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Home My WebLink AboutDAQ-2024-0120831 DAQC-CI141780002-24 Site ID 14178 (B1) MEMORANDUM TO: FILE – OWENS CORNING INSULATING SYSTEMS, LLC – Fiberglass Manufacturing Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jordan Garahana, Environmental Scientist DATE: December 10, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Juab County INSPECTION DATE: August 22, 2024 SOURCE LOCATION: 2762 South Main Nephi, UT 84648 DIRECTIONS: From south bound I-15, take exit222 to Nephi and then continue traveling south bound on UT 28/I4ain Street to the large plant located just outside of the city. SOURCE CONTACTS: Stefan Messmer, EHS Leader 618-713-3192 stefan.messmer@owenscorning.com OPERATING STATUS: Operating normally at the time of inspection PROCESS DESCRIPTION: Raw materials such as sand, soda ash, dolomite and borax are transported in from off site. The materials are pneumatically loaded into storage silos located in the Batch House. The materials are mixed and melted in electrically powered equipment. The molten glass is captured by an electric Fore Hearth with feeds the glass into one of the fiberizers. The fiberizers rotary spin the molten glass into wool fiberglass insulation. Currently, all fibers are considered to be an "unbounded" product which do not involve the application of chemicals. Bundles of rotary spun fiberglass are bagged and distributed as blow-in insulation. Bounded product lines may be manufactured at this site sometime after the first quarter of 2023 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN141780007-22, dated October 6, 2022 * - ) - # ) 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Owens Corning Insulating Systems, LLC - Fiberglass Manufacturing Facility One Owens Corning Parkway 2762 South Main Toledo, OH 43659 Nephi, UT 84648 SIC Code: 3296: (Mineral Wool) 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] 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: Out of Compliance. No notification has currently been made about the operational status of the equipment listed within this experimental AO. An initial stack test has been conducted on this equipment, but that does not meet the notification requirement for this condition. The source was notified at the time of inspection about notification requirements for any future AO modifications going forward. No further action is currently recommended. See the 2024 inspection memo for information regarding the 2023 Emission Inventory submitted by Owens Corning. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Fiberglass Manufacturing Facility Bio-Oxidation II.A.2 Wet Scrubber - STK-11 Wet Column Scrubber: Bonded Line Curing Oven (19.4 MMBtu/hr, ULNB) Maximum Air Flowrate: 26,250 scfm Maximum Liquid Recirculation Flowrate: 400 gal/min Status: In Compliance. The equipment listed here was onsite and operational at the time of inspection. II.B Requirements and Limitations II.B.1 EAO Requirements II.B.1.a The owner/operator shall record the wet scrubber temperature and scrubber outlet water pH during operation of the bio-oxidation system. The owner/operator shall quantify and record that the permitted reduction in VOC emissions is achieved. This demonstration will be made through a stack testing event within the initial 12-month period. The VOC emissions reduction testing shall use one of the following test methods, 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401] Status: In Compliance. An initial stack test on STK-11 was conducted on February 27, 2024. The destruction efficiency on the bio-oxidation scrubber was determined to be 86.9% ppmvd and 82.0% lb/hr from that stack test. The method utilized was Method 25A. For more information regarding the results of the stack test, see DAQC-398-24 for additional information. II.B.1.a.1 Records of wet scrubber temperature and scrubber outlet water pH shall be kept for all periods when the bio-oxidation system is in operation. Wet scrubber temperature and scrubber outlet water pH readings shall be conducted once per operational shift and recorded in an operation log. [R307-401] Status: In Compliance. Records of the wet scrubber pH and temperature are recorded as the bio-oxidation system is operating. They are recorded electronically and stored electronically. This was viewed onsite at the time of inspection. II.B.1.b Upon conclusion of the initial 12-month operating period for the bio-oxidation system, a final report will be prepared that details the parametric monitoring conducted and results of stack testing. This report will be submitted within 90 days of the initial 12-month period. Additional operation of the equipment listed in this EAO shall be addressed through an NOI for new equipment, submitted pursuant to UAC R307-401. The final report shall be submitted to the Director, attention NSR Section. [R307-401] Status: Compliance Not Determined. A report of the results of the initial 12-month period has not been made yet. The results of the initial stack test of the bio-oxidation scrubber were made in 2024. See DAQC-398-24 for information regarding the stack test. The source is currently undergoing the NOI process to receive a new AO based upon a self-report of two unapproved generators onsite. 4 II.B.1.c This EAO does not give approval to violate any conditions or limitations of OCIS's AO DAQE-AN14178006-22. [R307-401] Status: Out of Compliance. The source operated two unapproved generators onsite. Owens Corning self-reported those two generators and submitted an NOI to include those generators as part of a new AO for DAQE-AN14178006-22. No further action is currently recommended. 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. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided from Owens Corning Insulating Systems, LLC - Fiberglass Manufacturing Facility. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN141780007-22, dated October 6, 2022, is provided. The 2023 Emission Inventory for the main AO, DAQE-AN141780006-22, can be found in the 2024 inspection memo for this facility. See that memo for additional information. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Volatile Organic Compounds 0.00 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr PREVIOUS ENFORCEMENT ACTIONS: This is the initial inspection for this experimental AO. These are the previous enforcement actions for this facility for their main AO: A CAN for exceeding scrubber limits was issued on August 8, 2018 (DAQC-1037-18), and was resolved with a Warning Letter dated September 19, 2018 (DAQC-2097-18). A CAN for exceeding the opacity limit was issued on April 28, 2017 (DAQC-546-17), and was resolved with a Warning Letter dated May 31, 2017 (DAQC-677-17). COMPLIANCE STATUS & RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN141780007-22, dated October 6, 2022, the overall status is: Out of Compliance. Out of compliance with conditions I.8 and II.B.1.c of this AO. Source has two unapproved generators onsite. Source self-reported those generators and filed an NOI to include those generators in a new permit. The source has not submitted a notification regarding the operational status of the equipment in this AO. No further action is currently recommended. 5 Compliance not determined with condition II.B.1.b of the AO as the source has not submitted a report on the bio-oxidation from the initial 12-month startup period. The bio-oxidation unit was stack tested in 2024. In compliance with the rest of the conditions listed within this experimental AO. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Check to see if the source has filed the report on the bio-oxidation system required in condition II.B.1.b of this AO. NSR RECOMMENDATIONS: None at this time ATTACHMENTS: None