DAQ-2024-008062

1/23/24, 11:24 AM State of Utah Mail - VOC RACT Analysis – Atlas Molded Products – Murray, UT -- DAQE-AN0104200008-07
https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1785748291657223493&simpl=msg-f:1785748291657223…1/2
Ana Williams <[e-mail]>
VOC RACT Analysis – Atlas Molded Products – Murray, UT -- DAQE-AN0104200008-07
David Sykes <[e-mail]>Tue, Dec 19, 2023 at 2:44 PM
To: "[e-mail]" <[e-mail]>
Cc: Josh Livingston <[e-mail]>, Jes Lundberg <[e-mail]>, David Sykes
<[e-mail]>
Dear Ms. Williams,

Atlas Molded Products, a Division of Atlas Roofing Corporation, is submitting for your review the attached Reasonably Available Control
Technology (RACT) analysis for our facility located at 111 W Fireclay Avenue in Murray, Utah.

The Atlas Molded Products, Murray, Utah, facility has been identified as having the potential to become a major stationary source
located in Utah’s Wasatch Front Ozone Nonattainment Area (NAA). The Northern Wasatch Front ozone NAA is expected to be
reclassified to “serious” nonattainment of ozone National Ambient Air Quality Standards (NAAQS) in February 2025. A serious
nonattainment classification will trigger new requirements for major stationary source. Specifically, the reclassification will lower the
emissions threshold for Title V Major Source status and for Nitrogen Oxides (NOX) and Volatile Organic Compound (VOC) Reasonably
Available Control Technology (RACT) Analysis requirements to 50 tons per year.

Atlas Molded Products will not be a major source of NOX emissions even after the expected reclassification. However, the facility is
expected to become a major source of VOC emissions. Therefore, the purpose of the attached document is to present a RACT analysis
for VOC emitting sources at the facility.

If you should have any questions during your review of this information, please contact me at your convenience.

Please reply to acknowledge receipt of the RACT Analysis.

Sincerely,

David C. Sykes, P.E.
Principal Engineer

Access Environmental Solutions, Inc.
1100 Augusta Drive, Suite 704
Oxford, MS 38655
Phone [phone], ext 101
Direct [phone]
Fax [phone]

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1/23/24, 11:24 AM State of Utah Mail - VOC RACT Analysis – Atlas Molded Products – Murray, UT -- DAQE-AN0104200008-07
https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1785748291657223493&simpl=msg-f:1785748291657223…2/2
AMP Murray UT RACT Analysis Report.pdf
3786K
Reasonably Available Control
Technology (RACT) Analysis
Atlas Molded Products
Murray, Utah
December 18, 2023
1100 Augusta Drive, Unit 704
Oxford, Mississippi 38655
Phone [phone]
Fax [phone]
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page i
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................... 1
1.1 Background ...................................................................................................................... 1
1.2 UDEQ RACT Submittal Requirements .............................................................................. 1
2.0 VOC EMITTING UNITS AT THE FACILITY ............................................................................... 3
2.1 Emission Unit Descriptions .............................................................................................. 3
3.0 EMISSIONS SUMMARY ........................................................................................................ 5
4.0 PROPOSED VOC RACT .......................................................................................................... 6
4.1 Review of RACT/BACT/LAER Clearinghouse .................................................................... 6
4.2 EPS (Pre-Expander / Bead Aging / Block Mold) Process .................................................. 8
4.2.1 Control Technologies ............................................................................................... 8
4.2.2 Capture and Control Considerations ....................................................................... 8
4.3 Loose-Fill (Packaging) Process ............................................................................................... 8
4.3.1 Control Technologies ............................................................................................... 8
4.3.2 Capture and Control Scenario ................................................................................. 8
4.3.3 Technological Infeasibility ....................................................................................... 8
4.4 Recycled Foam Densification Process ................................................................................... 9
4.4.1 Control Technologies ............................................................................................... 9
4.4.2 Capture and Control Scenario ................................................................................. 9
4.4.3 Technological Infeasibility ....................................................................................... 9
5.0 PROPOSED RACT ................................................................................................................ 10
Attachment A: Boiler VOC Emissions Testing Results .................................................................. 11
Attachment B: Process Flow Diagram ........................................................................................... 30
Attachment C: RBLC Search Results .............................................................................................. 32
Attachment D: Emissions Calculations .......................................................................................... 39
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 1
1.0 INTRODUCTION
The Atlas Molded Products, Murray, Utah, facility has been identified as having the
potential to become a major stationary source located in Utah’s Wasatch Front Ozone
Nonattainment Area (NAA). The Northern Wasatch Front ozone NAA is expected to be
reclassified to “serious” nonattainment of ozone National Ambient Air Quality Standards
(NAAQS) in February 2025. A serious nonattainment classification will trigger new
requirements for major stationary source. Specifically, the reclassification will lower the
emissions threshold for Title V Major Source status and for Nitrogen Oxides (NOX) and
Volatile Organic Compound (VOC) Reasonably Available Control Technology (RACT)
Analysis requirements to 50 tons per year.
Atlas Molded Products will not be a major source of NOX emissions even after the
expected reclassification. However, the facility is expected to become a major source of
VOC emissions. Therefore, the purpose of this document is to present a RACT analysis
for VOC emitting sources at the facility.
1.1 Background
On August 3, 2018, EPA designated the Northern Wasatch Front as marginal
nonattainment for the 2015 eight-hour ozone standard. The Northern Wasatch Front NAA
includes all or part of Salt Lake, Davis, Weber, and Tooele counties.
The Northern Wasatch Front was required to attain the ozone standard by August 3, 2021,
for marginal classification. However, the Northern Wasatch Front NAA did not attain the
ozone standard by the attainment date and was reclassified to moderate status on
November 7, 2022. The Northern Wasatch Front NAA is now required to attain the ozone
standard by August 3, 2024, for moderate classification based on data from 2021, 2022,
and 2023. However, recent monitoring data indicates the Northern Wasatch Front NAA
will not attain the standard and will be reclassified to serious status in February of 2025.
This anticipated reclassification from moderate to serious status will trigger new control
strategy requirements for major sources in the Northern Wasatch Front NAA. Specifically,
the Ozone Implementation Rule in 83 FR 62998 requires the State Implementation Plan
(SIP) to include RACT requirements for all major stationary sources in nonattainment
areas classified as moderate or higher. The requirements for RACT in a serious ozone
nonattainment area are found in Clean Air Act (CAA) Section 182(c). A major stationary
source in a serious ozone nonattainment area is defined as any stationary source that
emits or has the potential to emit 50 tons per year or more of NOX or VOC. Atlas Molded
Products currently has the potential to emit greater than 50 tons per year.
1.2 UDEQ RACT Submittal Requirements
The Utah Department of Environmental Quality (UDEQ) DAQ is requesting RACT
analyses submittals from certain affected major sources located in ozone nonattainment
areas by January 2, 2024. A RACT analysis requires implementation of the lowest
emission limitation that an emission source is capable of meeting by the application of a
control technology that is reasonably available, considering technological and economic
feasibility. A RACT analysis must include the latest information when evaluating control
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 2
technologies. Control technologies evaluated for a RACT analysis can range from work
practices to add-on controls. As part of the RACT analysis, current control technologies
already in use for VOCs or NOx sources can be taken into consideration. To conduct a
RACT analysis, a top-down analysis is used to rank all control technologies.
The RACT analysis identifies each emission point listed, the control options evaluated for
each specified pollutant, the proposed RACT in the form of RACT emission limit(s) and/or
work practice(s), suggested monitoring and recordkeeping to demonstrate compliance
with the proposed RACT requirement(s), and schedule(s) for implementing RACT. The
RACT analysis also includes technical and economic supporting documentation for the
identified RACT.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 3
2.0 VOC EMITTING UNITS AT THE FACILITY
The following emission points are identified in the current Air Approval Oder DAQE-
AN0104200008-07:
Table 1: Permitted Emission Points
Emissions Source VOC
Source
Emissions
Controls in Place
Pre-Expander Yes Yes
Bead Aging Bags Yes Yes
Block Mold Yes Yes
Recycled Product Densifier Yes No
Two (2) Loose-Fill (Packaging) Expanders Yes No
Loose-Fill (Packaging) Aging Bags Yes No
Wire Cutters Yes No
2.1 Emission Unit Descriptions
The EPS process begins with pentane-impregnated polystyrene beads as the raw
material. These beads are heated with steam in a “pre-expander,” which softens the
plastic while causing the pentane gas to expand the bead. This causes the beads to
expand or “puff up.” Approximately 15-25 percent of the initial pentane content of the bead
can be emitted during the pre-expansion process. After pre-expansion, the beads are
pneumatically transferred to bead storage bag in the aging room, where they cool,
stabilize, and reach the desired density for molding.
The loose-fill operation consist of two expanders, one drum expander and one belt
expander, which apply heat and steam to expand the beads. After each pass through an
expander, the beads are pneumatically transferred to the loose-fill bead storage bags
located in the same room for up to 24 hours. This time in the bead storage bags allows for
bead stabilization. The beads pass through each expander twice a total of four passes.
Since the loose-fill expanders and loose-fill bead storage are located within the same
room, most of the pentane content is emitted within this room.
VOC emissions from bead pre-expansion, bead aging and storage, and block molding are
currently captured and controlled by combustion in a 12.5 MMBtu/hr natural gas-fired
boiler. Emissions testing has shown a 99.91 percent VOC destruction efficiency.
Table 2 summarizes the VOC emitting sources at the facility.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 4
Table 2: Emission Unit Characteristics
Emissions Source Capacity Raw Material Product Exhausts To
Pre-Expander 5,500 lb/hr Raw EPS Beads Expanded EPS
Beads
Boiler
Bead Aging Bags 3,000 lb/hr Expanded EPS Beads Expanded EPS
Beads
Boiler
Block Mold 4,000 lb/hr Expanded EPS Beads EPS Foam Blocks Boiler
Recycled Product Densifier Yes Scrap EPS Compressed Foam
Bricks
Plant Building
Two (2) Loose-Fill (Packaging)
Expanders
Yes Raw EPS Beads Expanded EPS
Beads
Plant Building
Loose-Fill (Packaging) Aging Bags Yes Expanded EPS Beads Expanded EPS
Beads
Plant Building
Wire Cutters Yes EPS Foam Dimensioned EPS
Foam
Plant Building
12.5 MMBtu/hr Boiler 12,500 CF/hr Natural Gas/Pentane Steam / Emission
Control
Stack
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 5
3.0 EMISSIONS SUMMARY
Potential VOC emissions are presented in Table 3 based on the facility-wide VOC limit of 64.6
tons per year. Actual emissions for the expander/aging/molding process are calculated based on
the calendar year 2022 bead usage, an assumed 15 percent VOC retained in the finished
products, and a combined capture and destruction efficiency of 79.37 percent (79.44% CE x
99.91% DE) from the most recent stack test in 2018.
Recycled scrap densification emissions are based on testing conducted at Atlas Molded Products’
Byron Center, Michigan, facility. Loose-fill (packaging) expansion emissions are based on 15
percent retained in the finished product with no emissions controls.
Table 3: Potential and Actual Emissions
Emissions Source
VOC Emissions
Potential
(tons/year)
Actual
(tons/year)
Pre-Expander 58.361 28.06
Bead Aging Bags
Block Mold
Recycled Product Densifier 2.051 0.99
Two (2) Loose-Fill (Packaging) Expanders 4.181 2.01
Loose-Fill (Packaging) Aging Bags
Wire Cutters <0.1 <0.1
12.5 MMBtu/hr Boiler 0.30 0.22
1 The facility-wide permit limit for VOC emissions from non-combustion sources is 64.6 tons/year.
The individual sources do not have limits.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 6
4.0 PROPOSED VOC RACT
EPA defines RACT as “the lowest emission limitation that a particular source is capable of meeting
by the particular source is capable of meeting by the application of control technology that is
application of control technology that is reasonably available considering technological
reasonably available considering technological and economic feasibility and economic feasibility”
(44 FR 53762; September 17, 1979). It may require technology that has been applied to similar,
but not necessarily identical, source categories. It is not intended that extensive research and
development be conducted before a given control technology can be applied to the source. This
does not preclude requiring a short-term evaluation program to permit the application of a given
technology to a particular type of source. A discussion of the available emission controls, previous
RACT determinations, and the proposed RACT control strategy for the facility follows.
4.1 Review of RACT/BACT/LAER Clearinghouse
In order to identify available control technologies, a search was conducted of the EPA
RACT/BACT/LAER clearinghouse (RBLC) database VOC emission controls that would be
applicable to EPS foam operations. The search identified multiple facilities that manufacture EPS
foam. The results of the search can be found in Table 4.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 7
Table 4: EPA RACT/BACT/LAER Clearinghouse (RBLC) Database Search Results
Company Name RBLC ID Permit Date Process Description RACT Determination
Plymouth Foam *WI-0320 07/21/2022 Polystyrene foam products
manufacturing
Regenerative Thermal
Oxidizer (RTO) controlling
pre-expanders, aging bins,
and molds
Cellofoam North America,
Inc.
IN-0284 04/19/2018 Expanded polystyrene
products (EPS)
Production limitations
equaling 150 TPY VOC
Genpak, LLC IN-0266 05/08/2017 One (1) polystyrene scrap
repelletizer
RTO at 98% destruction
efficiency
Polystyrene Foam
Container
FL-0360 12/20/2016 Polystyrene container
manufacturing facility
Boiler at 95% destruction
efficiency
Carpenter Company IN-0238 12/28/2015 Expanded polystyrene
(EPS) foam manufacturing
line
RTO at 98% destruction
efficiency
Genpak, LLC IN-0219 07/06/2015 Three (3) polystyrene foam
extrusion operations -
butane only blowing agent
RTO at 98% destruction
efficiency
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 8
4.2 EPS (Pre-Expander / Bead Aging / Block Mold) Process
4.2.1 Control Technologies
VOC emissions from each source identified in Table 4 were controlled by combustion—either a
thermal oxidizer or a boiler. Atlas Molded Products currently utilizes a boiler with a destruction
efficiency of 99.91 percent to control VOC emissions from the pre-expander, bead aging, and
block mold and proposes the boiler as RACT for this process.
4.2.2 Capture and Control Considerations
The capture efficiency for emissions from the pre-expander, bead aging, and block mold has been
determined through testing to be 79.44 percent. The pre-expander emissions are routed to the
total enclosure that houses the bead aging bags and can be considered to have near 100%
capture. The block mold exhaust is routed to the enclosure as well but does have some fugitive
emissions that cannot be captured, as the mold cannot be totally enclosed for safety reasons. A
primary concern while designing total enclosures for EPS processes is the fire hazard. All aspects
of the EPS pentane collection system must be designed with adequate ventilation in work areas,
to protect workers from exposure to pentane, and air movement throughout the enclosure, to
prevent the buildup of pentane to levels that are flammable or explosive. The lower explosive level
of pentane is 1.5%. The National Fire Protection Association (NFPA) guidelines limit
concentrations to below 25% of the LEL (NFPA 2015).
4.3 Loose-Fill (Packaging) Process
4.3.1 Control Technologies
VOC emissions from each source identified in Table 4 were controlled by combustion—either a
thermal oxidizer or a boiler. Combustion is the assumed technology of choice for controlling
emissions from the loose-fill (packaging) process.
4.3.2 Capture and Control Scenario
The loose-fill operation is contained in a large room approximately 75 feet x 50 feet x 25 feet tall
and contains both the expanders and the storage silos. The loose-fill expanders are open vessels
with large openings to allow for the transport of product. The beads are fed into the expanders by
raising the storage silo bags above and conveying the material into the expanders. The storage
silos are large bags approximately 16 feet x 20 feet x 15 feet. The most effective solution to
capture pentane emissions from the loose-fill expander process would be to enclose the room
and turn it into a PTE. Since the enclosure is so large, the exhaust does not need to go through
a steam condenser and a dehumidifier. Due to the 10 room changes per hour minimum to support
worker comfort required by the EPA Cost Control Manual (EPA 2002), the airflow from the loose-
fill PTE must be at least 16,000 cfm. As the 12.5 MMBtu/hr boiler can only handle an airflow of
about 2,400 cfm, the airflow from the loose-fill room is too large to be routed through the boiler.
Therefore, the boiler is an infeasible pentane control device.
4.3.3 Technological Infeasibility
As presented in Section 4.3.2, due to the large space that houses the loose-fill equipment and
storage silos, the airflow from the loose-fill PTE will be too large to be handled by the 12.5
MMBtu/hr boiler proposed to be installed. Since the facility does not need steam from a larger
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 9
boiler, using the proposed boiler as a control device for the loose-fill expanders is considered
technologically infeasible.
4.4 Recycled Foam Densification Process
4.4.1 Control Technologies
VOC emissions from each source identified in Table 4 were controlled by combustion—either a
thermal oxidizer or a boiler. Combustion is the assumed technology of choice for controlling
emissions from the recycled foam densification process.
4.4.2 Capture and Control Scenario
The recycled foam densification operation is contained in a large room approximately 70 feet x
60 feet x 25 feet tall and contains both the expanders and the storage silos. The recycled foam
densification equipment consists of grinders and presses where the recycle is densified with large
openings to allow for the transport of product. The most effective solution to capture pentane
emissions from the recycled foam densification expander process would be to enclose the room
and turn it into a PTE. Due to the 10 room changes per hour minimum to support worker comfort
required by the EPA Cost Control Manual (EPA 2002), the airflow from the recycled foam
densification PTE must be at least 18,750 cfm. As the 12.5 MMBtu/hr boiler can only handle an
airflow of about 2,400 cfm, the airflow from the recycled foam densification room is too large to
be routed through the boiler. Therefore, the boiler is an infeasible pentane control device.
4.4.3 Technological Infeasibility
As presented in Section 4.4.2, due to the large space that houses the recycled foam densification
equipment and storage silos, the airflow from the recycled foam densification PTE will be too large
to be handled by the 12.5 MMBtu/hr boiler proposed to be installed. Since the facility does not
need the steam from a larger boiler, using the proposed boiler as a control device for the recycled
foam densification expanders is considered technologically infeasible.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 10
5.0 PROPOSED RACT
Atlas Molded Products proposes the following RACT options for the VOC emitting sources at the
facility:
EPS Process (Pre-Expander / Bead Aging / Block Molding)
 VOC – Existing natural gas-fired boiler operating at 99.91 percent destruction efficiency
Loose-Fill Expander
 VOC – No Controls
Recycled Foam Densification
 VOC – No Controls
The proposed RACT techniques are already in place and operating. They have been tested. Atlas
Molded Products propose to continue the permit required recordkeeping of EPS bead usage and
loose-fill and densified recycled foam production.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 11
ATTACHMENT A: BOILER VOC EMISSIONS TESTING RESULTS

EMISSIONS TEST REPORT

Pentane Emission Control System
Capture and Destruction Efficiency Testing

Prepared for
ACH Foam Technologies, Inc.
Murray, Utah

Performed on May 30 – June 1, 2018

Project # 18002
Soderberg
Polytechnic
Company, LLC
306 W. 7th St. #401
Kansas City, MO 64105
[phone]
[phone] (fax)
18002 ii

PREFACE
This report contains the results of testing that was performed at the ACH Foam Technologies
facility in Murray, Utah, on May 30 – June 1, 2018. The data presented are believed to be
accurate and complete. Questions concerning this report may be directed to Mr. Daniel
Soderberg, Project Manager.
This report was authored by Mr. Soderberg.

Certified By:

Daniel R. Soderberg
Project Manager
Soderberg Polytechnic Company, LLC

July 16, 2018

18002 iii

TABLE OF CONTENTS
SECTION 1 - INTRODUCTION .................................................................................................. 1
1.1 TEST SITE INFORMATION .................................................................................................................... 1
1.2 DESCRIPTION OF FACILITY.................................................................................................................. 1
1.3 PURPOSE OF TESTING .......................................................................................................................... 1
1.4 FACILITY CONTACT ................................................................................................................................ 1
1.5 TESTING COMPANY CONTACT ......................................................................................................... 1
1.6 SUMMARY OF TESTING PERFORMED ............................................................................................. 1
1.7 TESTING PERSONNEL ............................................................................................................................ 2
1.8 REGULATORY REPRESENTATIVES ..................................................................................................... 2
SECTION 2 - PROCESS DESCRIPTION ..................................................................................... 3
2.1 EPS PRODUCTION PROCESS .............................................................................................................. 3
2.2 EQUPIMPENT DESCRIPTIONS ............................................................................................................ 3
Pre-Expander ............................................................................................................................. 3
Block Mold ................................................................................................................................. 3
2.3 CONTROL OF VOC EMISSIONS ......................................................................................................... 3
SECTION 3 - TEST PROTOCOL ................................................................................................. 6
3.1 OVERALL CONTROL EFFICIENCY ...................................................................................................... 6
3.2 CAPTURE EFFICIENCY METHODOLOGY ......................................................................................... 6
PRODUCTION SCHEDULE DURING TESTING ................................................................ 6
Determination of Total Pentane in Raw Material ........................................................ 7
Determination of Residual Pentane in Finished Product ......................................... 8
Calculation of Total Collectable Pentane ....................................................................... 8
Determination of Captured Pentane ................................................................................ 8
Calculation of Capture Efficiency ....................................................................................... 9
3.3 CONTROL EFFICIENCY METHODOLOGY ....................................................................................... 9
Boiler VOC Emission Rate ..................................................................................................... 9
Boiler Inlet VOC input rate ................................................................................................... 9
Calculation of Destruction Efficiency ............................................................................... 9
3.4 TOTAL EMISSIONS FROM THE PROCESS DURING THE TEST PERIOD ............................ 10
SECTION 4 - SUMMARY OF RESULTS ................................................................................... 11
4.1 DESTRUCTION EFFICIENCY .............................................................................................................. 11
4.2 CAPTURE EFFICIENCY ......................................................................................................................... 12
4.3 POTENTIAL ERRORS IN TESTING ................................................................................................... 12
18002 iv

4.4 PENTANE CONTENT ANALYSIS RESULTS ................................................................................... 13
4.5 RAW DATA FILES .................................................................................................................................. 13
4.6 GRAPHS OF INLET FLOW AND CONCENTRATION ................................................................. 13
SECTION 5 - SAMPLING AND ANALYTICAL PROCEDURES ................................................ 16
5.1 SAMPLING LOCATIONS..................................................................................................................... 16
Boiler Inlet ............................................................................................................................... 16
Boiler Outlet ........................................................................................................................... 16
5.2 DETERMINATION OF CAPTURED PENTANE .............................................................................. 16
Sampling System .................................................................................................................. 16
Analysis Instrumentation ................................................................................................... 16
Quantifications ...................................................................................................................... 16
Calibration Checks ............................................................................................................... 17
Stratification Check .............................................................................................................. 17
Boiler Inlet Flow Rate .......................................................................................................... 17
5.3 DESTRUCTION EFFICIENCY TEST METHODOLOGY................................................................. 19
Traverse Point Layouts ....................................................................................................... 19
Cyclonic Flow Check ............................................................................................................ 19
Stratification Check .............................................................................................................. 19
Response Time ...................................................................................................................... 19
Boiler Outlet Flow Rate ...................................................................................................... 19
Molecular Weight ................................................................................................................. 19
Moisture Content ................................................................................................................. 20
VOC Emissions (Total Hydrocarbons) ........................................................................... 20
5.4 RAW EPS SAMPLING .......................................................................................................................... 20
5.5 MOLDED BLOCK SAMPLING ........................................................................................................... 20
5.6 MOLDED SHAPE SAMPLING ............................................................................................................ 21
5.7 DETERMINATION OF PENTANES IN EXPANDABLE STYRENE POLYMERS ..................... 21
5.8 DATA LOGGING .................................................................................................................................... 21
5.9 DEVIATIONS FROM ANALYTICAL METHODS ............................................................................ 21
SECTION 6 - QUALITY CONTROL SUMMARY ...................................................................... 23
6.1 METHOD 320 (PENTANES BY FTIR) ............................................................................................... 23
Zero Checks ............................................................................................................................ 23
Calibration Transfer Standard .......................................................................................... 23
Dynamic Spiking ................................................................................................................... 23
6.2 METHOD 3A (OXYGEN/CARBON DIOXIDE) ............................................................................... 23
6.3 METHOD 25A (TOTAL HYDROCARBONS) .................................................................................. 23
18002 v

6.4 METHOD 2 (BOILER OUTLET FLOW RATE) ................................................................................. 23
6.5 METHOD ALT-012 (INLET FLOW RATE) ....................................................................................... 23
6.6 METHOD 4 .............................................................................................................................................. 24
6.7 EQUIPMENT CALIBRATIONS............................................................................................................ 24
Pitot Calibrations .................................................................................................................. 24
Thermocouple & Meter Calibrations ............................................................................ 24
Barometer Calibrations ...................................................................................................... 24
Dry Gas Meter Calibrations ............................................................................................... 24
6.8 CEM INTERFERENCE CHECK DATA ............................................................................................... 24
6.9 METHOD 306-91 PENTANE ANALYSIS ........................................................................................ 24
Duplicate Injections ............................................................................................................. 24
Calibration Drift ..................................................................................................................... 24
Screening Samples ............................................................................................................... 24
Duplicate Analysis ................................................................................................................ 24
Matrix Spike ............................................................................................................................ 25
Balance Calibration .............................................................................................................. 25

18002 vi

LIST OF APPENDICES
APPENDIX A – Detailed Results and Calculations
Boiler Inlet Calculations (Captured Pentane)
Method 320 QC
Boiler Outlet Flow and Moisture
Boiler Outlet VOCs, Oxygen and Carbon Dioxide
Pentane Mass Calculations
APPENDIX B – Calculation Equations
APPENDIX C – EPS Pentane Analysis
Sample Preparation
Instrument Calibration & QC
Analysis Results
Chromatograms
APPENDIX D – Production Data
Plant Production Records
Raw Bead Certificates of Analysis
APPENDIX E – Field Data Sheets
Boiler Outlet Flow and Moisture
Raw Bead and Finished Product Sampling
Project Notes
APPENDIX F – Equipment Calibrations
Pre-Test Calibrations
Post-Test Calibrations
APPENDIX G – Calibration Gas Certificates
APPENDIX H – CEM Interference Test Data
APPENDIX I – Boiler Outlet Raw Instrument Data

18002 1

SECTION 1 - INTRODUCTION
1.1 TEST SITE INFORMATIO N
Testing was performed at the ACH Foam Technologies, Inc. facility located at 111 W Fireclay
Avenue, Murray, UT 84107. The latitude/longitude of the facility are 40.677156/-111.894906.
1.2 DESCRIPTION OF FACIL ITY
This facility produces expanded polystyrene (EPS) foam blocks, which are cut into various final
products. EPS is produced by the expansion of polystyrene “raw beads” that contains a blowing
agent, typically composed of one or more isomers of pentane at a concentration of 3.5% to
7% by weight. A portion of the blowing agent is emitted during the manufacturing process.
ACH uses a Pentane Emission Control Systems (PECS) to capture and destroy these volatile
organic compound (VOC) emissions.
1.3 PURPOSE OF TESTING
Testing is being conducted to measure the capture efficiency (CE) and destruction efficiency
(DE) of the PECS in order to quantify the VOC emissions from the process after new control
technology was installed.
1.4 FACILITY CONTACT
The contact person for ACH is:
Brian Curran
Corporate Director EHS
Office: [phone]
[e-mail]
1.5 TESTING COMPANY CONT ACT
The contact person for Soderberg Polytechnic Company is:
Daniel Soderberg
Project Manager
Office: [phone]
[e-mail]
1.6 SUMM ARY OF TESTING PERFO RMED
Testing was performed to determine the collection efficiency of the Pentane Emission Control
System (PECS) and the destruction efficiency of a gas-fired boiler that was used as a pentane
destruction device.
Collection efficiency testing was performed by measuring the total mass of pentane fed to the
boiler during a complete production cycle, and comparing this value to the total amount of
pentane emitted during production. Collection efficiency testing covered a period of about 57
hours.
18002 2

Destruction efficiency testing was performed by the concurrent measurement of the VOC mass
emission rates at the inlet and outlet of the boiler. Three 60-minute runs were performed.
1.7 TESTING PERSONNEL
Testing was performed by Mr. Daniel Soderberg, QSTI, Project Manager, and Mr. William
Robinson, Environmental Technician.
1.8 REGULATORY REPRESENT ATIVES
No regulatory representative was present during the testing.

18002 3

SECTION 2 - PROCESS DESCRIPTION
2.1 EPS PRODUCTION PROCE SS
EPS is produced in a multi-step process. During the first phase the raw polystyrene beads are
partially expanded using steam in a pre-expander. The beads are then dried in a fluidized bed
drier. After pre-expansion, the “pre-puff” beads are transferred to bags in the bead storage
room where they are kept at elevated temperature for approximately 12 - 24 hours to allow
excess blowing agent to diffuse from the beads. In the final step, the aged beads are
transferred to a mold, where they are subjected to steam and vacuum cycles until they fuse
into a solid block or shaped part.
2.2 EQUPIMPENT DESCRIPTI ONS
The following equipment is used in the EPS manufacturing process.
Pre -Expander
The pre-expander is a Hirsch Pre-Ex 12000 batch expander with fluid bed dryer, serial
number D 22 PD, manufactured in 2000. It is rated for a production rate of 6,000 pounds
per hour at a density of 1.5 lb/ft3.
Block Mold
The block mold is a Kurtz Vacuum Mold, serial number BF000376. It was manufactured
in 2007. The maximum cavity size is 4’ x 4’ x 24’. It is rated for a nominal maximum
capacity of 15-20 block per hour, based on a density of 0.90 pounds per cubic foot.
2.3 CONTROL OF VOC EMISS IONS
The PECS is a closed-loop system that collects pentane emissions from several points in the
process:
 Block pre-expander/dryer exhaust
 Block mold vacuum pump exhaust
 Block mold conveyor air return
 Bead storage room

The captured emissions from the block mold and pre-expander are passed through a
condenser and dryer to remove moisture from the steam. The dried air is then fed into the
bead storage room. A portion of the air in the bead storage room is continuously removed
and combusted in the boiler that provides steam to the manufacturing process in addition to
serving as an emission control unit (ECU). Fresh make-up air is drawn into the bead storage
room through vents in the wall.
Air from the bead storage room is also extracted for use by the pneumatic conveyance system
that transports the pre-puff material. This air is returned to the bead storage room.

18002 4

The specification for the boiler are:
Manufacturer Hurst
Description HP 4-Pass Wetback with Preferred Instruments O2 Trim System.
Capacity 300 HP
Model # S1500-150-120
Serial # 0750501
Year Built 2007
Burner IC Model DG-145P (Serial#50148-1)
Firing Rate (1000 BTU/CF) = 12,600,000 BTU/HR
Steam 10,350 lb/hr
Combustion Air 2,373 SCFM @ 100% Fire Rate, 396 SCFM @ Minimum Fire Rate

A diagram of the process is shown in Figure 2-1.

300 HP
BOILER
STEAM
KNOCKOUT
PRE-
EXPANDER
EPS
RAW
BEADS
FP1
RM1
TG
AGING
BAG
BLOCK
MOLD
AGING
BAG
AGING
BAG
AGING
BAG
BEAD STORAGE ROOM
RM RAW MATERIAL SAMPLING POINT
FP FINISHED PRODUCT SAMPLING POINT
VOC VOC SAMPLING POINT
TG TRACER GAS INJECTION POINT
AIR STREAM EPS CONVEYOR CONVEYOR
AIR RETURN
MAKE-UP AIR
Figure 2-1
Process Diagram
5
18002 6

SECTION 3 - TEST PROTOCOL
3.1 OVERALL CONTROL EFFI CIENCY
The overall control efficiency (OCE) was determined by multiplying the capture efficiency (CE)
of the PECS and the destruction efficiency (DE) of the captured pentane in the boiler.
The DE and CE were determined according to the following procedures:
3.2 CAPTU RE EFFICIENCY METHOD OLOGY
The capture efficiency of the PECS was determined by comparing the mass of pentane captured
and fed to the boiler with the total amount of collectable pentane emissions from the
manufacturing process. Collectable pentane emissions were determined by the difference
between the total mass of pentane in the raw expandable polystyrene (EPS) material and the
residual pentane in the molded blocks and shape parts.
Because of the batch nature of the process, emissions at any point in time cannot be considered
representative of steady-state conditions. Therefore, it was necessary for the emission test to
cover an entire production cycle. Because of the extended time required to “age” the pre-puff
EPS before molding, the test covered a period of approximately 57 hours. During the testing
63,915 pounds of raw EPS material was processed for block molding and about 4,406 pounds
of raw EPS was processed for pre-puff.
At the beginning of the test, the pre-puff aging bags were empty and the emissions from the
PECS were near zero. During the first test day, several batches of raw EPS were pre-expanded
to fill the aging bags. On the second day, molding operations started and additional raw EPS
was expanded. On the third day, the remaining pre-puff was molded, but no new raw EPS was
pre-expanded. One lot of pre-puff material was sold as finished product, and was not molded
into blocks.
When all the pre-puff from the aging bags had been molded the emissions from the PECS
dropped back to near zero, at which point the capture efficiency test was concluded.
P roduction Schedule During Testing
The following is a summary of the production during the test period.

May 30, 2018 (expansion only):
Pre-Expansion
4,406 lbs Flint Hills 5654, 0.70 Density (6.2 - 7.0% Pentane)
22,030 lbs Flint Hills 5654, 0.90 Density (6.2 - 7.0% Pentane)
Block Molding
None

18002 7

May 31, 2018 (mold materials from day 1 and expansion for day 3):
Pre-Expansion
11,015 lbs Flint Hills S5454, 1.15 Density (4.5 – 5.1% Pentane)
15,435 lbs NOVA 3M77BG 1.80A Density (~4% Pentane)
15,435 lbs NOVA M77BG 1.80A Density (~4% Pentane) (second lot #)
Block Molding
22,030 lbs Flint Hills 5654, 0.90 Density
Pre-Puff
4,406 lbs Flint Hills 5654, 0.70 Density was final product as pre-puff beads, and was
not molded into blocks.
June 1, 2018 (complete molding of expanded material)
Block Expansion
None
Block Molding
11,015 lbs Flint Hills S5454, 1.15 Density
15,435 lbs NOVA 3M77BG 1.80A Density
15,435 lbs NOVA M77BG 1.80A Density (second lot #)
Determination of Total Pentane in Raw Material
Samples from each lot of EPS resin used in the test were taken prior to the pre-expansion
phase (Test Point RM1). These samples were placed into crimp-sealed vials to be
analyzed later for their pentane content. The total amount of pentane in the raw material
used was calculated as follows:

MPTotal Total mass of pentane in raw material (lb)
MRi Mass of raw material used from lot i (lb)
IPi Initial pentane fraction in raw material lot i (% by weight)

The amount of EPS processed into molded blocks was assumed to be the same as the
amount of raw material processed, adjusted for the difference in pentane content
between the raw material and finished product.



n
i
i
iTotal
IPMRMP
1 100
18002 8

Determination of Residual Pentane in Finished Product
Samples from the EPS molded blocks produced during the test (Test Point FP1) were
taken immediately after the blocks came out of the mold. These samples were placed
into crimp-sealed vials to be analyzed later for their pentane content.
The following equation was used to determine total residual pentane in the finished
blocks and shapes:

MPResidual Total mass of residual pentane in finished product (lb)
MRi Mass of raw material used from lot i (lb)
IPi Initial pentane fraction in raw material lot i (% by weight)
RPi Residual pentane fraction in finished product lot i (% by weight)
Calculation of Total Collectable Pentane
The total collectable pentane for the test period was calculated as follows:
MPCollectable = MPTotal - MPResidual

MPCollectable Total mass of collectable pentane (lb)
MPTotal Total mass of pentane in raw material (lb)
MPResidual Total mass of residual pentane in finished product (lb)
Determination of Captured Pentane
During the entire test period the pentane concentration in the boiler feed (Test Point
VOC 1) was measured as described in Section 4. The flow rate was also continuously
monitored. The mass emission rate of pentane in the boiler air feed was calculated at
30-second intervals.
The total mass of pentane captured during the test period was calculated as follows:

MPCaptured Total mass of pentane captured by control system (lb)
CPi Pentane concentration in boiler air feed for integration period i (lb/scf)
Fi Flow rate of air feed to boiler for integration period i (scfm)
Ti Duration of integration period i (minutes)






n
i
i
i
i
iResidual RPRP
IP
MRMP
1
1001
1001
i
n
i
iiCaptured TFCPMP
1



18002 9

Calculation of Capture Efficiency
The following equation was used to calculate the capture efficiency:
100
eCollectabl
Captured
MP
MPCE

CE: Capture efficiency (%)
MPCaptured Total mass of pentane captured by control system (lb)
MPCollectable Total mass of collectable pentane (lb)
3.3 CONTROL EFFICIENCY METHODOLO GY
The collected pentane emissions were fed to the boiler and destroyed by incineration. The
destruction efficiency of the boiler was determined by comparing the amount of pentane at
the boiler inlet (Test Point VOC1) and in the boiler’s emission stream (Test Point VOC2). Three
one-hour runs were performed on the second day of testing, when pentane emissions were
expected to be highest.
Boiler VOC Emission Rate
The total gaseous organic carbon (TGOC) concentration and flow rate from the boiler
stack was measured to calculate the mass emission rate, as follows:

MPStack Total mass of pentane emitted from boiler stack (lb)
CPStack Concentration of pentane in boiler stack exhaust (lb/dscf)
FStack Flow rate from boiler stack (dscfm)

Boiler Inlet VOC input rate
The mass of pentane fed to the boiler during the DE test was determined from the data
collected for the capture efficiency testing. The boiler input VOC data for each run can
be found in Appendix A.
Calculation of Destruction Efficiency
The destruction efficiency was calculated as follows:
StackStackStackFCPMP
18002 10

DE Boiler destruction efficiency (%)
MPCaptured Total mass of pentane captured by control system during DE run (lb)
MPStack Total mass of pentane emitted from boiler stack during DE run (lb)

3.4 TOTAL EMISSIONS FROM THE P ROCESS DURING THE TEST PERIOD
The total amount of pentane emitted from the process during the test period was calculated
as follows:
=−×
100 ×
100

MPEmitted Total mass of pentane emitted during test period (lb)
MPCollectable Total mass of collectable pentane (lb)
DE Boiler destruction efficiency (%)
CE Capture efficiency (%)

100
Captured
StackCaptured
MP
- MPMPDE
18002 11

SECTION 4 - SUMMARY OF RESULTS
4.1 DESTRUCTION EFFICIEN CY
Three 60-minute test runs were performed to measure the VOC mass rates at the inlet and
outlet of Boiler #2 in order to calculate the destruction efficiency. The boiler outlet emissions
for are summarized in Table 4-1. Detailed run reports can be found in Appendix A.
Table 4-1
Boiler #2 Outlet VOC Emissions
Parameter Unit Run 1 Run 2 Run 3 Average
Run Time
on 05/31/18
start 16:25 17:55 19:30
end 17:28 18:59 20:35
Moisture % 14.31 14.32 14.43 14.35
Oxygen % 6.96 6.90 6.88 6.91
Carbon Dioxide % 8.44 8.49 8.52 8.48
Stack Temp °F 358 357 358 357
Stack Velocity ft/min 1,278 1,251 1,245 1,258
Flow Rate
acfm 2,858 2,798 2,785 2,814
scfm 1,560 1,530 1,521 1,537
dscfm 1,337 1,311 1,301 1,316
Total VOCs
(as pentane)
ppmV Wet 2.93 2.42 1.84 2.40
ppmV Dry 3.42 2.82 2.16 2.80
Mass Emission Rate lb/hr 0.0514 0.0415 0.0315 0.0415

The mass rate of pentane fed to the boiler during each test run was taken from the data
collected for capture efficiency testing. The pentane input rate and destruction efficiency
results are summarized in Table 4-2.

18002 12

Table 4-2
Destruction Efficiency
Parameter Unit Run 1 Run 2 Run 3 Average
Run Time
on 05/31/18
start 16:25 17:55 19:30
end 17:28 18:59 20:35
Outlet VOCs
(as pentane)
ppmV wet 2.93 2.42 1.84 2.40
lb/hr 0.0514 0.0415 0.0315 0.0415
Inlet VOCs
(as pentane)
ppmV wet 2,455 3,306 3,773 3,178
lb/hr 38.22 49.99 57.02 48.41
Destruction
Efficiency % 99.87 99.92 99.94 99.91
4.2 CAPTURE EFFICIENCY
Measurement of captured VOCs at the boiler inlet was conducted form 10:00 on 05/30/2018
until 18:17 on 06/01/2018. The capture efficiency results are summarized in Table 4-3. Detailed
calculations can be found in the appendices of this report.
Table 4-3
Capture Efficiency
Parameter Unit Result
Total raw EPS expanded lb 68,321
Total pentane in raw EPS lb 3,681
Total residual pentane lb 1,569.2
Total collectable pentane lb 2,111.8
Total collected pentane lb 1,677.6
Capture efficiency % 79.44
Destruction efficiency % 99.91
Overall control efficiency % 79.37

4.3 POTENTIAL ERRORS IN TESTING
The boiler outlet VOC emissions were not corrected for methane content. The measured VOC
emissions are likely primarily methane from the fuel gas, and not pentane. The actual
18002 13

destruction efficiency is likely slightly higher than reported. Since the measured DE was above
99.9%, this bias would be statistically insignificant.
There were no other factors that may have introduced errors in the test results.
4.4 PENTANE CONTENT ANAL YSIS RESULTS
Details of the raw bead and finished product pentane analysis can be found in Appendix C.
The analyses of all raw bead samples were in close agreement with the pentane content
provided on the manufacturers’ certificates of analysis. The manufacturers’ certificates can be
found in Appendix D.
4.5 RAW DATA FILES
Complete calculation spreadsheets and raw data files can be found on the DVD-ROM included
with this report.
4.6 GRAPHS OF INLET FLOW AND CONCENTRATION
A graph of the pentane concentration over the test period is shown in Figure 4-1. Data from
the plant’s LEL monitor is presented for comparison. A graph of the flow rate data and plant
flow data is shown in Figure 4-2.
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 30
ATTACHMENT B: PROCESS FLOW DIAGRAM
300 HP
BOILER
STEAM
KNOCKOUT
PRE-
EXPANDER
EPS
RAW
BEADS
FP1
RM1
TG
AGING
BAG
BLOCK
MOLD
AGING
BAG
AGING
BAG
AGING
BAG
BEAD STORAGE ROOM
RM RAW MATERIAL SAMPLING POINT
FP FINISHED PRODUCT SAMPLING POINT
VOC VOC SAMPLING POINT
TG TRACER GAS INJECTION POINT
AIR STREAM EPS CONVEYOR CONVEYOR
AIR RETURN
MAKE-UP AIR
Figure 2-1
Process Diagram
5
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 32
ATTACHMENT C: RBLC SEARCH RESULTS
Reasonably Available Control Technology (RACT) Analysis
Atlas Molded Products, Murray Utah
December 18, 2023 Page 39
ATTACHMENT D: EMISSIONS CALCULATIONS
Date -
Year Date - Month
Bead Usage
(lbs)
Bead
Pentane
Content (%)
VOC
Throughput
(tons)
VOC Emitted
(15%
Retained in
Final
Product)
VOC Capture
& Destruction
Efficiency
(%)
VOC
Emissions
(tons)
Monthly
Production
(%)
2022 January 452,295 5.28 11.89 10.11 79.37 2.08 7.18
2022 February 572,859 4.64 13.23 11.25 79.37 2.32 9.10
2022 March 699,415 5.16 17.80 15.13 79.37 3.12 11.11
2022 April 495,965 5.08 12.44 10.58 79.37 2.18 7.88
2022 May 590,391 5.32 15.65 13.30 79.37 2.74 9.37
2022 June 572,727 5.31 15.17 12.89 79.37 2.66 9.09
2022 July 509,954 5.26 13.34 11.34 79.37 2.34 8.10
2022 August 502,615 5.42 13.51 11.49 79.37 2.37 7.98
2022 September 607,087 4.98 14.97 12.72 79.37 2.62 9.64
2022 October 457,123 4.93 11.23 9.55 79.37 1.97 7.26
2022 November 494,493 4.70 11.72 9.96 79.37 2.05 7.85
2022 December 342,659 5.25 9.06 7.70 79.37 1.59 5.44
Total 6,297,583 5.11 160.01 136.01 28.06 100.00
Atlas Molded Products RY2022 Air Emissions (EPS Process)
Murray Utah
Date -
Year Date - Month
Bead Usage
(lbs)
Bead
Pentane
Content (%)
VOC
Throughput
(tons)
VOC Emitted
(15%
Retained in
Final
Product)
VOC Capture
& Destruction
Efficiency
(%)
VOC
Emissions
(tons)
Monthly
Production
(%)
2022 January 12,551 5.11 0.32 0.27 0.00 0.27 13.58
2022 February 9,417 5.11 0.24 0.20 0.00 0.20 10.19
2022 March 14,348 5.11 0.37 0.31 0.00 0.31 15.53
2022 April 8,723 5.11 0.22 0.19 0.00 0.19 9.44
2022 May 6,811 5.11 0.17 0.15 0.00 0.15 7.37
2022 June 3,852 5.11 0.10 0.08 0.00 0.08 4.17
2022 July 5,496 5.11 0.14 0.12 0.00 0.12 5.95
2022 August 4,852 5.11 0.12 0.11 0.00 0.11 5.25
2022 September 8,860 5.11 0.23 0.19 0.00 0.19 9.59
2022 October 3,482 5.11 0.09 0.08 0.00 0.08 3.77
2022 November 6,859 5.11 0.18 0.15 0.00 0.15 7.42
2022 December 7,146 5.11 0.18 0.16 0.00 0.16 7.73
Total 92,397 5.11 2.36 2.01 2.01 100.00
Atlas Molded Products RY2022 Air Emissions (Loose-Fill Expansion)
Murray Utah
Date -
Year Date - Month
Bead Usage
(lbs)
Initial Bead
Pentane
Content (%)
Bead
Pentane
Content at
Densification
(15% of
initial)
Post
Densification
Pentane
Content (%)
Pentane
Loss (%)
VOC
Emissions
(lbs)
VOC
Emissions
(tons)
VOC Capture
& Destruction
Efficiency (%)
VOC
Emissions
(tons)
Monthly
Production
(%)
2022 January 35,109 5.28 0.79 0.36 0.43 151.62 0.08 0.00 0.08 7.18
2022 February 44,467 4.64 0.70 0.36 0.34 149.68 0.07 0.00 0.07 9.10
2022 March 54,291 5.16 0.77 0.36 0.41 224.92 0.11 0.00 0.11 11.11
2022 April 38,498 5.08 0.76 0.36 0.40 154.75 0.08 0.00 0.08 7.88
2022 May 45,828 5.32 0.80 0.36 0.44 200.84 0.10 0.00 0.10 9.37
2022 June 44,457 5.31 0.80 0.36 0.44 193.84 0.10 0.00 0.10 9.09
2022 July 39,584 5.26 0.79 0.36 0.43 169.56 0.08 0.00 0.08 8.10
2022 August 39,015 5.42 0.81 0.36 0.45 176.72 0.09 0.00 0.09 7.98
2022 September 47,124 4.98 0.75 0.36 0.39 182.55 0.09 0.00 0.09 9.64
2022 October 35,483 4.93 0.74 0.36 0.38 134.72 0.07 0.00 0.07 7.26
2022 November 38,384 4.70 0.71 0.36 0.35 132.57 0.07 0.00 0.07 7.85
2022 December 26,598 5.25 0.79 0.36 0.43 113.53 0.06 0.00 0.06 5.44
Total 488,838 5.11 0.77 0.36 0.41 1,985.31 0.99 0.99 100.00
Atlas Molded Products RY2022 Air Emissions (Recycled Product Densification)
Murray Utah