DAQ-2024-012003

1
DAQC-CI118290001-24
Site ID 11829 (B1)

MEMORANDUM

TO: FILE – DETROIT REMANUFACTURING LLC – Engine Maintenance Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: September 10, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Tooele County

INSPECTION DATE: June 12, 2024

SOURCE LOCATION: 100 South Lodestone Way
Tooele, UT 84074
SOURCE CONTACT: Derek Terry, EHS Engineer, 435-843-6034, C:385-235-0967,
[e-mail]

OPERATING STATUS: In operation

PROCESS DESCRIPTION: Detroit Diesel Remanufacturing, LLC receives, disassembles,
cleans, and remanufactures diesel engines and engine
components. The engines, engine parts, and components such as
turbo chargers, oil pumps, injectors, and water pumps are
trucked to the facility where they are inspected and
disassembled, then cleaned and remanufactured utilizing various
machining and repair processes such as: baking, glass beading,
shot blasting, grinding, sanding, honing, welding, and
machining. The remanufactured components are then assembled,
painted, and packaged for shipping to the distribution network.
Some complete engines are also tested prior to shipping. The
engines are tested by mounting them in a DYNO test cell and
operating the engine for a prescribed time under various loads
and speeds and recording the engine performance. The majority
of these test runs are about 1 hour in duration but some last for
several hours. The emissions resulting from these tests are
exhausted through engine muffler systems and exhausted out
stacks mounted on the roof of the building. Cameras are focused
on the stack vents to monitor emissions. Paint booths are
equipped with particulate arrestor filters and are exhausted out
the roof of the building. Welding, sand blasting,
and grinding operations are all controlled by dust collecting
baghouses.

/ :
2
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN118290014-20, dated
December 24, 2020
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Detroit Remanufacturing LLC - Engine
Maintenance Facility

13400 Outer Drive West 100 South Lodestone Way
Detroit, MI 48239 Tooele, UT 84074

SIC Code: 7538: (General Automotive Repair Shops)

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

I.7

The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. [R307-150] The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

3
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: In Compliance. Detroit Diesel Remanufacturing has not exceeded any limits set forth in this Approval Order. Detroit Diesel Remanufacturing maintains records for at least two years, and maintains records of maintenance activities performed on approved equipment. According to the Detroit Diesel Remanufacturing, there has been no breakdowns resulting in an emissions event. Detroit Diesel Remanufacturing is not required to submit an Emissions Inventory Report at this time. According to Detroit Diesel Remanufacturing, an NOI was submitted to NSR on August 16, 2022, for an Administrative Amendment to add several pieces of equipment and to increase propane usage.
According to DAQC-CI18290001-23, Detroit Diesel had submitted an NOI in 2020 to
include three thermal cleaning ovens and two drying ovens carried over from their Kansas
Facility. However, the equipment was not reflected in AO DAQE-AN118290014-20, dated
December 24, 2020. There are six thermal cleaning ovens in AO Condition II.A.11.

Detroit Diesel Remanufacturing plans to fulfill AO Condition 1.8, as soon as the
administrative update is completed.

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Detroit Diesel Remanufacturing, LLC

II.A.2 Maintenance Cartridge Dust Collector
Controls fumes from MIG welding

II.A.3 Once Box Cartridge Dust Collector
Controls fumes from plasma cutting

II.A.4 Glass Beader Baghouse
Controls emissions from six (6) glass bead abrasive blaster units

II.A.5 Spinner/Hanger External Dust Collector

II.A.6 Double Table Blaster External Dust Collector

II.A.7 Tumble Blasters
Two (2) units (vent to internal dust collector)

II.A.8 Steel Shot Blaster
Vents to internal dust collector

II.A.9 Various Degreasing Tanks
Contents: solvent based cleaner

II.A.10 Engine Test Cells
Fourteen (14) total/six (6) operational
4
II.A.11 Thermal Cleaning Ovens
Three (3) units, equipped with afterburners
Maximum rating: 2.25 MMbtu/hr (each)
Fuel: Natural Gas

II.A.12 Paint Booths
Two (2) units

II.A.13 Proceco Parts Washer

II.A.14 Various Heaters
Includes: Parts Washer heater
Maximum rating: less than 5.00 MMBtu/hr (each)

II.A.15 Various Non-volatile Degreasing Tanks
For informational purposes only

II.A.16 TAC Welding Operations
For informational purposes only

II.A.17 Waste Water Treatment
For informational purposes only

II.A.18 Cooling Tower
Rating: 250 Gal/min
Controls: High Efficiency Drift Eliminator

II.A.19 Four (4) HVAC units
Rating: 10 MMBtu/hr each
Fuel: Natural Gas

II.A.20 Two (2) Storage Tanks
Storage Tank one (1)
Capacity: 7,000 gallons
Contents: Diesel Fuel

Storage Tank two (2)
Capacity: 150 Gallons
Contents: Gasoline
MACT Applicability: Subpart CCCCCC

II.A.21 Four (4) Blow off Tables

II.A.22 Four (4) Dust Collectors
Controls emissions from blow off tables

5
11.A.23 Miscellaneous Combustion Equipment
Rating: <5MMBtu/hr
*Included for informational purposes only
Status: In Compliance. According to DAQC-CI18290001-23, Detroit Diesel
Remanufacturing had submitted an NOI in 2020 to include three thermal cleaning ovens
and two drying ovens carried over from their Kansas Facility. However, the equipment was
not reflected in AO DAQE-AN118290014-20, dated December 24, 2020. There are six
thermal cleaning ovens in AO Condition II.A.11. Both storage tanks in AO Condition
II.A. 20, contain diesel. One of the paint booths in AO Condition II.A.12 is used as a storage.
The steel shot blaster in AO Condition II.A.8 has been removed from the site. There are five
(5) dust collectors in AO Condition II.A.22.

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Detroit Diesel Remanufacturing, LLC shall be subject to the following:

II.B.l.a Unless otherwise specified in this AO, the owner/operator shall not allow visible
emissions from any stationary or fugitive emission source on site to exceed 10% opacity.
[R307-401-8]

II.B.l.a.1 Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. [R307-201-3]

Status: In Compliance. There were no visible emissions observed during this
inspection from any stationary point. The opacity observations were conducted
according to 40 CFR 60, Appendix A, Method 9.

II.B.l.b The owner/operator shall use only natural gas as a primary fuel and propane as a backup
fuel in the building space/process heating. Appropriate fuels may be used in equipment
being tested and in small auxiliary mobile equipment associated with the facility.
[R307-401-8(1)(a)]

Status: In Compliance. Detroit Diesel Remanufacturing acknowledge that only
natural gas is used as a primary fuel, and propane as a backup fuel in the building
space/process heating.

II.B.l.c The owner/operator shall not exceed the following site-wide fuel limitations per rolling
12-month period:

A. Natural gas - 40 MMscf

B. Propane -10,000 gallons
[R307-401-8]

6
II.B.1.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall
calculate a new 12-month total by the 20th 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. The Consumption shall be determined by billing statements from a utility
company. The records of Billing statements shall be kept on a monthly basis.
[R307-401-8]

Status: In Compliance. The natural gas and propane consumption in a rolling
12-month period from June 2023 to May 2024, indicated the following:

A. Natural gas - 36.17 MMscf

B. Propane - 7,459 gallons
[R307-401-8]

The records of consumption were determined monthly from billing statements and
kept for all periods when the plant is in operation. See the attachment for additional
information.

II.B.l.d The owner/operator shall not emit more than the following from evaporative sources
(painting, printing, coating, and/or cleaning) on site:

15.8 tons per rolling 12-month period of VOCs
1.57 tons per rolling 12-month period of all HAPs combined
[R307-401-8]

11.B.l.d.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 use a mass-balance
method to calculate emissions from evaporative sources. The owner/operator may use the
following equations with applicable units to comply with the mass-balance method:

VOCs=[% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP=[% HAP by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]

11.B.l.d.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs
and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs
reclaimed from the quantities calculated above to provide the monthly total emissions of
VOCs and HAPs.
[R307-401-8]

11.B.1.d.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used

C. The density of each material used

D. The volume of each VOC- and HAP-emitting material used

7
E. The amount of VOCs and the amount of each HAP emitted from each material

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from
each material

G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons)
[R307-401-8]

Status: In Compliance. The VOC and HAP emissions in a rolling 12-month
from June 2023 to May 2024, indicated the following:

1.95 tons per rolling 12-month period of VOCs
0.823 tons per rolling 12-month period of all HAPs combined

Detroit Diesel Remanufacturing used a mass-balance method to calculate emissions
from evaporative sources. See the attachment for additional information.

11.B.1.e The owner/operator shall cover solvent tanks when not in use. [R307-401-8]

Status: In Compliance. The solvent tanks were closed during this inspection. See
the attachment for additional information.

II.B.1.f The owner/operator shall conduct all degreasing operations in accordance with the
requirements of R307-335. [R307-335]

Status: In Compliance. The degreasers were closed when not in operation.

II.B.1.g The paint spray booths shall be equipped with a set of paint arrestor particulate filters, or
equivalent, to control particulate emissions. Air exiting the booths shall pass through this
control system before being vented to the atmosphere (outside building/operation).
[R307-401-8]

Status: In Compliance. There are two sprays booths equipped with a set of paint
arrestor particulate filters, however, only one of the spray booths is currently in use.
The other spray booth serves as storage. Air exiting the operating booth is routed
through the particulate filters prior to being vented into the atmosphere. See the
attachment for additional information.

II.B.1.h The owner/operator shall install all fuel storage tanks with submerged fill pipes. The
owner/operator shall operate the storage tanks in a way that minimizes working and
breathing losses from the tank. [R307-401-8]

Status: Not applicable. Both storage tanks hold diesel fuel, and are not required to
have submerged fill pipes.

8
II.B.2 All blaster cleaners on site shall be subject to the following:

II.B.2.a The owner/operator shall control particulate emissions with the applicable dust collection
equipment indicated in the equipment list at all times when blasting is taking place.
[R307-401]

Status: In Compliance. The two tumble blasters in AO Condition II.A.7 vent to an
internal dust collector. The steel shot blaster in AO Condition II.A.8 has been
removed, and is no longer onsite.

II.B.3 All engine test cells on site shall be subject to the following:

II.B.3.a The approved engine test cells shall consist of four (4) 600 hp Dyna engines and two (2)
4,000 hp Dyno engines. Only one (1) of the 4,000 hp Dyno engines shall run at any one
time. [R307-401]

Status: In Compliance. Detroit Diesel Remanufacturing runs only one of the 4,000
hp Dyno engines at any time.

II.B.3.b The owner/operator shall use #1, #2 or a combination of #l and #2 diesel fuel as fuel in
the engine test cells. [R307-401]

Status: In Compliance. Detroit Diesel Remanufacturing uses diesel fuel in the engine
test cells. See the invoice for diesel in the attachment.

II.B.3.c The owner/operator shall not exceed the following diesel fuel limitations for engine
testing per rolling 12-month period:

A. 600 hp engines - 47,000 gallons (combined)

B. 4,000 hp engines - 100,000 gallons(combined)
[R307-401-8]

11.B.3.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall
calculate a new 12-month total by the 20th of each month using data from the previous 12
months. Fuel consumption for the engine test cells shall be determined by the use of
operations records. [R307-401-8]

Status: In Compliance. The diesel usage in a rolling 12-month from June 2023 to
May 2024, indicated the following:

A. 600 hp engines -7,879.20 gallons (combined)

B. 4,000 hp engines - 93.31 gallons (combined)
[R307-401-8]

Fuel consumption is determined from the operations records. See the attachment
for additional information.

9
11.B.3.d The owner/operator shall not allow visible emissions from any stationary engine on site
To exceed 20% opacity. [R307-201]
Status: In Compliance. There were no visible emissions observed during this inspection from any stationary engine. See the attachment for additional information.

11.B.4 All thermal cleaning ovens on site shall be subject to the following:

11.B.4.a The thermal cleaning ovens shall operate up to a temperature of 1, 100°F as needed. Each
Oven shall be equipped with an afterburner. The operating temperature of the afterburner
shall be no less than 1,400°F. Each afterburner shall operate whenever parts are being
baked. [R307-401]

11.B.4.a.1 The temperatures cited in the above condition shall be monitored on all three (3) ovens
With equipment located such that an inspector can, at any time, safely read the output.
All readings shall be accurate to within plus or minus l 5°F. All instruments shall be
calibrated against the manufacturer's specification at least once every 12-month period.
[R307-401]

Status: In Compliance. The ovens are equipped with temperature monitors for the
oven and the afterburners. During this inspection, the middle bake oven
temperature indicated 1,047 °F, the afterburner temperature indicated 1,552
°F, the south bake oven temperature indicated 1,049 °F, and the afterburner
temperature indicated 1,567 °F. See the attachments for additional information.

Calibration: There are six ovens in total. The two large ovens were calibrated on
January 25, 2023, the small oven was calibrated on June 20, 2023, and the three
other ovens were calibrated on January 25, 2023. See the attachment for additional
information.

11.B.5 The Proceco parts washer shall be subject to the following:

11.B.5.a The Proceco parts washer shall not exceed an operating temperature of 210°F.
[R307-401-8]

11.B.5.a.1 The temperatures cited in the above condition shall be monitored with equipment located
Such that an inspector or operator can, at any time, safely read the output. All readings
shall be accurate to within plus or minus l 5°F. All instruments shall be calibrated against
the manufacturer's specification at least once every 12-month period. [R307-401]

Status: Compliance undetermined. According to Detroit Diesel Manufacturing, the
Proceco parts washer has not been in operation since 2020, and consequently, no
calibration has been performed.

10
11.B.6 Cooling Tower Requirements

11.B.6.a The owner/operator shall install and operate high efficiency drift eliminators to control
particulate matter from the cooling tower. [R307-401-8]

Status: In Compliance. According to Detroit Diesel Remanufacturing, the cooling
tower is equipped with a high efficiency drift eliminators to control particulate
matter from the cooling tower.

11.B.7 Dust Collector Requirements

11.B.7.a The owner/operator shall route all emissions from the blowoff tables to a baghouse or
Dust collector. [R307-401-8]

Status: In Compliance. All emissions from the blowoff tables are routed to a
baghouse or dust collector before being vented to the atmosphere.

11.B.7.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure
the static pressure drop across each baghouse system. Each Baghouse system shall
operate within the static pressure range recommended by the manufacturer for normal
operations. [R307-401-8]

11.B.7.b.l The owner/operator shall record the static pressure drop readings at least once daily,
while the baghouse is operating. Records shall be kept in a log and shall include the
following:

A. Unit identification;
B. Manufacturer recommended static pressure drop for the unit;
C. Daily static pressure drop readings; and
D. Date of last bag replacement
[R307-401-8]

11.B.7.b.2 The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. [R307-401-8]

Status: In Compliance. During this inspection, the double table manometer
indicated 0.8 inches of water column, the spin hanger indicated 2.0 inches of water
column, and the glass beader indicated 1.0 inches of water column. See the
attachment for additional information on the pressure gauge readings.

11.B.7.b.3 The pressure gauges shall be calibrated in accordance with the manufacturer's
instructions or recommendations or replaced at least once every 12 months.
Documentation of calibrations shall be maintained. [R307-401-8]

Status: In Compliance. The next calibration for the pressure gauges is due on
October 17, 2024. See photos of the gauges in the attachment for additional
information.

11
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)-CCCCCC : National Emission Standards for Hazardous Air Pollutants for Source Category:
Gasoline Dispensing Facilities

Status: Not applicable. Both storage tanks hold diesel and are not required to have submerged fill pipes.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-203: Sulfur Content of Fuels -Emission Standards

Status: In Compliance. According to an invoice from Rhinehart Oil, the sulfur content is
characterized as ultra low sulfur. See the attachment for additional information.

R307-304 - Solvent Cleaning

Status: Exemption. Detroit Diesel Remanufacturing is claiming exemption R307-304-3(1), which
states that the requirements of R307-304 do not apply to the operations that are subject to R307-342
through R307-347, and R307-349 through R307-355.

R307-305: Nonattainment and Maintenance Areas for PM10: Emission Standards

Status: In Compliance. There were no visible emissions observed during this inspection. See the
attachment for additional information.

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

Status: In Compliance. There were no open containers containing VOCs observed during this
inspection.

R307-335: Degreasing

Status: In Compliance. The degreasers were closed during this inspection. See the attachment for
additional information.

R307-350 - Miscellaneous Metal Parts and Products Coatings

Status: In Compliance. There are two sprays booths equipped with a set of paint arrestor particulate
filters, however, only one of the spray booths is currently in use. The other spray booth serves as
storage. Detroit Diesel Remanufacturing is claiming the R307-350-3(1) exemption for the use of
aerosol coating products. Other coatings used are categorized either as General One Component Air
Dryed or General Multi-Component (Air Dryed). See the attached coatings spreadsheet for
additional information. The SDSs and technical data sheets reviewed indicated compliance with
Table 1 of R307-350-5(1) limits.

12
EMISSION INVENTORY: Not applicable. Detroit Diesel Remanufacturing is not required to submit an Emissions Inventory Report at this time.

The emissions listed below are an estimate of the total potential emissions (PTE) from Detroit
Remanufacturing LLC - Engine Maintenance Facility on the Approval Order (AO)
DAQE-AN118290014-20, dated December 24, 2020. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 10798.00
Carbon Monoxide 10.58
Nitrogen Oxides 38.19
Particulate Matter - PM10 6.12
Particulate Matter - PM2.5 6.12
Sulfur Dioxide 1.09
Volatile Organic Compounds 17.06

Hazardous Air Pollutant PTE lbs/yr
Total HAPs (CAS #THAPS) 1.75

PREVIOUS ENFORCEMENT CA (DAQC-566-22) for exceeding the natural gas limit.
ACTIONS: No Further Action Letter (DAQC-1164-22) resolving the CA.

COMPLIANCE STATUS &
RECOMMENDATIONS: Detroit Diesel Remanufacturing is in compliance with the
conditions of Approval Order (AO)-DAQE-AN118290014-20,
dated December 24, 2020. Detroit Diesel Remanufacturing
maintains good housekeeping practices.
HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Look for Administrative Amendment from NSR. Required PPE
includes safety glasses and steel-toe boots.

NSR RECOMMENDATIONS: According to DAQC-CI18290001-23, Detroit Diesel had
submitted an NOI in 2020 to include three thermal cleaning
ovens and two drying ovens carried over from their Kansas
Facility. However, the equipment was not reflected in AO
DAQE-AN118290014-20, dated December 24, 2020. There are
six thermal cleaning ovens in AO Condition II.A.11.

13
Both storage tanks in AO Condition II.A.20, now contain
diesel, therefore, they are no longer applicable to MACT
(Part 63) – CCCCCC, and to AO Condition II.B.1.h.

The steel shot blaster in AO Condition II.A.8 has been removed
from the site.

There are five (5) dust collectors in AO Condition II.A.22.

ATTACHMENTS: Applicable supporting documentation included