DAQ-2024-006953

DAQC-CI121010001-24Site ID 12101 (B1)MEMORANDUMTO:FILE – TCR COMPOSITES INC.–Defense Depot Ogden (Building B1)THROUGH:Chad Gilgen, Minor Source Compliance Section ManagerFROM:Daniel
Riddle, Environmental ScientistDATE:March 11, 2024SUBJECT:FULL COMPLIANCE EVALUATION, Minor, Weber CountyINSPECTION DATE:February 8, 2024
SOURCE LOCATION:Building 1 B 219 North 530 West
Ogden, UT 84405
SOURCE CONTACTS:Robert Eyre, Manager
801-622-3822 [e-mail] STATUS:Operating normally at the time of inspection
PROCESS DESCRIPTION:TCR Composites Inc. operates a composite manufacturing plant in Weber County. The facility is inside the Ogden City limits. The process involves impregnating roving
with a mixed,
two-part resin. After completing a production run, the equipment must be cleaned using a 50-50 mixture of methyl ethyl ketone (MEK) and acetone to clean equipment.
APPLICABLE REGULATIONS:Approval Order (AO) DAQE-493-01, dated June 27, 2001SOURCE EVALUATION:
Name of Permittee:Permitted Location:
TCR Composites Inc.-Defense Depot Ogden (Building B1)
219 North 530 West
Building 1 B 219 North 530 WestOgden, UT 84404
Ogden, UT 84405General Conditions:This AO applies to the following company:Facility LocationBuilding D205219 North 530 West Ogden, Utah 84404Status:In Compliance.The facility is still
located at this addressDefinitions 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.Status:In Compliance.This AO conforms to UAC R307 and 40 CFR.Thiokol
Propulsion, owner/operator, shall conduct its operation of the Composite Materials Manufacturing Process in accordance with the terms and conditions of this AO, which was written pursuant
to Thiokol’s NOI submitted to the Division of Air Quality (DAQ) on September 21, 1998, and additional information submitted to the DAQ on March 15, 2001.Status: In Compliance.Operations
are conducted as required.The source is now known as TCR Composites Inc.This AO shall replace the AO dated August 11, 1998 (DAQE-468-98).Status: In Compliance.This is the current AO.Visible
emissions from any stationary point or fugitive emission source associated with the source or with the control facilities shall not exceed 10% opacity.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 were observed from any point at the time of inspection.Method
9 was utilized to verify opacity limits.See attached VEO form.The plant-wide emissions of cleaning solvent (methyl ethyl ketone (MEK) or equivalent) and VOC shall not exceed:6.6 tons
per rolling 12-month period for VOC (including cleaning solvent) Compliance with each limitation shall be determined on a rolling 12-month total. By the fifteenth day of each month a
new 12-month total shall be calculated using data from the previous 12 months.The plant-wide emissions of cleaning solvent and VOC emitted to the atmosphere shall be determined by maintaining
a record of cleaning solvent and VOC containing materials used each month.The record shall include the following data for each item used:A.Amount and location of cleaning solvent and
VOC containing materials used on a daily basis.The building to which the material was delivered/issued may be considered as use location.B.To calculate the monthly cleaning solvent and
VOC usage, sum the daily usage for the month and use the following procedure:X (tons) = (% Volatile by Weight/100) x (Density lb/gallon) x (gallons consumed) / (2,000 lb/ton)C.The amount
of solvent and VOC reclaimed/disposed of for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total.D.Records of consumption
shall be kept for all periods when the plant is in operation. Status: In Compliance.For the rolling 12-month period from February 2023 - January 2024, a total of 2.0675 tons of MEK were
emitted.See the attachment below.
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:Solvent Cleaning [R307-304]Status: In Compliance. TCR Composites uses a 50/50 Blend Cleaning Solvent from TARR for solvent cleaning which
has a VOC content of 3.347 lbs./gal.This is within the limits established by Table 1 of R307-304.See the attached email correspondence and SDS for more information.Ozone Nonattainment
& Maintenance Areas [R307-325]
Status: In Compliance.No VOC containing materials were observed spilled, discarded, stored in open containers, or handled in any other way that would result in greater evaporation.EMISSION
INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from TCR Composites Inc.Defense Depot Ogden (Building B1) on the Approval Order (AO) DAQE-AN0121010005-10,
dated April 20, 2010.PTE are supplied for supplemental purposes only.
Criteria Pollutant
PTE tons/yrCarbon Monoxide 0.44Nitrogen Oxides 1.03Particulate Matter - PM10 0.12Sulfur Dioxide 0.01Volatile Organic Compounds 6.60
Hazardous Air Pollutant
PTE lbs/yr
PREVIOUS ENFORCEMENT ACTIONS:No enforcement actions within the past five years.
COMPLIANCE STATUS &RECOMMENDATIONS:In regards to Approval Order (AO) DAQE-493-01, dated June 27, 2001:In compliance at the time of inspection.HPV STATUS:Not Applicable.
RECOMMENDATION FORNEXT INSPECTION:Inspect at low frequency.NSR RECOMMENDATIONS:None at this time.ATTACHMENTS:Email correspondence, VEO form, MEK emissions, Correspondence with NSR, SDS