DAQ-2025-000007

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DAQC-174-24
Site ID 10594 (B1)

MEMORANDUM

TO: FILE – QUALITY PLATING COMPANY

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: December 18, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County, NESHAP N
Source
INSPECTION DATE: February 8, 2024

SOURCE LOCATION: 420 South 500 West, Salt Lake City, UT 84101

SOURCE CONTACT(S): Glenn Fassmann – President - 801-355-7424 ext. 2
[e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: Conducts various plating operations, including hard chrome,
anodizing chrome, and decorative chrome plating. In addition,
black oxide, brass plating, cadmium plating, copper plating, gold
plating, manganese plating, nickel plating, electrolyze nickel
plating, silver plating, sulfuric anodizing, tin plating, tin-lead
plating, and zinc plating. Each process has associated tanks for
cleaning, etching, rinsing, and dyeing, and specific steps unique
with the individual coating process requirements. The source is
categorized as a small existing source, maintaining actual
cumulative rectifier capacity less than 60 million amp-hr/yr by
operating less than 6,240 hours per year. A composite mesh pad
is utilized as a control device for the hard chrome electroplating
operations.

APPLICABLE REGULATIONS: Approval Order DAQE-080-97, dated January 30, 1997

NESHAP (Part 63), N: National Emission Standards for
Chromium Emissions From Hard and Decorative Chromium
Electroplating and Chromium Anodizing Tanks

SOURCE EVALUATION:

General Conditions:

1. This AO applies to the following company:
* - ) - # )
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Facility Location
Quality Plating Company
533 West 400 South
Salt Lake City, UT 84101
Telephone: [phone]
Facsimile: [phone]

The equipment listed below in this AO shall be operated at the following location:

PLANT LOCATION:

Universal Transverse Mercator (UTM) Coordinate System:
4,512.4 kilometers Northing; 423.5 kilometers Easting; Zone 12

Status: In Compliance. Source location information is correct with the exception of the
address, which is now 420 South 500 West due to the closing of the entrance on 400
South.

2. Definitions of terms, abbreviations, and references used in this AO conform to those used
in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of
Federal Regulations (40 CFR). These definitions take precedence unless specifically
defined otherwise herein.

3. Quality Plating Company shall install and operate the electroplating operation and control
system according to the terms and conditions of this AO as requested in the Notice of
Intent dated October 27, 1995 and additional information submitted to the Executive
Secretary dated November 1, 1996.

Status: In Compliance. The source was familiar with the terms and conditions of the AO.

4. A copy of this AO shall be posted on site. The AO shall be available to the employees
who operate the air emission producing equipment. These employees shall receive
proper instruction as to their responsibilities in operating the equipment according to all
of the relevant conditions listed below.

Status: In Compliance. The AO is kept in a binder in the main office.

5. The approved installations shall consist of the following equipment or equivalent*:

A. Hard Chromium Electroplating Tanks Controlled by fume suppressants and high
efficiency mist eliminators

Electroplating Tanks (Hard Chrome)
Amount: 3
Surface Area: 45 square feet
Rectifier Capacity: >60 million amperes/year
1) Mist Eliminator Manufacturer: Munters* Type: Stainless Steel Baffle Model: T-271
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Size: (inches) 26.8x36x6.4
Efficiency: Not rated

2) Pre-Filter Units
Manufacturer: FARR*
Type: Stainless Steel
Model: S4S4 20H 10W
Size: (inches) 24x24x2
Efficiency: 87.8% on 5 - 10 micron particles

3) Secondary Filter Units
Manufacturer: FARR*
Type: Reinforced cotton and synthetic
Model: 30/30
Size: (inches) 24x24x2
Efficiency: 99.97% on 0.3 micron particles

4) Secondary Filter Units
Manufacturer: FARR*
Type: RIGA-FLO Rigid disposable air filter unit
Model: RIGA-FLO 200
Size: (inches) 24x24x12
Efficiency: 99 on 1.0 micron particles

5) Final Filter Unit
Manufacturer: ECO AIR*
Type: HEPA
Model: ALPHA 2000
Size: (inches) 24x24x12
Efficiency: 99.97% on 0.3 micron particles

B. Electroplating Tank (Decorative Chrome)
Amount: 1
Surface Area: 18 square feet
Control Method: Chemical fume suppressant

C. Chrome Anodizing Tank
Amount: 1
Surface Area: 12 square feet
Control Method: Chemical fume suppressant

D. Natural as Boiler
Manufacturer: Superior Boiler*
Burner: Aztec Burner
Model: 5-5-75L
Serial: 11590
Rating 5175 lb/hr steam (appx. 5.0 mmbtu/hr)

E. Natural Gas Heaters Heating Capacity: <5.0 x 106 BTU/hr

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F. Process Tanks
Black Oxide Tanks Gold Plating Tanks
Phosphating Tanks Copper Plating Tanks
Chemical Conversion Coating Tanks Tin Plating Tanks
Cadmium Plating Tanks Electroless Nickel Plating
Zinc Plating Tanks Silver Plating
Nickel Plating Tin-Lead Plating
Sulfuric Acid Anodizing Sulfuric Acid Anodizing
Brass Plating Manganese Plating
Dow #7 Coating

G. Support operations consisting of wet lab with fume hoods, waste water
pretreatment plant, forklifts, etc.

* Equivalency shall be determined by the Executive Secretary.

Any future changes or modifications to the equipment and processes approved by this
AO that could effect the emissions covered by this AO must be approved in accordance
with R307-1-3.1.1, UAC.

Status: In Compliance. The equipment list was reviewed with the site President. No new
equipment has been installed since the 2017 inspection. Additional clarifying
information carried over from the previous inspection:

5.A – There are only two Electroplating Tanks installed.

5.A 1) through 5) – The filtration units associated with the Hard Chrome tanks are
located outside.

There is still the Grieve-brand Heat Treating Oven onsite that operates on
electricity.

R307-1-3.1.1, UAC has been superseded by UAC R307-401-1.

6. The following items are recognized to be at the Quality Plating. A permit is not
necessary for their operation due to installation prior to November 29, 1969:

A. Glass bead blasting cabinet
B. Stroke sander, polishing lathes, and timesaver
C. Paint booth

Status: In Compliance. The source still operates the pre-1969 equipment referenced in this
condition. No additional equipment has been added.

7. The Executive Secretary shall be notified in writing upon start-up of the installation, as
an initial compliance inspection is required. Eighteen months from the date of this AO
the Executive Secretary shall be notified in writing of the status of
construction/installation if construction/installation is not completed. At that time the
Executive Secretary shall require documentation of the continuous
construction/installation of the operation and may revoke the AO in accordance with
R307-1-3.1.5, UAC. If construction is complete and operation has commenced a notice
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is not required on the status of the construction/installation.

Status: Compliance status not determined. Previous inspections have stated that the
Installation Notification could not be found in the source file. This source has been
inspected every three to five years since the Approval Order was issued in 1997.
This operation has reportedly been in operation at this location since the 1950s. No
further compliance action is recommended.

R307-1-3.1.5, UAC has been superseded by R307-401-18.

Limitations and Tests Procedures

8. Emissions to the atmosphere from the indicated emission point(s) shall not exceed the
following rates and concentrations:

Source: Electroplating Stack

Pollutant grains/dscf
(68F, 29.92 in Hg)

Chromium (total) ......... ...................................... 6.6 x 10-6 (0.015mg/dscm)

Status: In Compliance. The test, conducted on July 11, 1997, indicated that emissions from
the Electroplating Stack were recorded at 0.00107 mg/dscm for runs 1 and 2 and
0.00093 mg/dscm for run 3. Additional information can be found in DAQH-1437-
1997.

9. Stack testing to show compliance with the emission limitations stated in the above
condition shall be performed as specified below:

A. Testing Test
Emissions Point Pollutant Status Frequency

Electroplating stack Chromium ........... * ..............@

B. Testing Status (To be applied above)

* An initial performance test is required to satisfy the NESHAP
requirement listed on 40 CFR 63.343(b)(1). The initial test date shall be
within 180 days of the January 25, 1997 compliance date.

@ Test if directed by the Executive Secretary. Tests may be required if the
source is suspected to be in violation with other conditions of this AO.

C. Notification

The applicant shall provide a notification of the test date at least 45 days before
the test. A pretest conference shall be held if directed by the Executive
Secretary. It shall be held at least 30 days before the test between the
owner/operator, the tester, and the Executive Secretary. The emission point shall
be designed to conform to the requirements of 40 CFR 60, Appendix A, Method
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1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.

D. Sample Location

40 CFR 60. Appendix A, Method 1

E. Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2

F. Chromium

40 CFR 63, Appendix A, Method 306 or 306A as appropriate

G. Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the
Executive Secretary to give the results in the specified units of the emission
limitation.

H. New Source Operation

For a new source/emission point, the production rate during all compliance
testing shall be no less than 90% of the production rate listed in this AO. If the
maximum AO allowable production rate has not been achieved at the time of the
test, the following procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to
date.

2) If the test is passed, the new maximum allowable production rate shall be
110% of the tested achieved rate. This new allowable maximum
production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when
necessary. Testing at no less than 90% of the higher rate shall be
conducted. A new maximum production rate (110% of the new rate) will
then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved.

I. Existing Source Operation

For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

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Status: In Compliance. The Electroplating Stack test pollutant limits were in compliance at
the time of stack testing on July 11, 1997. To date, the Executive Director has not
required retesting of the stack.

10. A chemical fume suppressant containing a wetting agent shall be used during decorative
chrome plating and chrome anodizing activities. The surface tension of the electroplating
or anodizing bath contained within the affected source shall not exceed 45 dynes per
centimeter (dynes/cm) (3.1 x 10-3 pound-force per foot [lbf/ft]) at any time during
operation of the tank. Monitoring of the surface tension will be in accordance with 40
CFR 63.343(c)(5). The surface tension must be monitored a minimum of once every 40
hours of tank operation.

Status: In Compliance. The source uses wetting agents during decorative chrome plating
and chrome anodizing activities. Surface tension is tested weekly using a
stalagmometer. Submitted records state that the current chemical fume
suppressant is Haviland Havachrome Mist Eliminator III. The tanks are tested at
least once for every 40 hours of tank operation. The Fume Suppressant Record log
for the 2023 calendar year and January of 2024 also indicates that the tanks are
tested regularly and at least once for every 40 hours of operation, last being tested
on February 8, 2024. T-1 has not been in operation since August 3, 2023. The
surface tension of each tank was measured below 40 dynes on that date. Dyne
measurements were as follows:

The Chromic Acid Anodizing tank 35.1
The Decorative Chrome tank 34.1
Tank T-1 Hard Chrome 34.8 on August 3, 2023
Tank T-2 Hard Chrome 34.1

For additional information, see the attachments section for a copy of the Fume
Suppressant log for 2023/2024.

11. Work practice standards. The work practice standards of this section address operation
and maintenance practices. All owners or operators subject to the standards in this section
are subject to these work practice standards.

A. At all times, including periods of startup, shutdown, and malfunction, owners or
operators shall operate and maintain any affected source, including associated air
pollution control devices and monitoring equipment, in a manner consistent with
good air pollution control practices, consistent with the operation and
maintenance plan.

B. Malfunctions shall be corrected as soon as practicable after their occurrence in
accordance with the operation and maintenance plan.

Status: In Compliance. The required emission control systems and chemical suppressant
methods were being used. The source indicated there have been no malfunctions
since the previous compliance inspection.

12. With the exception of boiler stack, visible emissions from any stationary point or fugitive
emission source associated with the plating process or with the control facilities shall not
exceed 20% opacity. Visible emissions from boiler stack shall not exceed 10% opacity.
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Opacity observations of emissions from stationary sources shall be conducted in
accordance with 40 CFR 60, Appendix A, Method 9.

Status: In Compliance. No visible emissions are possible from the permitted tanks or from
the natural gas boiler stack. The non-visible emissions from the tanks are controlled
by filter units and a mist eliminator.

13. The following production limits shall not be exceeded without prior approval in accordance
with R307-1-3.1, UAC:

6240 hours per rolling 12-month period for hard chrome electroplating tanks

Compliance with the annual limitations shall be determined on a rolling 12-month total.
The owner/operator shall calculate a new 12-month total based on the first day of each
month using data from the previous 12 months. Records of production shall be kept for
all periods when the plant is in operation. Records of production, including rolling 12-
month totals shall be made available to the Executive Secretary or executive secretaries
representative upon request and shall include a period of two years ending with the date
of the request. The records shall be kept on a daily basis. Hours of operation for the
chromium electroplating plating tanks shall be determined by supervisor monitoring and
maintaining of an operations log.

Status: In Compliance. The submitted record stated that the combined hard chrome tank
hours for the period of February 2023 through January 2024 were 3,007 hours.
Rolling 12-month hours for this time period for each tank were reported as follows:

Tank #1 – 741 hours
Tank #2 – 2,266 hours
Tank #3 – 0. This tank has been out of service since 2009.

See the attachments section for additional details about the tank operation hours.

R307-1-3.1, UAC has been superseded by R307-401.

Fuels

14. The owner/operator shall use only natural gas as fuel for the boiler. If any other fuel is to
be used, an AO shall be required in accordance with R307-1-3.1, UAC. Natural gas
usage must be monitored and recorded on a monthly basis. Records of natural gas
consumption for the boiler and for the heating system, including rolling 12-month totals
shall be made available to the Executive Secretary or executive secretaries representative
upon request and shall include a period of two years ending with the date of the request.

Status: In Compliance. The source confirmed that only natural gas is used as fuel for the
boiler. Questar gas bills are maintained on-site and an invoice was viewed onsite.

R307-1-3.1, UAC has been superseded by R307-401.

Federal Limitations and Requirements

15. In addition to the requirements of this AO, all provisions of 40 CFR 63, National
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Emission Standards for Hazardous Air Pollutants (NESHAP)1, 40 CFR 63.340 to 63.347
(National Emission Standards for Chromium Emissions from Hard and Decorative
Chromium Electroplating and Chromium Anodizing Tanks) apply to this installation. A
copy of the latest 40 CFR 63.7 and 40 CFR 63.340-347, dated January 25, 1995, is
attached to this document as Appendix A. However, to be in compliance, this facility
must operate in accordance with the most current version of 40 CFR 63.

Status: In Compliance. See status of Condition 10 of this AO and the Applicable Federal
Requirements - NESHAP (Part 63), N: National Emission Standards for Chromium
Emissions From Hard and Decorative Chromium Electroplating and Chromium
Anodizing Tanks’ for full rule evaluation.

16. The owner/operator shall prepare an Operation and Maintenance Plan in accordance with
40 CFR 63.342(f)(3). Recordkeeping associated with this plan is identified in 40 CFR
63.346(b). Reporting associated with this plan is identified in 40 CFR 63.347 (g) and (h)
and in 40 CFR 63.342(f)(3)(iv).

Status: In Compliance. The Operation and Maintenance (O&M) Plan has not been revised
since the March 14, 2017, inspection. All records are kept and submitted as
required. See the attached Fume Suppressant Records, Scrubber Records and VOC
rolling 12-month records.

Volatile Organic Compound (VOC)

17. The paint spray booth shall be equipped with particulate filters to control particulate
emissions. All air exiting the booth shall pass through this control system before being
vented to the atmosphere.

Status: In Compliance. Particulate filters in the paint spray booth were observed at the
time of inspection. All air exiting the booth passes through the filters before being
vented out of the building.

18. The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact
cement applicators, etc. and associated operations shall not exceed:

3.47 tons per rolling 12-month period for VOCs

This value shall not be exceeded without prior approval in accordance with R307-1-3.1,
UAC. Compliance with the limitation shall be determined on a rolling 12-month total.

Based on the first day of each month a new 12-month total shall be calculated using data
from the previous 12 months.

The plant-wide emissions of VOCs emitted to the atmosphere shall be determined by
maintaining a record of VOC potential contained in materials used each month. The record
shall include the following data for each item used:

A. Name of the VOC emitting material, such as: paint, adhesive, solvent, thinner,

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reducers, chemical compounds, etc.

B. The weight and use location of the VOC potential and HAP potential of the
material(s) listed in A in pounds per gallon.

C. Percent by weight of all VOC potential and HAP potential for each individual
material listed in A. The percent by weight of the VOC and HAP potentials can
be obtained from the manufacturers' MSDSs. The owner/operator can obtain
MSDS data from the manufacturers of the materials and retain the information
on-site.

D. Amount and location of materials containing VOCs and HAPs used on a monthly
basis and summed for every location and for the entire plant each month.

E. To calculate the above potentials contained in the material listed in D use the
following procedure:
VOC = % Volatile by Weight x [Density ( lb )] x Gal Consumed x 1 ton
(100) (gal) 2000 lb

F. The amount of VOC content potential (potential air emissions) and HAP
potential (potential air emissions) in pounds contained in materials deposited as
solid or hazardous waste for the month shall be quantified and subtracted from
the quantities calculated above. This is done to allow quantification by the
source of the total VOCs and HAPs emissions. (The assumption is that all the
two above potentials of the materials applied to a product evaporate and are
therefore considered emissions).

G. VOC emissions from other operations:

Boiler - 0.13 tons/yr

H. Records of consumption of VOCs and HAPs shall be kept for all periods when
the plant is in operation. Records of consumption shall be made available to the
Executive Secretary upon request, and shall include a period of two years ending
with the date of the request.

Status: In Compliance. The requirements of this condition were reviewed at the time of
inspection. VOC emissions for the rolling 12-month period from February 2023 – January 2024 are as follows:
VOCs – 0.58 tons See attached VOC Worksheet for additional information. R307-1-3.1, UAC has been superseded by R307-401.
19. All HAPs are subject to the annual Operating Permit Program if one of the following
conditions is met:

A. The emissions of any one of the 189 HAPs listed in the 1990 Clean Air Act is
over 10 tons/yr

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B. The emissions of any combination of these HAPs are over 25 tons/yr

Status: In Compliance. The emissions calculations for the AO DAQE-080-97 estimated
total HAPS as 0.92 tons. The previous inspection stated that the source has never
exceeded the limits specified in A. and B. of this condition. The recorded 2005
Emissions Inventory reported that each individual HAPs emission is under 10 tons.

Monitoring - General Process

20. The owner/operator shall install, calibrate, maintain, and operate a monitoring device for
the continuous measurement of the change in pressure of the gas stream through the mist
elimination system. The monitoring device must be certified by the manufacturer. The
monitoring device shall be accurate within plus or minus one half inch of water and must
be calibrated on an annual basis according to the manufacturer's instructions. Continuous
recording for the monitoring device is not required. However, daily records of readings
shall be maintained.

Status: In Compliance. The monitoring device is located on the mist elimination system
which is located outside the building on a northeast corner at approximately the
center of the building. Daily readings for February 2023 through January 2024
were submitted. See the attached Daily Records for Hard Chrome Plating
Department Scrubber.

21. The following operating parameters shall be maintained within the indicated ranges:

A. The pressure drop of the mist elimination system shall not exceed 6.5 inches of
water during operation. The minimum pressure drop across the mist elimination
system shall not fall below 3.0 during times of operation.

They shall be monitored with equipment located such that an inspector/operator can
safely read the output any time. The readings shall be accurate to within 0.5" water
gauge.

All instruments shall be calibrated against a primary standard at least once every 90 days.
The primary standard shall be established by the company and shall be submitted to the
Executive Secretary for approval.

Status: In Compliance. Gauges B, C, D, and E correspond with the individual filter units
referenced in Condition 5.A. 2 through 5. These filter units feed into Gauge A,
which is total pressure drop referenced in this condition. The monitoring device is
located outside of the building on the mist elimination system. Records for
February 2023 through January 2024 indicate the pressure drop ranged from 5.9 to
6.3 for the rolling 12-mont total. See the attached Daily Records for Hard Chrome
Plating Department Scrubber for the referenced rolling 12-month time period.

Records & Miscellaneous

22. All installations and facilities authorized by this AO shall be adequately and properly
maintained. Maintenance records shall be maintained while the plant is in operation. All
pollution control vendor recommended equipment shall be installed, maintained, and
operated. Instructions from the vendor or established maintenance practices that
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maximize pollution control shall be used. All necessary equipment control and operating
devices, such as pressure gauges, amp meters, volt meters, flow rate indicators,
temperature gauges, etc., shall be installed and operated properly and easily accessible to
compliance inspectors. A copy of all manufacturers' operating instructions for pollution
control equipment and pollution emitting equipment shall be kept on site. These
instructions shall be available to all employees who operate the equipment and shall be
made available to compliance inspectors upon their request.

Status: In Compliance. The submitted documents indicate that the tanks and other
permitted equipment are maintained as required.

23. The owner/operator shall comply with R307-1-3.5, UAC. This rule addresses emission
inventory reporting requirements.

Status: In Compliance. A copy of the source’s 2005 emissions inventory is on file and is
referenced in the 2017 Inspection. The source is not currently subject to the
emission inventory program.

R307-1-3.5, UAC has been superseded by R307-107.

24. The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses
unavoidable breakdown reporting requirements. Any breakdown lasting longer than two
hours shall be reported to the Executive Secretary within three hours of the breakdown if
reasonable, but in no case longer than 18 hours after the beginning of the breakdown.
During times other than normal office hours, breakdowns for any period longer than two
hours shall be initially reported to the Environmental Health Emergency Response
Coordinator. Within seven calendar days of the beginning of any breakdown lasting
longer than two hours, a written report shall be submitted to the Executive Secretary.
The owner/operator shall calculate/estimate the excess emissions (amount above AO
limits) whenever a breakdown occurs. The total of excess emissions per calendar year
shall be reported to the Executive Secretary with the inventory submittal, as directed by
the Executive Secretary.

Status: In Compliance. The source indicated there have been no breakdowns that could
produce excess emissions.

R307-1-4.7, UAC has been superseded by R307-107.

25. All records referenced in this AO or in applicable NSPS or NESHAP, which are required
to be kept by the owner/operator, shall be made available to the Executive Secretary or
executive secretaries representative upon request and shall include a period of two years
ending with the date of the request. All records shall be kept for a period of two years.
Examples of records to be kept at this source shall include the following as applicable:

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A. Surface tension of electroplating
and anodizing tanks (Condition number 10)
B. Hours of operation (Condition number 13)
C. Natural gas consumption rates. (Condition number 14)
D. VOC emission Records (Condition number 18)
E. Pressure drop across mist eliminator (Condition number 20)
F. Maintenance records (Condition number 22)
G. Emission inventory (Condition number 23)
H. Upset, breakdown episodes (Condition number 24)

Status: In Compliance. Records are maintained for at least two years. All of the requested
records were submitted upon request.

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.

NESHAP (Part 63), A: General Provisions

Status: In Compliance. Compliance with Part 63 A is satisfied by compliance with Part 63 N.
See status of Part 63 N for additional information.

NESHAP (Part 63), N: National Emission Standards for Chromium Emissions From Hard and Decorative
Chromium Electroplating and Chromium Anodizing Tanks

63.340(a) applies to each tank performing hard chromium electroplating, decorative
chromium electroplating or chromium anodizing
63.340(c) – process tanks associated with these processes (such as rinse tanks, etching
tanks and cleaning tanks) are not subject to these provisions
63.342(a)(1) – must operate and maintain affected source including control equipment
and monitoring equipment in a manner consistent with safety and good control practices
for minimizing emissions.

Status: In Compliance. All of the tanks appear to be maintained and operated as required
based on the submitted records. All of the measurements were within the required
ranges.

63.342(b)(1) – emission limits apply during tank operation and startup/shutdown
63.342(c)(1)(ii) – limit concentration of total chromium in exhaust gas stream to 0.015
mg/dscm for all open surface hard chrome electroplating tanks located at small facilities.

Status: In Compliance. Testing was conducted on July 11, 1997. No additional tests have
been required by the DAQ. See status of conditions 8 and 9 for additional
information.

63.342(c)(1)(iii) – for tanks with chemical fume suppressant containing wetting agent –
limit surface tension of electroplating or anodizing bath to 40 dynes/cm measured by a
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stalagmometer at any time during tank operation.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 10 of the AO. All surface tension measurements have been below 40
dynes.

63.342(c)(1)(v) – after September 21, 2015, cannot add PFOS-based fume suppressant to
any affected open surface hard chromium electroplating tank.

Status: In Compliance. The source is familiar with this requirement and confirmed PFOS-
based fume suppressants use was discontinued several years ago.

63.342(c)(3)(i) – may demonstrate size of a facility through the definitions in 63.341(a).
Large facility has maximum cumulative potential rectifier capacity greater than or equal
to 60 million ampere-hours per year.

Status: In Compliance. The source provided the following calculation during the 2017
compliance inspection (See DAQC-478-17):
total rectifier power = 2 @ 5,000 am + 1 @ 1,000 am = 11,000 amp
total usable rectifier power = 11,000 x 85% = 9,350 amps
60,000,000 amp-hours / 9,350 amps = 6,417 hours
The company President stated that no changes to the cumulative potential rectifier
or any other process has occurred since the January 30, 1997, AO was issued.

Condition 13 of the AO limits operation to 6,240 hours which is below the 6,417
hours needed to reach the 60,000,000 amp-hours/year limit. See status of condition
13 for additional information.

63.342(d)(3) – control emissions from decorative chromium electroplating tanks using
chromic acid bath and chromium anodizing tanks using chemical fume suppressant with
wetting agent – limit surface tension to 40 dynes/cm as measured by a stalagmometer.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 10 of the AO.

63.342(d)(4) – after September 21, 2015, cannot add PFOS-based fume suppressant to
any affected decorative chromium electroplating or anodizing tank.

Status: In Compliance. The source is familiar with this requirement and confirmed PFOS-
based fume suppressants use was discontinued several years ago.

63.342(f)(1)(i) – at all times, including startup, shutdown and malfunction, must operate
and maintain affected source and control devices and monitoring equipment in manner
consistent with good air pollution control practices.

Status: In Compliance. All equipment appeared to be well maintained and operated at the
time of inspection.

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63.342(f)(1)(ii) – correct malfunctions as soon as practicable.

Status: In Compliance. No malfunctions have occurred since the previous compliance
inspection. 63.342(f)(2)(ii) – Based on the results of a determination made under paragraph (f)(2)(i) of this section, the Administrator may require that an owner or operator of an affected source make changes to the operation and maintenance plan required by paragraph (f)(3) of this section for that source.
Status: In Compliance. No changes to the O&M plan have been required since 1998 by the
administrator.

63.342(f)(3)(i) – Operation and maintenance plan: 63.342(f)(3)(i)(A) – specify O&M criteria for the source, add-on air pollution control
device, process and control system monitoring equipment and include standardized
checklist to document operation and maintenance of equipment.
63.342(f)(3)(i)(B) – incorporate O&M practices for the add-on control device or
monitoring equipment identified in Table 1.
63.342(f)(3)(i)(D) – plan shall specify procedures to be followed to ensure that
equipment or process malfunctions due to poor maintenance or other preventable
conditions do not occur. 63.342(f)(3)(i)(E) – plan shall include systematic procedure for
identifying malfunctions of process equipment, add-on control devices, and monitoring
equipment and for implementing corrective actions to address malfunctions
63.342(f)(3)(ii) – revise O&M plan within 45 days if it does not address malfunction
event.
63.342(f)(3)(v) – written O&M plan (and all revisions for 5 years after each revision)
shall be available for inspection for the life of the source.

Status: In Compliance. The O&M plan provided at the time of inspection contains all of
the required information. A copy of the O&M plan was viewed onsite at the time of
inspection.

Table 1 to 63.342 – Summary of Operation and Maintenance Practices.

Status: In Compliance. O&M practices for the composite mesh-pad system was part of the
O&M plan. The maintenance practices are completed each quarter.

Table 2 to 63.342 – Housekeeping Practices

Status: In Compliance. The company maintains an onsite water treatment tank to treat
solution that drains or drips from parts as they are removed from the tank.
Buffing, grinding, or polishing operations are separated from the electroplating or
anodizing operation by a physical barrier. Generated chromium or chromium-
containing wastes are stored, disposed, recovered, or recycled using practices that
do not lead to fugitive dust and in accordance with hazardous waste requirements.

63.343(a)(1) – (a) Compliance dates. (1) The owner or operator of an existing affected
source shall comply with the emission limitations in §63.342 no later than September 19,
2014.

Status: In Compliance. The source has been in compliance with the emissions limitation
since 1997.

16
63.343(a)(8) – after March 19, 2013, the owner or operator of an affected source that is
subject to the standards in 63.342(c) or (d) shall implement the housekeeping procedures
specified in Table 2 of 63.342.

Status: In Compliance. See status of Table 2 above for additional information.

63.343(b)(2) – (b) Methods to demonstrate initial compliance. (1) Except as provided in
paragraphs (b)(2) and (b)(3) of this section, an owner or operator of an affected source
subject to the requirements of this subpart is required to conduct an initial performance
test as required under §63.7, using the procedures and test methods listed in §§63.7 and
63.344.

Status: In Compliance. An initial performance test is not required based on the criteria
listed in b(2)(i through iii). However, conditions 8 and 9 of the AO required a
performance test to be completed. See status of conditions 8 and 9 for additional
information.

63.343(c) – monitoring to demonstrate continuous compliance – dependent on type of
control techniques used:

63.343(c)(1)(i) composite mesh-pad systems – determine outlet chromium concentration
using test methods and procedures in 63.344(c) and establish pressure drop across system
setting the value that corresponds to compliance with the emission limitation.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 21 of the AO. See status of condition 21 for additional information.

63.343(c)(1)(ii) – monitor and record pressure drop across the composite mesh pad
system once a day that the tanks are operating.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 20 of the AO. See status of condition 20 for additional information.

63.343(c)(1)(iii) – The owner or operator of an affected source complying with the
emission limitations in §63.343 through the use of a composite mesh-pad system may
repeat the performance test and establish as a new site-specific operating parameter the
pressure drop across the composite mesh-pad system according to the requirements in
paragraphs (c)(1)(i) or (ii) of this section. To establish a new site-specific operating
parameter for pressure drop, the owner or operator shall satisfy the requirements
specified in paragraphs (c)(1)(iii)(A) through (D) of this section.

Status: In Compliance. The source has not chosen to repeat the performance test. The
established pressure drop remains 6” water column.

63.343(c)(5) – this section pertains to wetting agent-type of control system and requires
surface tension to be measured with a stalagmometer every 4 hours for the first 40 hours
of tank operation. If the tension remains under 40 dynes/cm (no exceedances) then the
frequency can be dropped to every 8 hours of tank operation for 40 hours. If there are no
exceedances, then the frequency is dropped to once a week. Any exceedance would
increase the frequency back to every 4 hours of tank operation. When the bath solution
is drained from the tank and new solution added, monitoring begins every 4 hours again.
17

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 10 of the AO.

63.343(c)(7) – fume suppressant/add-on control device (both).

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 20 of the AO. See status of condition 20 for additional information.

63.344(a) – performance test requirements.

Status: In Compliance. The requirements of this section are satisfied by compliance with
conditions 8 and 9 of the AO. See status of conditions 8 and 9 for additional
information.

63.346 recordkeeping requirements:
63.346(b) – shall maintain following records:
63.346(b)(1 and 2) – inspection records for add on control device and monitoring
equipment to document that inspections and maintenance required by work practice
standards have taken place; can be checklist and should identify device inspection, date
of inspection, brief description of working condition of the device during the inspection,
and any actions taken to correct deficiencies found.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 21 of the AO. See status of condition 21 for additional information.

63.346(b)(3 and 4) – records of occurrence, duration, and cause of each malfunction of
process, control or monitoring equipment.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 24 of the AO. See status of condition 24 for additional information.

63.346(b)(5) – other records necessary to demonstrate consistency with the provisions of
the O&M plan.

Status: In Compliance. The Operation and Maintenance Plan was provided at the time of
inspection.

63.346(b)(6 and 7) – Test reports documenting results of all performance tests; All
measurements as may be necessary to determine the conditions of performance tests,
including measurements necessary to determine compliance with the special compliance
procedures of §63.344(e).

Status: In Compliance. The requirements of this section are satisfied by compliance with
conditions 8 and 9 of the AO. See status of conditions 8 and 9 for additional
information.

18
63.346(b)(8) – Records of monitoring data required by §63.343(c) that are used to
demonstrate compliance with the standard including the date and time the data are
collected.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 21 of the AO. See status of condition 21 for additional information.

63.346(b)(9) – specific identification of each period of excess emissions (as indicated by monitoring data) that occurs during malfunction of the process, control or monitoring
equipment.

Status: In Compliance. No period of excess emissions occurring during a malfunction of the
process, control, or monitoring equipment have occurred based on the record
submissions for the 12-month period of February 2023 through January 2024.

63.346(b)(10) – specific identification of each period of excess emissions (as indicated by
monitoring data) that occurs during periods other than malfunctions.

Status: In Compliance. No periods of excess emissions as indicated by monitoring data
have occurred.

63.346(b)(11) – the total process operating time during the reporting period.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 13 of the AO. See status of condition 13 for additional information.

63.346(b)(12) – records of actual cumulative rectifier capacity if using this to determine
facility size.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 13 of the AO and section 63.342(c)(3)(i). See status of condition 13 and
section 63.342(c)(3)(i) for additional information.

63.346(b)(13) – For sources using fume suppressants to comply with the standards,
records of the date and time that fume suppressants are added to the electroplating or
anodizing bath and records of the fume suppressant manufacturer and product name.

Status: In Compliance. The requirements of this section are satisfied by compliance with
condition 10 of the AO. See status of condition 10 for additional information. The
source maintains records of fume suppressant manufacturer and product name.

63.346(b)(16) – all documentation supporting the notifications and reports required.

Status: In Compliance. The source maintains all required and applicable documentation
required by this section on-site. Applicable records were provided at the time of
inspection.

63.346(c) – all records shall be maintained for 5 years.

Status: In Compliance. The requirements of this section were reviewed at the time of
inspection. The source maintains all required records beyond the required 5 years.
19
63.347(a) – Subpart A reports - submit reports by mail or electronically.
63.347(b) – reporting requirements apply when sources becomes subject.

Status: In Compliance. All applicable reporting requirements have been met by the source.

63.347(c) – initial notifications.

Status: In Compliance. Previous compliance inspections indicate initial notification was
submitted to the EPA on July 18, 1995.

63.347(d) – notification of performance test.

Status: In Compliance. The requirements of this section are satisfied by compliance with
conditions 8 and 9 of the AO. See status of conditions 8 and 9 for additional
information.

63.347(e) – notification of compliance status – required each time an affected source
becomes subject.

Status: In Compliance. Previous compliance inspections indicate notification of compliance
status was submitted to the EPA on August 7, 1997.

63.347(f) – reports of performance test results.

Status: In Compliance. Previous compliance inspections indicate performance test results
reports were submitted on August 8, 1997, October 7, 1997, October 23, 1997, and
December 10, 1997.

63.347(h) – ongoing compliance status reports for area sources; required to prepare a
summary report to document ongoing compliance status of the affected source; report
shall contain the following information and be retained on site:

• company name and address
• identification of the operating parameter that is monitored for compliance
determination
• relevant emission limitation and operating parameter value that corresponds to
compliance
• beginning and end dates of reporting period
• description of the type of process performed
• total operating time during the reporting period
• if the affected source is a hard chromium electroplating tank and the owner is
limiting the maximum cumulative rectifier capacity (for this source, based on
maximum operating hours of 6240 hours – see 63.342(c)(3)(i))
• summary of operating parameter values, including the total duration of excess
emissions during the reporting period, the total duration of excess emissions
expressed as a percent of the total source operating time during that reporting
period, and a breakdown of the total duration of excess emissions during the
reporting period into those that are due to process upsets, control equipment
malfunctions, other known causes, and unknown causes
• certification by a responsible official that the work practice standards were
20
followed in accordance with the operation and maintenance plan for the source
• if the O&M plan was not followed, an explanation of the reasons
• description of any changes in monitoring, processes, or controls since the last
reporting period
• number, duration, and brief description for each type of malfunction
• name, title, and signature of the responsible official who is certifying the
accuracy of the report
• date of the report

Status: In Compliance. The Operation and Maintenance Plan is in place and is being
followed as required. No revisions have occurred since the 2017 inspection. The
O&M plan was viewed onsite at the time of inspection.

63.347(h)(2) – reports of exceedances.

Status: In Compliance. There have been no reports of exceedances at the source location.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-214. National Emission Standards for Hazardous Air Pollutants.

Status: This area source rule is applicable per R307-214-2. Sources Subject to 40 CFR Part
63, Subpart N, National Emission Standards for Chromium Emissions From Hard
and Decorative Chromium Electroplating and Chromium Anodizing Tanks.

In Compliance. This area source rule is satisfied by compliance with condition 15 of
the AO and Subpart N. See status of ‘Applicable Federal Requirements - NESHAP
(Part 63), N: National Emission Standards for Chromium Emissions From Hard
and Decorative Chromium Electroplating and Chromium Anodizing Tanks’ for full
rule evaluation.

R307-304. Solvent Cleaning

Status: Out of Compliance. The MEK and Lacquer thinner apply to this section as they are
used for cleaning for their painting operations. According to their VOC
spreadsheet, they exceed the limit for VOC lb/gallon. Both the MEK and Lacquer
Thinner are used for cleaning equipment. Compliance assistance was provided to
help the source find products that would meet the VOC lb/gal limits or are EPA
exempt, such as acetone. Source was notified via email on March 22, 2024, about the
non-compliant lacquer thinner and MEK used for cleaning equipment and was
provided information on compliance guidelines. The source was also notified via
telephone on March 26, 2024, about compliance information regarding the limits
within the rule. Further compliance action may be necessary in the future should
the source still be operating with non-compliant solvents. No further action is
currently recommended.

R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards.
21

Status: In Compliance. This area source rule is satisfied by compliance with condition 12 of
the AO.

R307-306. PM10 Nonattainment and Maintenance Areas: Abrasive Blasting.

Status: Not Applicable. This area source rule was evaluated during the 2017 inspection as
potentially applicable to the glass bead blasting activities. The source indicated the
glass bead blaster vents internally with all air being routed through a filter bank
before venting.

R307-309. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive
Emissions and Fugitive Dust.

Status: In Compliance. No visible emissions from operations were observed at the time of
inspection. The 15% opacity limit in R307-309-4(l) supersedes the 20% opacity limit
in condition 12 of the AO.

R307-342. Adhesives and Sealants.

Status: Not Applicable. This area source rule was evaluated at the time of inspection. The
source indicated they do not currently use any adhesives or sealants as part of their
operation.

R307-350. Miscellaneous Metal Parts and Products Coatings.

Status: Not Applicable at this time. R307-350-2 applicability indicates any coating of metal
parts or products that includes primary metal industries, fabricated metal products,
nonelectric and electrical machinery manufacturing, and other miscellaneous
manufacturing industries. Quality Plating Company is a specialty plating operation
that plates individual already manufactured products. Quality Plating is exempt
from R307-350-3 (i) as they use canned aerosol coating for their products.

22
EMISSION INVENTORY: Quality Plating Company’s Emission Inventory data for the 2005
activity year are recorded as follows:

Pollutant Tons/yr

1. Ammonia ............................................................ 0.00085
2. Cadmium Compounds ........................................ 0.006
3. CO ...................................................................... 0.268
4. Chromium Compounds ...................................... 0.0011
5. Cyanide Compounds .......................................... 0.006
6. Hydrogen Chloride ............................................. 0.009
7. Nickel Compounds ............................................. 0.132
8. NOx ..................................................................... 0.318
9. PM10 ................................................................... 0.164
10. PM2.5 ................................................................... 0.025
11. SOx ..................................................................... 0.022
12. Sulfuric Acid ...................................................... 0.02
13. VOCs .................................................................. 1.159

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

COMPLIANCE STATUS &
RECOMMENDATIONS: Out of Compliance with R307-304. Source was utilizing cleaners
that exceeded the VOC lb/gal limit established within the rule.
Compliance assistance was provided to help the source find
compliant cleaners for their paint gun and parts cleaner. Source
was notified on March 22, 2024, via email about the need to find
compliant solvents for their paint gun as well as more
information about compliant products via telephone on March
26, 2024. No further action is currently recommended. In
compliance with the rest of the conditions of DAQE-080-97,
dated January 30, 1997, and the most recent version of 40 CFR
63 Subpart N at the time of inspection. The source appears to be
well maintained and operated. Required records were current
and were provided upon request.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The source’s regular operating hours are 8:00 AM to 5:00 PM,
Monday through Friday. Inspect at the usual frequency. Check to
see if the source has changed to a compliant cleaner for their
paint gun and parts cleaning. They may be subject to additional
compliance action if they are still operating with non-compliant
solvents. Source was notified on March 22, 2024, via email and
March 26, 2024, via telephone about the requirements for a
compliant solvent for cleaning.

23
RECOMMENDATION FOR
NSR: This AO needs to go through the 10-year review since it is
subject to that based on its approval date. The equipment list also
needs to be updated to include new equipment, the Grieve-brand
Heat Treating Oven, that was added from the 2017 inspection.

ATTACHMENTS: Quality Plating VEO 2024, State of Utah Mail- Documents for
Visit 2-8-2024, Summary Audit Letter with 12-month totals,
Fume Suppressant Records, Quarterly Inspection of Hard
Chrome Fume Scrubber Equipment, Scrubber Records, Tank
Hour Report, and VOC Worksheet.
Jordan Garahana <[e-mail]>
Documents for visit 2-8-2024
19 messages
Glenn Fassmann <[e-mail]>Sat, Feb 10, 2024 at 9:10 AM
To: [e-mail]

Hello Jordan,

There are 4 stars in your comments which I owe you.

1. Surface Tension Readings - see attached.
2. I spoke with Bill and we are staying with the Havachrome Mist Eliminator III for the fume suppressant. Bill and I
had a conversion a while ago when we were considering a change. At that time we both thought the Eliminator III
was a MacDermid product and we have been trying to move away from MacDermid and use Haviland more. This
fume suppressant is a Haviland product, so he stayed with it. Bill said that he inquired about something better for
our purposes, but Haviland assured us it is still the best product they have for our situation for cost and
effectiveness.
3. VOC emissions – see attached.
4. Scrubber numbers – see attached.

Let me know if I missed something. Please contact me with questions.

Thank You,

Glenn Fassmann
QP Quality Plating Co., Inc.
801-355-7424 X 203

3 attachments
Scrubber Records.pdf
8214K
VOC Records.pdf
1404K
Surface Tension Readings.pdf
2647K
12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1790529055051974075&simpl=msg-f:179052905505197407…1/8
Jordan Garahana <[e-mail]>Mon, Feb 12, 2024 at 9:57 AM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
Thank you for sending over the information I requested from my inspection. I will let you know if I have any other
questions or records I need.
Thanks,
Jordan
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Jordan Garahana <[e-mail]>Tue, Mar 5, 2024 at 2:38 PM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
I have a question in regards to the MEK and Lacquer Thinner used onsite. Are they used for cleaning and if so how are
they used?
Thanks,
Jordan Garahana
On Sat, Feb 10, 2024 at 9:12 AM Glenn Fassmann <[e-mail]> wrote:
[Quoted text hidden]
[Quoted text hidden]
Glenn Fassmann <[e-mail]>Tue, Mar 5, 2024 at 4:18 PM
To: Jordan Garahana <[e-mail]>

Hello Jordan,

They are primarily used for cleaning.

12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1790529055051974075&simpl=msg-f:179052905505197407…2/8
The lacquer thinner is primarily used to clean the spray gun equipment and wiping the parts before they are
sprayed. The lacquer thinner is sometimes used to thin the lacquer so it sprays better for certain
applications.

The MEK is used to clean parts, clean adhesive and remove masking materials.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Wed, Mar 6, 2024 at 9:39 AM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
Thanks for the information. Do you happen to have the SDS for both of those products on file?
Thanks,
Jordan
[Quoted text hidden]
Glenn Fassmann <[e-mail]>Thu, Mar 7, 2024 at 9:06 AM
To: Jordan Garahana <[e-mail]>
[Quoted text hidden]
2 attachments
MEK SDS.pdf
62K
Sherwin Willimas Lacquer thinner - SDS.pdf
582K
Jordan Garahana <[e-mail]>Tue, Mar 12, 2024 at 10:40 AM
To: Chad Gilgen <[e-mail]>
Quality Plating information
[Quoted text hidden]
[Quoted text hidden]
3 attachments
Scrubber Records.pdf
8214K
VOC Records.pdf
1404K
Surface Tension Readings.pdf
2647K
Jordan Garahana <[e-mail]>Tue, Mar 12, 2024 at 10:41 AM
To: Chad Gilgen <[e-mail]>
SDS sheets from Quality Plating
---------- Forwarded message ---------
From: Glenn Fassmann <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1790529055051974075&simpl=msg-f:179052905505197407…3/8
[Quoted text hidden]
2 attachments
MEK SDS.pdf
62K
Sherwin Willimas Lacquer thinner - SDS.pdf
582K
Jordan Garahana <[e-mail]>Tue, Mar 12, 2024 at 2:05 PM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
Thanks for sending me the SDS for the lacquer and MEK. Do you have a more recent version from your supplier or can
you request one from your supplier?
Thanks,
Jordan
[Quoted text hidden]
Glenn Fassmann <[e-mail]>Wed, Mar 13, 2024 at 12:55 PM
To: Jordan Garahana <[e-mail]>

Hello Jordan,

Attached is the Lacquer Thinner. Waiting on the MEK.
[Quoted text hidden]
Sherwin Willimas Lacquer thinner - SDS.pdf
202K
Jordan Garahana <[e-mail]>Wed, Mar 13, 2024 at 3:56 PM
To: Chad Gilgen <[e-mail]>
Updated SDS from Quality Plating that they received from Sherwin Williams. The vapor pressure and VOC content is still
the same as the 2018 SDS.
---------- Forwarded message ---------
From: Glenn Fassmann <[e-mail]>
Date: Wed, Mar 13, 2024 at 12:58 PM
Subject: RE: Documents for visit 2-8-2024
To: Jordan Garahana <[e-mail]>

Hello Jordan,
[Quoted text hidden]
[Quoted text hidden]
12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1790529055051974075&simpl=msg-f:179052905505197407…4/8
Sherwin Willimas Lacquer thinner - SDS.pdf
202K
Glenn Fassmann <[e-mail]>Thu, Mar 14, 2024 at 9:23 AM
To: Jordan Garahana <[e-mail]>

Good Morning Jordan,

I went back to our supplier and received this SDS for MEK. It is also a 2020 revision.

I attached what I received. Let me know if you need anything else.
[Quoted text hidden]
MEK SDS Thatcher.pdf
2832K
Chad Gilgen <[e-mail]>Thu, Mar 21, 2024 at 1:21 PM
To: Jordan Garahana <[e-mail]>
Hi Jordan,
I can't remember all the details from our conversation but, if it's exceeding the VOC lb/gal or vapor composite limit found
in the corresponding 307 rule, then they need to find a compliant alternative. We can work with them on a timeline for
that.
Let me know if you have any questions or would like to discuss further.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Fri, Mar 22, 2024 at 8:56 AM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
Thanks for sending me more information about the cleaners that are used for the paint gun. Based on their usage and the
amount that has been used, this means they are subject to the state rule for solvent cleaning, R307-304. Based on the
information provided on the data sheets, the lacquer thinner and the MEK have a vapor pressure or a VOC content that is
12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1790529055051974075&simpl=msg-f:179052905505197407…5/8
higher than what is allowed, meaning you will have to find a compliant alternative. I have attached the rule here for your
reference. Please let me know if you have any questions.
Thanks,
Jordan Garahana
[Quoted text hidden]
R307-304.pdf
24K
Glenn Fassmann <[e-mail]>Fri, Mar 22, 2024 at 9:32 AM
To: Jordan Garahana <[e-mail]>

Hello Jordan,

OK, I guess I need to start looking.

Just to help me start out is Acetone an acceptable alternative?

I have tried acetone and if I use acetone, I will use at least double the amount of solvent and my person
doing the job will take twice as long.

I will call some suppliers and see what other options I may have and any thoughts you have would be
appreciated.

I can still use lacquer thinner to thin the lacquer, but I can’t use it to clean the parts or the spray gun?

Is removing masking paint considered solvent cleaning or is there another category?

Any advice appreciated.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Fri, Mar 22, 2024 at 9:51 AM
To: Chad Gilgen <[e-mail]>
Hey Chad,
Do you have any thoughts on what he is requesting?
Thanks,
Jordan
12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1790529055051974075&simpl=msg-f:179052905505197407…6/8
---------- Forwarded message ---------
From: Glenn Fassmann <[e-mail]>
Date: Fri, Mar 22, 2024 at 9:35 AM
Subject: RE: Documents for visit 2-8-2024
To: Jordan Garahana <[e-mail]>

Hello Jordan,
[Quoted text hidden]
[Quoted text hidden]
Chad Gilgen <[e-mail]>Tue, Mar 26, 2024 at 11:19 AM
To: Jordan Garahana <[e-mail]>
Jordan,
See my responses in red:
Just to help me start out is Acetone an acceptable alternative?

I have tried acetone and if I use acetone, I will use at least double the amount of solvent and my person
doing the job will take twice as long.
Yes. Acetone is an EPA-exempt solvent but it sounds like it may not be an acceptable alternative for
their processes.
I will call some suppliers and see what other options I may have and any thoughts you have would be
appreciated.
That sounds like their best course of action. There should be an alternative that works for them.
I can still use lacquer thinner to thin the lacquer, but I can’t use it to clean the parts or the spray gun?
That is correct unless they can find a lacquer thinner that meets the vapor composite pressure
limits.
Is removing masking paint considered solvent cleaning or is there another category?
Depens on their process. Likely yes as solvent cleaning in our UAC rules is defined as:
Solvent cleaning" means operations performed using a liquid that contains any VOC, or combination of
VOCs, which is used to clean parts, tools, machinery, equipment and work areas. Cleaning operations
include, but are not limited to, spraying, wiping, flushing, and purging. Solvent cleaning does not include
degreasing operations subject to R307-335.
Thanks and let me know if you have any additional questions.
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
12/18/24, 1:51 PM State of Utah Mail - Documents for visit 2-8-2024
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Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Tue, Mar 26, 2024 at 1:52 PM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
Sorry for the late reply, but here is what my manager said in regard to the questions you asked, his responses are in red
below:
Just to help me start out is Acetone an acceptable alternative?

I have tried acetone and if I use acetone, I will use at least double the amount of solvent and my person
doing the job will take twice as long.
Yes. Acetone is an EPA-exempt solvent but it sounds like it may not be an acceptable alternative
for their processes.
I will call some suppliers and see what other options I may have and any thoughts you have would be
appreciated.
That sounds like their best course of action. There should be an alternative that works for them.
I can still use lacquer thinner to thin the lacquer, but I can’t use it to clean the parts or the spray gun?
That is correct unless they can find a lacquer thinner that meets the vapor composite pressure
limits.
Is removing masking paint considered solvent cleaning or is there another category
Depends on their process. Likely yes as solvent cleaning in our UAC rules is defined as:
Solvent cleaning" means operations performed using a liquid that contains any VOC, or combination of VOCs,
which is used to clean parts, tools, machinery, equipment and work areas. Cleaning operations include, but
are not limited to, spraying, wiping, flushing, and purging. Solvent cleaning does not include degreasing
operations subject to R307-335.
Please let me know any other questions you have.
Thanks,
Jordan
[Quoted text hidden]
Jordan Garahana <[e-mail]>Wed, Dec 18, 2024 at 1:50 PM
To: Glenn Fassmann <[e-mail]>
Hey Glenn,
Just wanted to send as a reminder that the solvents must be replaced by the time the next inspection occurs. Generally,
you have a year from the date of notification/inspection to get those replaced, which was March 22, 2024. Otherwise you
may run into compliance issues during your next inspection. Please let me know if you have any questions.
Thanks,
Jordan
[Quoted text hidden]
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