water piping disconnected for shipping. Gas feed piping with one (1) manual shut-off valve from Purchaser's gas headerto the gas train inlet is not included in this proposal. The main gas pressure regulator (if required) and vents are not included in this proposal. Water feed piping with one (1) manual shut-off valve from Purchaser's water source to the equipment connection point is not included in this proposal. The work described above can be provided by Jackson Oven as a field order item at time of installation. STACKS AND VENTS Jackson Oven will supply and assembly one (1) exhaust stack system consisting of two (2) sections of straight exhaust stack with roof flashing, weather collar and weather cap through the roof opening . Roof anchors for guy wires (if applicable) by Purchaser. Jackson Oven will supply and assembly gas train vents through the roof opening. Roof opening framing, anchors and sealing for exhaust stack and vents are not included in this proposal. This work shall be the sole responsibility of Purchaser. MISCELLANEOUS Jackson Oven Supply shall be required to supply all miscellaneous installation materials such as anchor bolts, brackets, nuts, bolts and necessary steel for installation unless otherwise noted. PURCHASER'S MISCELLANEOUS RESPONSIBILITIES o Provide a 50amp 240 volt single phase for installers . Provide a dumpster for the disposal of waste material . Prior to equipment arrival; receive, off-load and store misc. material for installation . Miscellaneous freight/shipping charges of material JACKSO\| OYE!'[ SUPPLY, INC. Industrial C)vens' Parts ' Scrvice FINAL PREPARATION Upon completion of the installation work described in this proposal, Jackson Oven will notifu purchaser of readiness for Start-Up. Standby labor and tools required for final checkout of the system will be available at that time. If Purchaser elects to delay the Start-Up due to circumstances beyond the control of Jackson Oven, then standby labor and tools required for checkout will become the responsibility of Purchaser when Start-Up begins. sTART-rrP (OPTTONAL) Jackson Oven will provide one (1) day of Start-Up service after the equipment is completely installed. This period is to be used for travel to and from the job site, making final adjustments, checking electrical circuits and training operating and maintenance personnel. Any time over this period will be on a per diem basis. The per diem rate is $750.00 per day, plus expenses. It is recommended that Purchaser retain the services of Jackson Oven supervision during first production run. The daily rate quoted is for ten (10) hour weekdays (Monday thru Friday). Daily overtime and Saturdays will be invoiced at lYztimes the normal rate, and Sundays at 2 times the normal rate. JACKSON OVE]V SUPPLY, INC industrial Ovens 'Parts ' Scrvice PRICE SCHEDULE One ( 1) Model 4505 Batch Burn-Off Oven as described within this proposa1.................. $30,785.00 OPTIONS Hi-Fire Afterburner.................. ... INCLUDED Automatic Controls .. INCLUDED Modulating gas on both burners (estimated 40%o fuel savings). .. $2,550.00 Installation as described within this proposal.................. OPTIONAL Start-up & Training as described within this proposal .................. OPTIONAL Delivery CONTACT JOS Stainless Steel Oven Liner 20 gauge CONTACT JOS Exhaust Stack 60" long ........... Barometric Damper Temperature Recorder (single pen) ............ Electric Door Lock Battery Back-Up $460.00 $660.00 $ 1,075.00 $ 1,100.00 s7s0.00 $47s.00 $ 180.00 Hinged Tracks Additional Length Process Complete Indicating light............ TERMS 509'o with purchase order 50% before shipment SHIPMENT Shipment of equipment will be made twelve (12) weeks after first 50% is received. All orders are subject to credit approval prior to acceptance. All prices are quoted F.O.B. Jackson, MI (unless otherwise noted) and are to be payable in U.S. funds. Prices are firm for thirty (30) days after date of this proposal. PUCHASER RESPONSIBILITIES r Permits, licenses and approvals r lnstallation . Operate and maintain firrnace within compliance of Owner's manual We appreciate this oppofiunity to work with Autoliv and hope that we may be of service. I will contact you to discuss this proposal and your requirements. In the meantime, if you have any questions, please contact us. Respectfully, Rob Barringer Rob Barringer JACKSON OVEN SUPPLI" TNC. Industrial C)vens Parts Service FREE FLOW RAIN CAP WEATHER COLLAR LINKNOWN BAROMETRIC DAMPER REQUIRED IF EXHAUST STACK EXCEEDS 25' ABOVE FLOOR BURN-OFF OVEN ONTROL PA ELEVATION VIEW JACKSON O'IEN SUPPLY, INC Industrial Ovens ' Parts . Service AFTERBURNER PLAN VIEW JACKSON AVEN SUPPLY, TNC. Industrial Ovens'Parts ' Service "3#;:ili1b,1",,,, Amanda Smith Executive Direoor DTVISION OF AIR QUALITY Bryce C. Bird Diretutr I 95 North 1950 West . Salt lake City. UT Mailing Address: P.O. Box 144820 . Salt lake City. UT 84114-4820 Telephone (801 ) 536-4000 . Fax (801) 5364099 . T.D.D. (801) 536-4414 wwl.deq.uIttlt. gov hinted on 100%, recycled paper DAQE-GN141670006-11 December 16. 201I Daren Koldewyn Autoliv ASP, Incorporated 3350 Airport Road Ogden. UT 84405 Dear Mr. Koldewyn: RE: Notification of Company Name and Ownership Change for Modification to Approval Order DAQE-ANO141670005-l I, dated August 9.201I - Autoliv ASP. Incorporated Project Number: N 14167-0006 The Utah Division of Air Quality (DAQ) has received your request on December l, 201 I for a name and ownership change for the holder of the above-referenced Approval Order (AO). According to your request, we have noted in our records that the holder and party responsible for complying with the terms and conditions contained in the above-referenced AO has been changed to 'Autoliv ASP, lncorporated'. This change took effect on the date of this letter. Autoliv ASP, Incorporated currently has three AOs with DAQ (DAQE-AN0141670005-l l, dated August 9.201I. for the plastic laminate plant; AO DAQE-AN10025001l-l l. dated November 29,201I, for the automotive airbag manufacturing plant; and AO DAQE-AN1602005-03. dated May 20,2003, for the module manufacturing plant) that are now considered part of one source. A modification of either of these AOs will need to consider a summation of the emissions from all of these AOs. The charge for the review done in making this change is a flat fee plus a filing fee as authorized by the Utah Legislature. You will receive an invoice for these charges shortly. If you have any questions, please contact Ms. Heather Mickelson, who may be reached at (801) 536-4014. Sincerely, Bryce C. Bird, Executive Secretary Utah Air Quality Board State of Utah GARY R. HERBERT Govenutr GREG BELL Lieuternnt Crn'enutr f'oni r 16 -r r\x:, i, ,.1 l't -:.l L Li.,J.n u;u;* [] "ffiNew Source Review Section BCB:HM:sa A A A A A NEWSPAPER NOTICE (NN)Oftlce Tech signs cover letter ol'Nervspaper Notice INTENTTO APPROVE (ITA)Covcr lcttcr and ITA signed by associated Section Manl,eer Elcctronic C'opy of ITA sent to Ron Reece APPROVAL ORDER (AO)C'opy ol-purple slreet and cover letter of AO to Teri Wciss EXPERIMENTAL AO Copy oi purplc slreet and cover letter of AO to Te ri Wciss CORRESPONDEN(]E Signatory varies s0il. RF.MF.r)tA'ftoN If associated lee- send copy of purple sheet und lcttcr to Teri Weiss SALES TAX EXEMITION (TAX) SMALL SoI IR(]E EXENI I}TION Ciopy ol purple slrcct and lctter to 'l'eri Weiss EN,I ISS IoNS I]ANKING LETTER (lopy ol lcttcr to ('unrron Hzlrry NAME C'l-lAN(iE Lctter Copy ol purplc shcct ancl lctter to Teri Weiss :Hfii?x,$i,?ilie,"l +: REGARDING: HE TTACMD DOCUMENT IS CATEGORIZED S REVIEWED BY AND DOCIJMENT SIGN OFF DATES: N141670006-l l Autoliv ASP,Inc.: Plastic L]ut" fturt Modification to Approval Order (DAQE-AN0141610004- l0) (PLEASE CHOOSE ONE COPIE,S TO BE SENT TO THE FOLLOWINCi ARTIES: (PLEASE CFIECK AS THEY APPL Manila File Folder (*'orking tile)(irccns Folder Healtli Departrrcnt (see letter tbr rvhich)EPA - Mike C)wens Compliance (associated Section Managcr)Finance - Teri Weiss , Narne Change Lettcrs: Deborah McMr,rrtrie Susan Wcisenbcrg Dave Bcatty Brett Wilding. Utah State Tax Comnrrssron. Tcchnical Rcsearch Unil Offiets Uscd l Copy of docurrcnt(s) to Carnron Harry Enter tlnal Name Change Letters in /enginecriaoname Copl'To:Enter in /engineer/aocond & in AO Log: (AOs. AO not ncedcd. Replaccment in Kind) NEWSPAPER NOTICE _ COPIES TO: Cities. Countres. Cov. Agencies. & etc./& a copy of Public Ol'flcial letter $'ith self-addressed cnvelope E-Mail To: dvd.kvdG)juno.com. Jodie Srvanson. Lori Walkcr. Debbie Oberndorfer. Bill Sinclair. Beverly Rasrnussen & Jen Burge. Donna Spangler. Ron Reccc. and Kclly Beck E-Mail copv & Pax to Newspaper Aeencies PSD PROJECTS: Copy thc NOI. Enginecring Review. l1'A. NOTICE & AO Send to: Mike Orvens. EPA Don Banks. Bureau of Land Management Clrris [.lockct. L].S Forcst Scrvice Chris Shaver. Nation:rl Park Service TI-fl-E V: Chcck lv/ NSR Engineer fbr rvhich doclrment(s) to bc copied. Completeness determination Peer review ofproject Section Manager sign off December 8. 201 December 8. 201 Heather Mickelson Tim DeJulis Timothy Andrus 12011) Heather From: To: cc: Date: Subject: Attachments: Heather, Thank you for talking with me this aftemoon about the A&K Paintlng name change to Autoliv for Approval Order DAQE-AN0141670005-11. I appreciate being able to send the name change form direcdy to you. I have attached two forms to thls email: - the first form is just signed by Autoliv. - the second form is signed by Autoliv and A&K Paintlng but is not very legible. Please use me as your point of contact. I will be able to answer any questions you may have with this name change. Sincerely, Daren Koldewyn HS&E Environmental Engineer Autoliv Americas 801-620-8286 daren. koldewyn@autoliv.com (See attached file: Change Form signed by A&K Painting_Autoliv.pdf)(See attached file: Change Form signed by Autoliv.pdf) Consider the environment before printlng this message. To read Autoliy's lnformation and Confidentiality Notice, follow this link: http :/Ar'rur. autoliv. corn/d isdai mer. htrnl <Daren. Koldewyn@autoliv.com> <Hm ickelson@utah. gov> <Mark.Bunker@autoliv.com>, <Dj.Meyerhoffer@autoliv.mm> '12J1120113:49 PM Autoliv Approval Order Name Change Notification Change Form signed by A&K Painting_Autoliv.pdf; Change Form signed by Autol iv.pdf UTAII il[Lral]r:'i itf Of-rNVlllwi, t,tEh: I /rL eUALlTy DII I - Z0t1 DIVISION OF AIR QUALITY 5tt- AAJoluttte 3?\+ hx\L ='\7-11 Utah Division of Air Quality Nerv source Revierv Section Own ersh ip C han gelCom pany Name Chan ge Notification The following inforrnation is necessary before the Division will be able to make lhe nanre change you have requested. Please return this document within l0 days ofreceipt. Please be aware that all records associaled with this company will change to the nerv name unless you specifically indicate otherwise. The fee assessed fcrr rnaking these changes is authorized by the legislature forthe actual time spent by the reviewer. Note: lf this nanre change is the result of a sale or acquisition, both the buver & the seller must sien this document as proofofthe closure ofthe agreement. Reason for O*'nership ChangeiCompany Name Change A', K. F 1u,'Y 1'r Par!'nt C(,ntpan] 'lhe undr'rsigned, as an authorized representative oithe companl. acknorvledges that thc alrovc inlbrnralion is correct. and requests that the conrpan!' narne change be made in all Air Qualiry records. Prcvious Orvner sisnatfi; Nanre (plcasc print) Contact Namc (Please prinr) C, ,l-_i!, ) :^- j _,:--':tL Phonc Nurnber J.,.' !.:i,.t ;,t -li'ffi_- \t('ll(l\ f,rnl; \.rrrr.( hrr:-qcdL,t Rur trcrl i. ll. l I Title Return this fornr to: State ol Utah Division of r\ir Oualitv ,'\ttrr: NSR Orvnership,/i.ianre Chanse Notillcltion I9-i Norrh l9-i0 \\'est PO Box lJl8l0 Salr t-oke ( itr. Ulah s-l l l4-.1820 .Au-r4'tIu /\t. I-' /v( '\',-,(- i\r::r';'tr \.'t> /l,rL,., {- -I t4LlCt-, \. L' ::lr Y. f ? f l"'l Lii,r,") r- .1;'1 -,r.,'"\ I Ll'!'-, Ll t' r Approval Order # (DAQE-ANxr:rx,\xrrxr-xr)Site Narne & Address (for each .{pproval Order) l,liiit_ i\j,,!iL-,j[ [ t'> - il L-L't r:l' i '. "t (I ll i. /'v i -l i' i,irr ^, L' I i t' i-' l prcscnt orvfr-r ,'j r ,. L , L ,.1 ... i. / ,v. Utah Divisiorr of Air Qualiry Ncrv source Revierv Section Orvnership Chnnge./Contltruy Natne (lhangrt Notilication The follorviug intbnnation is neces,uary bqltrre the Divisicrn rvill be able lo rtrakc lhc ttattre change you have reqrlesled. Please retunl this documcnl rvithin 30 days ofreceipt. Phtsc bc au.are thai nl! records associated rvith this c()nlp{lny rvill change to the new tralite unless yott sp('cilicrrll}' indicate orherwise. The fee assesselt hr making rhcsc changes is authorized by tlre legislalure lorlhe irclull lintc spenl lry the revierver. Note; ll'rhis nanrc clrange is rhe rcsult ofa sale or acquisition, both the lruver .t {he seller orrrsl sign tltis tlocrlntent as proofof thc closurc ofthe aBrcsrreill. Recson for Or';nership ChangeiConrpaoy Nante Charge (lrrrcnt Protiorrs ir r-'-i 6i I1.,A i., i-' ,r ...it' P,rrctrt LbrnAin!': C'rrrrcnl -i- !\ ..-, 1> t,? t-l I t l' 1., (i;')t'i,-,1, I itk l,).i,:a .., l'{' rL ;ri- r'" i'\ eonGa-NuurEiPt-"fi;;; i-i!r i- ) ir; !.i'.-;.-"i.-! r ,t Plturrc Nrrrrrbcr i ,, ,i,i ..r.,I :: I l(i,' :.. :t:,:-..i,. j.' []:nriii"****"- (pleasc print) t r1\ng.a llelurn lhis forrrr to: Statc ol Utah I)ilisiorr of Air Qualitr- ,'\urr: NSll - Olnursh ip.lranrc (. hln g c Not i ficrt iort l9-i North l9i0 West l)0 Box l,l.lS2Q Sirlr l.ale f-'ir\', Lltah 8"1 I l.l--l$?0 Padgnl Crinrpi[y; Prcvious i" 'i', ?\ t II. ll i::!\ { rtpproval Ordcr ll (trrtQB-AN x rr.t rxr sxx-xr)Site Nnrue & Address (for trch r\pprrrlnl Order) !)i'ir.i-i- liril,tC l l,' i ti"', lf i1 l-'i" r-'t I /.'i,irr,'; l'i- "jilti f i 'Ihe rurdersigtred,;u an authorized representati\ie ol'lhe c0upany, ackrrorvlct'lgcs thtt thc alxivc intbrntirlion is corrcct, and requests that lhc conrpan) noruc elrrurgc bc nrirdc in rrll ,\ir ()urllit-v rutolJs. \''\(,i' , l. iJ u .. [",, ,- rtfr ir-flt-ptdiG[-prinu !)re:ent ()t,tilr ,'1. .' , r , r i. ': '', i.' i ',.r' 9[( t tt]r-'].,arn;, llurt C[or;u- rlt,: I{rui: trl :i t 6.' i I