DAQ-2024-011815

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DAQC-CI127390001-24
Site ID 12739 (B1)

MEMORANDUM

TO: FILE – STORM PRODUCTS INCORPORATED – Bowling Ball Manufacturing

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: November 8, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: November 6, 2024

SOURCE LOCATION: 165 South 800 West
Brigham City, UT 84302
SOURCE CONTACTS: Corbet Austin, VP of Operations
435-723-0403 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Storm Products Incorporated (Storm Products), located in
Brigham City, Box Elder County, creates bowling balls for
shipment to national and international customers. Bowling ball
manufacturing involves six (6) stages: casting the core, casting
the ball around the core, cutting the ball to the proper
dimensions, drilling finger holes, polishing, and etching.
Finished bowling balls are packaged and stored for shipping.
Particulates from cutting, cleaning, sizing, finishing, and etching
are sent to an outdoor baghouse, then vented back into the
building or exhausted outside for heat control. A closed room
houses three (3) styrene and two (2) isocyanate tanks. Polyol is
stored in large containers.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN127390007-24, dated June 4,
2024
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Storm Products Incorporated- Bowling Ball
Manufacturing

165 South 800 West 165 South 800 West
Brigham City, UT 84302 Brigham City, UT 84302

SIC Code: 3949: (Sporting & Athletic Goods, NEC)

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Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. The source is not currently required to submit an Emission Inventory.
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: Not Applicable. The listed equipment and process has not changed since the previous AO and a construction notification is not necessary. Previous inspections have verified the permitted equipment as installed and operational.

Section II: SPECIAL PROVISIONS

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

II.A.1 Brigham City Bowling Products Manufacturing Plant
II.A.2 Baghouse One (1) baghouse Flowrate: 27,000 scfm Controls emissions from the laser etcher
II.A.3 Batching Systems Two (2) two-vessel closed batching systems
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II.A.4 Batching System One (1) three-vessel closed batching system
II.A.5 Casting Machine One (1) Peyton-Technology casting machine
II.A.6 Ball Polisher One (1) filtered bowling ball polisher This equipment is listed for informational purposes only.
II.A.7 Parts Washers Various Parts Washers
II.A.8 Vent Stack One (1) Vent Stack 43 feet from ground level 7,500 scfm blower
Status: In Compliance. No unapproved equipment was observed. The parts washer listed in II.A.7 is located in the maintenance area.

II.B Requirements and Limitations
II.B.1 VOC and HAPs Emission Limitations II.B.1.a The owner/operator shall comply with all applicable requirements of R307-304, Solvent Cleaning, and R307-335, Degreasing for all applicable emission units on site. [R307-304, R307-335] Status: In Compliance. The source used 15 gallons of VOC containing solvent products for the previous year. Therefore, R307-304 is not applicable at this time. Used VOC-laden rags and towels are stored in closed, fireproof containers. The source utilizes one cold cleaning parts washer located in the maintenance area applicable to R307-335-4. The parts washer lid was closed and remains closed except during actual loading, unloading, or handling of parts. An internal drainage rack is installed and the system appeared to be in good working condition. Used solvent is stored in covered containers and shipped off site by a third-party vendor. Written procedures were originally posted on the bottom of the lid but have degraded throughout the years and are no longer legible. Compliance assistance was provided and the source will print and post new operating instructions. II.B.1.b The owner/operator shall not emit more than the following from the bowling ball formers; contact cement applicators; batching and casting systems; and associated operations: 28.31 tons of VOC per rolling 12-month period 9.76 tons of xylene per rolling 12-month period 2.77 tons of styrene per rolling 12-month period. [R307-401-8] Status: In Compliance. The source emitted the following totals for the rolling 12-month period from October 2023 - September 2024: 19.00 tons of VOC 5.93 tons of xylene 1.96 tons of styrene II.B.1.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall determine and log the monthly consumption of the materials containing VOCs and HAPs. [R307-401-8]
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II.B.1.b.2 The owner/operator shall keep records of consumption for all periods when the plant is in operation. These records of consumption shall include the following: A. Name of the VOC or HAP emitting material B. Density of each material used (pounds per gallon) C. Percent by weight of all VOCs and HAPs in each material used D. Gallons of each VOC or HAP emitting material used E. The amount of VOC or HAPs emitted monthly by each material. [R307-401-8] II.B.1.b.3 The owner/operator shall calculate the amount of VOC or HAPs emitted with the following procedure: VOC = monthly material throughput (in 1,000 of pounds) x VOC factor in (in pounds/1,000 pounds of material) HAPs = % styrene or xylene by weight/100 x density (lb/gal) x gallons used x 1 ton/2000 lb x emission factor. The owner/operator has used 83% in its xylene calculations and 0.3% in its styrene calculations. [R307-401-8] Status: In Compliance. Calculations are made according to this condition and were viewed during the inspection. Monthly consumption is tracked and recorded for each material containing VOCs and HAPs. II.B.1.c The owner/operator shall not operate for more than 16 hours per day and five days per week. [R307-401-8] II.B.1.c.1 The owner/operator shall determine the hours of operation by supervisor monitoring and maintaining of an operations log. [R307-401-8] Status: In Compliance. The source typically operates from 6:00 AM to 5:00 PM, five days per week. Operation logs are kept by the maintenance manager and were viewed during the inspection. II.B.2 Baghouse Requirements II.B.2.a The owner/operator shall use a baghouse to control particulate emissions from the laser etcher of each produced bowling ball. [R307-401-8] Status: In Compliance. A baghouse is used to control particulate emissions from the laser etchers. II.B.2.b The owner/operator shall not allow visible emissions from the baghouse to exceed 10% opacity. [R307-401-8] II.B.2.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from the baghouse. II.B.2.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the baghouse. [R307-401-8] II.B.2.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
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II.B.2.c.2 The pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] Status: In Compliance. A magnehelic pressure gauge is installed and can be safely read at any time. The pressure gauge measures static pressure in 0.5-inch increments and read 3.5 inches of water column at the time of inspection. II.B.2.d During operation of the baghouse, the owner/operator shall maintain the static pressure differential across the baghouse between 2 and 7 inches of water column. [R307-401-8] II.B.2.d.1 The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] II.B.2.d.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Daily static pressure differential readings; C. Date of reading. [R307-401-8] Status: In Compliance. Daily measurements are recorded and averaged 3.5 - 4.0 inches of water column for the previous 12 months. No measurement was outside of the permitted range. Daily measurements include the required information listed in this condition. II.B.2.e At least once every 12 months, the owner/operator shall calibrate the pressure gauge in accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8] II.B.2.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] Status: Not Observed. The source has not calibrated the pressure gauge as this is a new requirement for this AO issued in June 2024. Compliance assistance was provided and the source created a work order to ensure the gauge is calibrated or replaced once every 12 months.
Section III: APPLICABLE FEDERAL REQUIREMENTS

No federal requirements apply at this time.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Solvent Cleaning [R307-304]

Status: Not Applicable. Refer to Condition II.B.1.a for more details.
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. All VOC-laden rags and towels are stored in closed, fireproof containers. All
other VOC-related products were observed to be handled and stored correctly at the time of
inspection.

Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. Refer to Condition II.B.1.a for more details.

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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Storm Products
Incorporated - Bowling Ball Manufacturing on the Approval Order (AO) DAQE-AN127390007-24, dated
June 4, 2024. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
Particulate Matter - PM10 0.02
Particulate Matter - PM2.5 0.01
Volatile Organic Compounds 28.31

Hazardous Air Pollutant PTE lbs/yr
Styrene (CAS #100425) 5540
Xylenes (Isomers And Mixture) (CAS #1330207) 19520

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN127390007-24,
dated June 4, 2024, the overall status is: In Compliance. The
source appears to be well maintained and operated. Records were
current and provided at the time of inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the normal frequency. Verify the source does not use
more than 55 gallons of VOC containing solvent products. Look
for the baghouse magnehelic pressure gauge calibration records.

NSR RECOMMENDATIONS: Condition I.8 can be removed as the baghouse and etching
system are not new equipment and are included on the previous
AO.

ATTACHMENTS: VOC, xylene and styrene emission totals, emission trend lines