DAQ-2025-000325

1
DAQC-CI141670001-24
Site ID 14167 (B1)

MEMORANDUM

TO: FILE – AUTOLIV ASP, INCORPORATED – Ogden Airbag Module Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: January 13, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County

INSPECTION DATE: August 15, 2024

SOURCE LOCATION: 1000 West 3300 South
Ogden, UT 84401
SOURCE CONTACTS: Brian Boudreaux, Shared Services Health and Safety Manager
801-664-6616 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: The source has a plastics laminate plant and automotive airbag
manufacturing plant, warehouse, line maintenance shop,
facilities maintenance shop, coating line with heat drying,
gasoline fuel station, and diesel fueling station. The plastic
laminate plant produces parts by injection molding.

Plastic covers are placed on hangers and automatically conveyed
through the coating booths and drying oven. Coating is pumped
to booths and applied by robotic spray arms. The airbag module
manufacturing plant assembles parts into the final product. An
oven with an afterburner removes paint from hangers used to
hold parts during coating. Four emergency generators, boilers, a
small touch-up paint booth, and a small confined abrasive blast
unit are also present onsite.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN141670008-20, dated March
16, 2020
NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines,
NSPS (Part 60) A: General Provisions,
MACT (Part 63) -A: General Provisions,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines
* - ) - # )
2
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Autoliv ASP, Incorporated - Ogden Airbag
Module Facility

3350 Airport Road 1000 West 3300 South
Ogden, UT 84405 Ogden, UT 84401

SIC Code: 3799: (Transportation Equipment, NEC)

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: In Compliance. No unapproved equipment was observed at the time of inspection. No limits appear to have been exceeded. The source sent in the notification of the operational status of the new equipment in 2020. All generators were observed to be
operational at the time of inspection. The source submitted their 2023 Emission Inventory on time. That can be found in the attachments section.

3
Section II: SPECIAL PROVISIONS

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

II.A.1 Autoliv Plastic parts coating plant and airbag module manufacturing plant
II.A.2 Oven and After Burner Combined rating: 0.39 MMBtu/hr
II.A.3 Coating Line Adhesion-promoter spray booth, ozonation-adhesion-promoter system, topcoat spray booth, curing oven, touch-up spray booth, and high-volume low-pressure spray guns.
II.A.4 Air Make-Up Unit Fuel: Natural Gas Capacity: 6.084 MMBtu/hr
II.A.5 Emergency Generator Engines Two (2) Engines Fuel: Natural Gas Output: 60 kW and 80 kW MACT Subpart ZZZZ
II.A.6 Emergency Generator Engines Four (4) Engines Fuel: Diesel Output: 125 kW, 100 kW, two (2) at 40 kW NSPS Subpart IIII MACT Subpart ZZZZ
II.A.7 Paint Spray Booth Particulate control: Fiberglass or polyester filters
II.A.8 Boilers Two (2) Boilers Fuel: Natural gas Rating: <5 MMBtu/hr - each This is listed for informational purposes only.
II.A.9 Miscellaneous Natural Gas-Fueled Equipment Boilers and space heaters Rating: <5 MMBtu/hr each Combined rating: 10 MMBtu/hr Listed for informational purposes only.
II.A.10 Unconfined-Abrasive Blast Booth

4
II.A.11 Miscellaneous Equipment Injection molding machines Parts washers Airbag module production equipment Plant maintenance Offices Laboratories Forklifts and other non-road mobile equipment (propane, gasoline, or diesel fueled) This equipment is listed for informational purposes only.
Status: In Compliance. No unapproved equipment was observed at the time of inspection. The 40-kW generator is installed and is operational.

II.B Requirements and Limitations
II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions to exceed the following values from the following emission points: A. Air Make-Up Unit - 5% opacity B. Oven - 10% opacity C. All natural gas-, propane-, and gasoline-fueled combustion-device exhaust stacks - 10% opacity D. All paint-booth exhaust stacks - 10% opacity E. All natural gas-fueled emergency generator engines - 10% opacity F. All building exhaust stacks - 10% opacity G. All diesel-fuel-combustion exhaust stacks - 20% opacity H. Outdoor abrasive blasting operations - 20% opacity I. All other points including fugitive emissions - 20% opacity. [R307-305-3, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached VEO form for additional information. II.B.2 Manufacturing Plant Requirements II.B.2.a The VOC- and/or HAP-containing materials shall be stored in covered containers (except when in use). VOC- and/or HAP-laden rags shall also be stored in a covered container. [R307-325-3] Status: In Compliance. VOC and HAP containing materials were stored in containers that were closed at the time of inspection. II.B.2.b The owner/operator shall not exceed the following consumption limits in the airbag module manufacturing plant: A. 1,000 pounds of sand-blasting media per rolling 12-month period B. 6,000,000 gallons of propane per rolling 12-month period C. 3,000,000 gallons of gasoline per rolling 12-month period D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period E. 60,000,000 cubic feet of natural gas per rolling 12-month period. [R307-401-8]

5
II.B.2.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. No later than 20 days after the end of each month, a new 12-month total shall be calculated using data from the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by examination of material supplier billing records. The records of consumption shall be kept on a monthly basis. [R307-401-8] Status: In Compliance. The rolling 12-month total from August 2023 to July 2024, are as follows: A. One 50-pound bag was ordered in 2023. Sandblasting is rarely used onsite and is in consideration for removal from operations. B. Propane is not utilized often onsite anymore and is only purchased on an as needed basis in small amounts. C. 4,284.21 gallons of gasoline consumed onsite D. 3,077 gallons of diesel fuel consumed onsite E. 17,058,000 cubic feet of natural gas consumed onsite The sandblaster is only used once every year or two and is in consideration for removal from their operations. Propane is only utilized onsite by one vehicle and grills onsite. The propane isn't bought through a distributor as it is a very small amount of propane purchased and used. See the attachments section for additional information. II.B.2.c The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module manufacturing plant and coating line: 65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde 0.25 tons per rolling 12-month period for glycol ethers 4.44 tons per rolling 12-month period for toluene 15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene, trichloroethylene, and xylene.* * Any individual HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for in R307-410-5. The above VOC and HAP limits do not include the products of incomplete combustion generated by the emergency generator engines, boilers, or assorted fuel burning equipment items. The coating line includes, but is not limited to thinners, cleaning solvents, top coating, catalysts, and adhesion promoters. [R307-401-8] II.B.2.c.1 Compliance with each limitation shall be determined on a rolling 12-month total. No later than 20 days after the end of each month, a new 12-month total shall be calculated using data from the previous 12 months. [R307-401-8] II.B.2.c.2 The VOC and HAP emissions shall be determined by maintaining a record of VOC- and HAP-emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC- or HAPs-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, and etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC or HAP in each material used D. Gallons of each VOC- or HAP-emitting material used
6
E. The amount of VOC or HAP emitted monthly by each material used shall be calculated by the following procedure: VOC = (% VOC by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb) HAP = (% HAP by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb) F. The amount of VOC or HAP emitted monthly from all materials used G. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. [R307-401-8] II.B.2.c.3 To demonstrate compliance with those HAPs that have an emission limit less than its ETV, Autoliv shall compare the actual maximum emission rate to the ETV and maintain records of this comparison for each month of operation. This comparison shall be performed no later than 20 days after the end of each month. [R307-401-8] Status: In Compliance. The rolling 12-month total for VOC and HAP emissions from August 2023 to July 2024, are as follows: 31.8 tons of VOC emissions 0 tons of formaldehyde 0 tons of glycol ethers 0.1 tons of toluene 1.6 tons of combined HAPs Source calculates totals using Microsoft Excel and the source shows monthly calculations in the spreadsheet. Comparison to ETV records are maintained and did not exceed the ETV. See the attachments section for additional information. II.B.2.d Plastic parts coating line plant shall use only pipeline quality natural gas as fuel. [R307-401-8] Status: In Compliance. Only natural gas is used in the plastic parts coating line. II.B.3 Emergency Generator Engine Requirements II.B.3.a The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines. [R307-401-8] Status: In Compliance. Only natural gas is used in the 60 and 80 kW generators. See the attached Excel sheet that shows gas consumption for the two generators. II.B.3.b The owner/operator shall install a diesel-fired emergency engine that is certified to meet a NOx emission rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30 g/hp-hr for each of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.1 To demonstrate compliance with the emission rate, the owner/operator shall keep records of the manufacturer's certification of the emission rate. The records shall be kept for the life of the equipment. [R307-401-8] Status: In Compliance. Source maintains the generator information from CAT that shows the emission rates meet the standards in this AO. See the attachments section for a copy of the information for the two generators. II.B.3.c The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
7
II.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 day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The rolling 12-month total for generator hours from August 2023 to July 2024, is as follows: A range of 9.9 hours to 59.9 hours for each individual generator. An overall total record is in the attachments section, with a monthly breakdown for each generator’s monthly hour usage. II.B.3.d To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. Each generator has a non-resettable meter installed on them. II.B.3.e The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 125 kW, 100 kW, and two (2) 40 kW emergency engines. [R307-401-8] II.B.3.e.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.3.e.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. A fuel invoice from RelaDyne shows the diesel fuel used onsite is ULSD. II.B.4 Abrasive Blasting Requirement II.B.4.a The owner/operator shall comply with all applicable requirements of R307- 306, Emission Standards: Abrasive Blasting. [R307-306] Status: In Compliance. Abrasive blasting rarely occurs onsite anymore, but is conducted in an enclosed cabinet shop onsite.

8
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.

NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. The 125 kW, 100 kW, and 40 kW generators apply to this subpart. Source
maintains and operates the generators according to the manufacturer's specifications. The generators
are operated in emergency situations and records of usage are maintained.

NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Status: In Compliance. The 60kW and 80kW generators apply to this subpart. Both generators operate
only on natural gas. Both generators are equipped with non-resettable meters, did not operate over 100
hours within the rolling 12-month period, and maintenance is performed according to the
manufacturer's specifications.

NSPS (Part 60) A: General Provisions

Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable federal
subparts. In Compliance with Subparts IIII and JJJJ.
MACT (Part 63) -A: General Provisions

Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable federal
subparts. In Compliance with Subparts ZZZZ.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. All generators onsite apply to this subpart. No generator operated over 100
hours within the rolling 12-month period and are maintained according to the manufacturer's
specifications. The generators are equipped with non-resettable meters.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: In Compliance. No visible emissions were observed at the time of inspection.

PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306]

Status: In Compliance. Source follows rules with abrasive blasting. Source uses glass beads and
conducts blasting in an enclosed cabinet shop.
9
Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No fugitive emissions were observed. Area around the shop is paved.

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

Status: In Compliance. No VOC containing spills were observed. Containers onsite were closed at the
time of inspection.
Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. Source operated a parts washer. At the time of inspection, the parts washer was not in use and the lid was closed. Signage is posted that states the parts washer should be closed
when not in use.

Plastic Parts Coatings [R307-353]

Status: In Compliance. The plastic cover line applies to this rule. According to Brian Boudreaux of
Autoliv, the paints are used for air-dried coatings for interior parts, as stated in Table 1 of the rule.
The limit for air-dried coatings for interior parts under the rule is 5.0 lb/gal VOC. The highest VOC
paint used by Autoliv is 4.56 lb/gal VOC, according to the SDS sent from Autoliv. Source maintains
the same methods from the previous inspection. HVLP guns are used for application. The oven
temperature that the flexible coatings are dried in is above 194 F. Source was notified of the rule via
email to ensure they were compliant with R307-353. See the attachments section for further
information regarding R307-353.

10
EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Autoliv ASP, Incorporated - Ogden
Airbag Module Facility. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN141670008-20, dated March 16, 2020, is provided. The 2023 Emission Inventory is provided
below and can be found in the attachments section. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 8363.00
Carbon Monoxide 57.00 11.50
Nitrogen Oxides 21.64 1.56
Particulate Matter 1.18 0.06
Particulate Matter - PM10 6.70 0.32
Particulate Matter - PM2.5 6.70 0.31
Sulfur Dioxide 0.43 0.00
Volatile Organic Compounds 131.56 37.93

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 2340 0
Cumene (CAS #98828) 80 400
Ethyl Benzene (CAS #100414) 2340
Formaldehyde (CAS #50000) 500 0
Generic HAPs (CAS #GHAPS) 31400
Glycol Ethers (CAS #EDF109) 500
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 13500 1600
Toluene (CAS #108883) 16580 200
Total HAPs (CAS #THAPS) 32404 0
Xylenes (Isomers And Mixture) (CAS #1330207) 8960 1200

PREVIOUS ENFORCEMENT
ACTIONS: None within the past 5 years

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN141670008-20,
dated March 16, 2020, the overall status is: In Compliance. In
compliance with conditions listed within AO. The facility
appears to be well maintained, and records were made available
upon request.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect next year as the source just received a new updated AO.

NSR RECOMMENDATIONS: None

ATTACHMENTS: Applicable Supporting Documentation Included
2023 Emissions Inventory Report
Autoliv ASP, Incorporated (14167)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)0.38017 0.02735 0.40751
PM10-FIL PM10 Filterable 0.32817 <.00001 0.32817
PM25-PRI PM2.5 Primary (Filt + Cond)0.38016 0.02591 0.40607
PM25-FIL PM2.5 Filterable 0.31874 <.00001 0.31874
PM-CON PM Condensible 0.0604 <.00001 0.0604
SO2 Sulfur Dioxide 0.00727 0.00133 0.0086
NOX Nitrogen Oxides 1.19604 0.37149 1.56753
VOC Volatile Organic Compounds 37.59508 0.33991 37.93499
CO Carbon Monoxide 1.18793 10.40251 11.59044
NH3 Ammonia 0.20218 <.00001 0.20218

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC 0.00014
107028 Acrolein (HAP)VOC 0.00004
71432 Benzene (HAP)VOC 0.0043
98828 Cumene (HAP)VOC 0.2
50000 Formaldehyde (HAP)VOC 0.00044
108101 Methyl Isobutyl Ketone (HAP)VOC 0.8
91203 Naphthalene (HAP)VOC 0.00072
130498292 PAH, total (HAP)PM 0.00118
108883 Toluene (HAP)VOC 0.10156
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.60107

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
Cat® D100 GC
Diesel Generator Sets
LEHE2663-03 1/2
Standby : 60 Hz
PACKAGE PERFORMANCE
Image shown might not reflect actual configuration.
Engine Model Cat® C4.4 In-line 4, 4-cycle diesel
Bore x Stroke 105 mm x 127 mm (4.1in x 5.0 in)
Displacement 4.4 L (269 in³)
Compression Ratio 16.7:1
Aspiration Turbocharged
Fuel Injection System Common Rail
Model Standby Emission Strategy
D100 GC 100 ekW EPA TIER III
Performance Standby
3-Phase 1-Phase
Frequency 60 Hz 60 Hz
Genset Power Rating 125 kVA 100 kVA
Genset power rating with fan, 3p@ 0.8 & 1p@1.0 power factor 100 ekW 100 ekW
Performance Number P4514A P4514A
Fuel Consumption
100% load with fan, L/hr (gal/hr)27.9 (7.4)28.2 (7.4)
75% load with fan, L/hr (gal/hr)22.5 (5.9)22.8 (6.0)
50% load with fan, L/hr (gal/hr)16.7 (4.4)16.9 (4.5)
Cooling System1
Radiator air flow restriction (system), kPa (in. Water)0.12 (0.48)
Engine coolant capacity, L (gal)7.0 (1.8)
Radiator coolant capacity, L (gal)10.0 (2.6)
Total coolant capacity, L (gal)17.0 (4.4)
Inlet Air
Combustion air inlet flow rate, m³/min (cfm)8.82 (311)8.82 (311)
Max. Allowable Combustion Air Inlet Temp, °C (°F)45 (113)
Exhaust System
Exhaust stack gas temperature, °C (°F)659 (1218)659 (1218)
Exhaust gas flow rate, m³/min (cfm)20.2 (712)20.2 (712)
Exhaust system backpressure (maximum allowable) kPa (in. water)15.0 (60.2)15.0 (60.2)
Heat Rejection
Heat rejection to exhaust (total) kW (Btu/min)91.3 (5192)91.3 (5192)
Heat rejection to atmosphere from engine, kW (Btu/min)15.6 (887)15.6 (887)
Emissions (Nominal)2
NOx + HC, g/kW-hr 3.6 3.6
CO, g/kW-hr 0.9 0.9
PM, g/kW-hr 0.12 0.12
D100 GC Diesel Generator Sets
Electric Power
Alternator3
Voltages 480V 208V 600V 240V
Motor starting capability @ 30% Voltage Dip, skVA 165 182 328 229
Current Amps 150 347 120 417
Frame Size M2236L4 M2254L4 M2236L4 M2238L4
Excitation SE SE AREP SE
Temperature Rise, °C 130 105 130 130
WEIGHTS & DIMENSIONS
APPLICABLE CODES AND STANDARDS:
AS1359, CSA C22.2 No100-04, UL142, UL489, UL869, UL2200, NFPA37, NFPA70, NFPA99, NFPA110, IBC, IEC60034-1, ISO3046, ISO8528, NEMA MG1-22, NEMA MG1-33, 2006/95/EC, 2006/42/EC, 2004/108/EC. Note: Codes may not be available in all model configurations. Please consult your local Cat Dealer representative for availability.
STANDBY: Output available with varying load for the duration of the interruption of the normal source power. Average power output is 70% of the standby power rating. Typical operation is 200 hours per year, with maximum expected usage of 500 hours per year.
PRIME: Output available with varying load for an unlimited time. Average power output is 70% of the prime power rating. Typical peak demand is 100% of prime rated ekW with 10% overload capability for emergency use for a maximum of 1 hour in 12. Overload operation cannot exceed 25 hours per year
RATINGS: Ratings are based on SAE J1349 standard conditions. These ratings also apply at ISO3046 standard conditions.
DEFINITIONS AND CONDITIONS
1 For ambient and altitude capabilities consult your Cat dealer. Air flow restriction (system) is added to existing restriction from factory.
2 Emissions data measurement procedures are consistent with those described in EPA CFR 40 Part 89, Subpart D & E and ISO8178-1 for measuring HC, CO, PM, NOx. Data shown is based on steady state operating conditions of 77° F, 28.42 in HG and number 2 diesel fuel with 35° API and LHV of 18,390 BTU/lb. The nominal emissions data shown is subject to instrumentation, measurement, facility and engine to engine variations. Emissions data is based on 100% load and thus cannot be used to compare to EPA regulations which use values based on a weighted cycle.
3 UL 2200 Listed packages may have oversized generators with a different temperature rise and motor starting characteristics. Generator temperature rise is based on a 40° C ambient per NEMA MG1-32.
LEHE2663-03 (06/22)
www.Cat.com/electricpowerAll rights reserved.Materials and specifications are subject to change without notice.The International System of Units (SI) is used in this publication.© 2022 Caterpillar. All Rights Reserved. CAT, CATERPILLAR, LET’S DO THE WORK, their respective logos, “Caterpillar Corporate Yellow”, the “Power Edge” and Cat “Modern Hex” trade dress as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission
Dim “A”
mm (in)
Dim “B”
mm (in)
Dim “C”
mm (in)
Dry Weight
kg (lb)
2097 (82.6)1100 (43.3)1343 (52.9)1008 (2222)
C
A B
Note: General configuration not to be used for installation. See general dimension drawings for detail.
Cat® D40 GC
Diesel Generator Sets
LEHE2669-03 1/2
Standby : 60 Hz
PACKAGE PERFORMANCE
Image shown might not reflect actual configuration.
Engine Model Cat® C4.4 In-line 4, 4-cycle diesel
Bore x Stroke 105 mm x 127 mm (4.1in x 5.0 in)
Displacement 4.4 L (269 in³)
Compression Ratio 18.2:1
Aspiration Turbocharged
Fuel Injection System Common Rail
Model Standby Emission Strategy
D40 GC 40 ekW EPA TIER III
Performance Standby
3-Phase 1-Phase
Frequency 60 Hz 60 Hz
Genset Power Rating 50 kVA 40 kVA
Genset power rating with fan, 3p@ 0.8 & 1p@1.0 power factor 40 ekW 40 ekW
Performance Number P3454C-00 P3454C-00
Fuel Consumption
100% load with fan, L/hr (gal/hr)13.5 (3.6)13.0 (3.4)
75% load with fan, L/hr (gal/hr)10.5 (2.8)10.1 (2.7)
50% load with fan, L/hr (gal/hr)7.8 (2.1)7.5 (2.0)
Cooling System1
Radiator air flow restriction (system), kPa (in. Water)0.12 (0.48)
Engine coolant capacity, L (gal)7.0 (1.8)
Radiator coolant capacity, L (gal)9.5 (2.5)
Total coolant capacity, L (gal)16.5 (4.3)
Inlet Air
Combustion air inlet flow rate, m³/min (cfm)5.3 (187.2)5.3 (187.2)
Max. Allowable Combustion Air Inlet Temp, °C (°F)45 (113)
Exhaust System
Exhaust stack gas temperature, °C (°F)571 (1060)571 (1060)
Exhaust gas flow rate, m³/min (cfm)13.7 (483.8)13.7 (484)
Exhaust system backpressure (maximum allowable) kPa (in. water)15.0 (60.2)15.0 (60.2)
Heat Rejection
Heat rejection to exhaust (total) kW (Btu/min)66.9 (3805)66.9 (3805)
Heat rejection to atmosphere from engine, kW (Btu/min)14.9 (847.3)14.9 (847.3)
Emissions (Nominal)2
NOx + HC, g/kW-hr 4.42 4.42
CO, g/kW-hr 1.02 1.02
PM, g/kW-hr 0.26 0.26
D40 GC Diesel Generator Sets
Electric Power
Alternator3
Voltages 480V 208V 600V 240V
Motor starting capability @ 30% Voltage Dip, skVA 72 64 128 85
Current Amps 60 139 48 167
Frame Size M1736L4 M1754L4 M1736L4 M1754L4
Excitation SE SE AREP SE
Temperature Rise, °C 130 130 130 130
WEIGHTS & DIMENSIONS
C
A B
Note: General configuration not to be used for installation. See general dimension drawings for detail.
APPLICABLE CODES AND STANDARDS:
AS1359, CSA C22.2 No100-04, UL142, UL489, UL869, UL2200, NFPA37, NFPA70, NFPA99, NFPA110, IBC, IEC60034-1, ISO3046, ISO8528, NEMA MG1-22, NEMA MG1-33, 2006/95/EC, 2006/42/EC, 2004/108/EC. Note: Codes may not be available in all model configurations. Please consult your local Cat Dealer representative for availability.
STANDBY: Output available with varying load for the duration of the interruption of the normal source power. Average power output is 70% of the standby power rating. Typical operation is 200 hours per year, with maximum expected usage of 500 hours per year.
PRIME: Output available with varying load for an unlimited time. Average power output is 70% of the prime power rating. Typical peak demand is 100% of prime rated ekW with 10% overload capability for emergency use for a maximum of 1 hour in 12. Overload operation cannot exceed 25 hours per year
RATINGS: Ratings are based on SAE J1349 standard conditions. These ratings also apply at ISO3046 standard conditions.
DEFINITIONS AND CONDITIONS
1 For ambient and altitude capabilities consult your Cat dealer. Air flow restriction (system) is added to existing restriction from factory.
2 Emissions data measurement procedures are consistent with those described in EPA CFR 40 Part 89, Subpart D & E and ISO8178-1 for measuring HC, CO, PM, NOx. Data shown is based on steady state operating conditions of 77° F, 28.42 in HG and number 2 diesel fuel with 35° API and LHV of 18,390 BTU/lb. The nominal emissions data shown is subject to instrumentation, measurement, facility and engine to engine variations. Emissions data is based on 100% load and thus cannot be used to compare to EPA regulations which use values based on a weighted cycle.
3 UL 2200 Listed packages may have oversized generators with a different temperature rise and motor starting characteristics. Generator temperature rise is based on a 40° C ambient per NEMA MG1-32.
LEHE2669-03 (06/21)
www.Cat.com/electricpowerAll rights reserved.Materials and specifications are subject to change without notice.The International System of Units (SI) is used in this publication.© 2020 Caterpillar. All Rights Reserved. CAT, CATERPILLAR, LET’S DO THE WORK, their respective logos, “Caterpillar Corporate Yellow”, the “Power Edge” and Cat “Modern Hex” trade dress as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission
Dim “A”
mm (in)
Dim “B”
mm (in)
Dim “C”
mm (in)
Dry Weight
kg (lb)
1962 (77.2)1100 (43.3)1220 (48.0)838 (1847)
Cat® D125 GC
Diesel Generator Sets
LEHE2664-02 1/2
Standby : 60 Hz
PACKAGE PERFORMANCE
Image shown may not reflect actual configuration.
Engine Model Cat® C7.1 In-line 6, 4-cycle diesel
Bore x Stroke 105 mm x 135 mm (4.1 in x 5.3 in)
Displacement 7.01 L (428 in³)
Compression Ratio 16.7:1
Aspiration Turbocharged Air-to-Air-Aftercooled
Fuel Injection System Electronic, Common Rail
Governor Electronic
Model Standby Emission Strategy
D125 GC 125 ekW EPA TIER III
Performance Standby
Frequency 60 Hz
Genset Power Rating 156.3 kVA
Genset power rating with fan, 3p@ 0.8 & 1p@1.0 power factor 125 ekW
Performance Number P4392A-00
Fuel Consumption
100% load with fan, L/hr (gal/hr)37.8 (10.0)
75% load with fan, L/hr (gal/hr)30.3 (8.0)
50% load with fan, L/hr (gal/hr)21.9 (5.8)
Cooling System1
Radiator air flow restriction (system), kPa (in. Water)0.12 (0.48)
Engine coolant capacity, L (gal)9.5 (2.5)
Radiator coolant capacity, L (gal)11.5 (3.0)
Total coolant capacity, L (gal)21.0 (5.5)
Inlet Air
Combustion air inlet flow rate, m³/min (cfm)14.4 (508.5)
Max. Allowable Combustion Air Inlet Temp, °C (°F)51 (124)
Exhaust System
Exhaust stack gas temperature, °C (°F)450 (843)
Exhaust gas flow rate, m³/min (cfm)29.9 (1056)
Exhaust system backpressure (maximum allowable) kPa (in. water)15.0 (60.2)
Heat Rejection
Heat rejection to exhaust (total) kW (Btu/min)128.0 (7496)
Heat rejection to aftercooler, kW (Btu/min)32.0 (2138)
Heat rejection to atmosphere from engine, kW (Btu/min)28.0 (1649)
Emissions (Nominal)2
NOx + HC, g/kW-hr 4.0
CO, g/kW-hr 1.0
PM, g/kW-hr 0.2
D125 GC Diesel Generator Sets
Electric Power
Alternator3
Voltages 480V 208V 600V
Motor starting capability @ 30% Voltage Dip, skVA 235 199 326
Current Amps 188 434 150
Frame Size M2254L4 M2256L4 M2254L4
Excitation SE SE AREP
Temperature Rise, °C 130 105 130
WEIGHTS & DIMENSIONS
APPLICABLE CODES AND STANDARDS:
AS1359, CSA C22.2 No100-04, UL142, UL489, UL869, UL2200, NFPA37, NFPA70, NFPA99, NFPA110, IBC, IEC60034-1, ISO3046, ISO8528, NEMA MG1-22, NEMA MG1-33, 2006/95/EC, 2006/42/EC, 2004/108/EC. Note: Codes may not be available in all model configurations. Please consult your local Cat Dealer representative for availability.
STANDBY: Output available with varying load for the duration of the interruption of the normal source power. Average power output is 70% of the standby power rating. Typical operation is 200 hours per year, with maximum expected usage of 500 hours per year.
PRIME: Output available with varying load for an unlimited time. Average power output is 70% of the prime power rating. Typical peak demand is 100% of prime rated ekW with 10% overload capability for emergency use for a maximum of 1 hour in 12. Overload operation cannot exceed 25 hours per year
RATINGS: Ratings are based on SAE J1349 standard conditions. These ratings also apply at ISO3046 standard conditions.
DEFINITIONS AND CONDITIONS
1 For ambient and altitude capabilities consult your Cat dealer. Air flow restriction (system) is added to existing restriction from factory.
2 Emissions data measurement procedures are consistent with those described in EPA CFR 40 Part 89, Subpart D & E and ISO8178-1 for measuring HC, CO, PM, NOx. Data shown is based on steady state operating conditions of 77° F, 28.42 in HG and number 2 diesel fuel with 35° API and LHV of 18,390 BTU/lb. The nominal emissions data shown is subject to instrumentation, measurement, facility and engine to engine variations. Emissions data is based on 100% load and thus cannot be used to compare to EPA regulations which use values based on a weighted cycle.
3 UL 2200 Listed packages may have oversized generators with a different temperature rise and motor starting characteristics. Generator temperature rise is based on a 40° C ambient per NEMA MG1-32.
LEHE2664-02 (06/26)
www.Cat.com/electricpowerAll rights reserved.Materials and specifications are subject to change without notice.The International System of Units (SI) is used in this publication.© 2022 Caterpillar. All Rights Reserved. CAT, CATERPILLAR, LET’S DO THE WORK, their respective logos, “Caterpillar Corporate Yellow”, the “Power Edge” and Cat “Modern Hex” trade dress as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission
Dim “A”
mm (in)
Dim “B”
mm (in)
Dim “C”
mm (in)
Dry Weight
kg (lb)
2634 (103.7)1300 (51.2)1402 (52.2)1406 (3099)
C
A B
Note: General configuration not to be used for installation. See general dimension drawings for detail.
Genset 10 9 6 7 8
Totals 40.3 32.6 33.2 9.6 59.9
Rolling 12-Month Total Generator Hours
C.AUG 23 SEP 23 OCT 23 NOV 23 DEC 23 JAN 24 FEB 24 MAR 24 APR 24 MAY 24 JUN 24 JULY 24 Total
Gasoline Usage (gallons)389.75 328.79 447.71 274.82 395.74 549 358 272 158 545 319 247 4284.81
D.AUG 23 SEP 23 OCT 23 NOV 23 DEC 23 JAN 24 FEB 24 MAR 24 APR 24 MAY 24 JUN 24 JULY 24 Total
Diesel Fuel #2 Usage (gallons)274.82 277.82 125.92 308.8 172.89 496 280 272 116 338 217 198 3077.25
Mobile [phone] 141 161
Stationary 136 53 49 82 15 76 37
*We started differentiating between diesel #2 that is used for mobile
operations vs stationary ones in
2024. This is why the values become split.
E.AUG 23 SEP 23 OCT 23 NOV 23 DEC 23 JAN 24 FEB 24 MAR 24 APR 24 MAY 24 JUN 24 JULY 24 Total
Natural Gas Useage (cubic feet)163000 372000 1244000 2396000 2795000 3148000 2345000 1977000 1243000 988000 237000 150000 17058000
Internal
Emission AUG 23 SEP 23 OCT 23 NOV 23 DEC 23 JAN 24 FEB 24 MAR 24 APR 24 MAY 24 JUN 24 JUL 24
Total
(lbs) Total (tons)
Limit
(tons) % of limit Compliant?
VOC (lbs)9057.7 894.6 5665.9 4685.2 5750.4 6000.1 1979.5 6273.5 7603.6 6703.2 6854.9 2137.5 63605.7 31.8 48.00 66.3 Y
formaldehyde (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.25 0.0 Y
glycol ethers (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.25 0.0 Y
toluene (lbs)31.0 14.1 28.2 19.7 16.9 19.7 16.9 25.4 25.4 16.9 19.7 11.3 234.1 0.1 4.44 2.6 Y
acetonitrile (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
benzene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
cumene (lbs)45.5 31.0 35.1 30.8 37.2 28.8 30.4 39.0 38.2 28.8 31.8 21.4 376.6 0.2
dichlorobenzene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
ethyl benzene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
ethylene glycol (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
hexane (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
methylene chloride (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
methanol (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
MIBK (lbs)163.2 113.8 144.4 92.8 117.9 124.9 125.7 141.3 154.3 97.6 125.1 92.2 1401.0 0.7
naphthalene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
perchloroethylene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
phenol (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
styrene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
trichloroethylene (lbs)0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
xylene (lbs)143.2 102.8 143.5 71.6 87.0 112.2 104.2 121.4 152.8 80.6 95.7 68.0 1215.1 0.6
Combined HAP (lbs)383.0 261.7 351.2 214.9 259.0 285.6 277.2 327.1 370.7 223.9 272.4 193.0 3226.8 1.6 15.70 10.3 Y
**How HAPs are calculated :
We take the product (paint/solvent), multiply the HAPs by the density and the usage we had of that product to get the emissions.
**Calculating for VOCs:
We take the product (paint/solvent), multiply by the VOC content and the usage we had of that product to get the emissions.
Autoliv Cover Painting
12-Month Rolling Emission Recordkeeping
Jordan Garahana <[e-mail]>
Records Request for Inspection
6 messages
Jordan Garahana <[e-mail]>Fri, Aug 23, 2024 at 10:19 AM
To: [e-mail]
Hello Leonard,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's division of Air Quality. I am
requesting some records as part of an inspection of the facility's operations located at 1000 West 3300 South in Ogden.
These are the records I am looking for:
The owner/operator shall not exceed the following consumption limits in the airbag module manufacturing plant:
A. 1,000 pounds of sand-blasting media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumption amounts for the items listed above.
The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module manufacturing plant and
coating line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene, dichlorobenzene, ethyl
benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl ketone, naphthalene, perchloroethylene,
phenol, styrene, trichloroethylene, and xylene.* * Any individual HAP included in this list shall have an emission limit less
than the Emission Threshold Value (ETV) for that chemical, as provided for in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions for the compounds
listed above. I also need a log that shows the comparison/calculation of the emission limit of the ETV to the
emission of the HAP.
The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmation that natural gas is the only fuel source utilized in the 60 kW and 80 kW generators.
The owner/operator shall install a diesel-fired emergency engine that is certified to meet a NOx emission rate of 2.80
g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30 g/hp-hr for each of the 40 kW engines; or
less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW engines onsite.
The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period
during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63
Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator was operated onsite,
including the date, hours of operation, and reason the generator was operated. Also, if you have any
maintenance logs for the generators that show it is being maintained according to manufacturer's
recommendations, that would be appreciated.
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a
sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel utilized onsite is classified as
ULSD.
For abrasive blasting, is the media that is used in abrasive blasting still glass beads?
For the coating of the plastic parts, what is the VOC content of the paint that is utilized for coating? On previous
inspections it was noted that the VOC content of the paint was 4.4 lb/gal. Are you still utilizing the same paints as noted in
the inspection conducted in 2021?
10/4/24, 11:23 AM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100358…1/6
Please let me know if you have any questions about the records I am requesting. Please have this for me by Monday,
August 26.
Thanks,
Jordan Garahana
--
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.
Brian Boudreaux <[e-mail]>Fri, Aug 23, 2024 at 11:07 AM
To: Jordan Garahana <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>, Brent Pedersen <[e-mail]>, Kent Parkinson
<[e-mail]>, Scott Billings <[e-mail]>, Jamieson Oleson
<[e-mail]>
Thank you, Jordan. My team will get on this.
Just to be clear, you want this by the end of business on Monday?
From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 10:19 AM
To: Brian Boudreaux <[e-mail]>
Subject: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using theReport Phishing button.]
[Quoted text hidden]
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
Jordan Garahana <[e-mail]>Fri, Aug 23, 2024 at 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>, Brent Pedersen <[e-mail]>, Kent Parkinson
<[e-mail]>, Scott Billings <[e-mail]>, Jamieson Oleson
<[e-mail]>
Hey Biran,
10/4/24, 11:23 AM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100358…2/6
Sorry about the date on when I need the records. If you could provide that to me by August 30 that would be great. Please
let me know if you have any questions or need more time than that to compile everything.
Thanks,
Jordan
[Quoted text hidden]
Brian Boudreaux <[e-mail]>Fri, Aug 23, 2024 at 11:11 AM
To: Jordan Garahana <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>, Brent Pedersen <[e-mail]>, Kent Parkinson
<[e-mail]>, Scott Billings <[e-mail]>, Jamieson Oleson
<[e-mail]>
Absolutely, we can for sure have it to you by 30th. I will keep you posted, but it seems very reasonable to
get it by the end of business on next Friday.
From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>; Brent Pedersen <[e-mail]>; Kent
Parkinson <[e-mail]>; Sco Billings <[e-mail]>; Jamieson Oleson
<[e-mail]>
Subject: Re: Records Request for Inspecon

[Quoted text hidden]
Brian Boudreaux <[e-mail]>Thu, Aug 29, 2024 at 3:23 PM
To: Jordan Garahana <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>, Brent Pedersen <[e-mail]>, Kent Parkinson
<[e-mail]>, Scott Billings <[e-mail]>, Jamieson Oleson
<[e-mail]>
Hey Jordan,
I wanted to provide you with the answers we have gathered around your queson. Please let me know if
you have any other quesons for us.
The owner/operator shall not exceed the following consumpon limits in the airbag module manufacturing
plant:
A. 1,000 pounds of sand-blasng media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumpon amounts for the items listed
above.

Please see aachment labeled Sec 1.
For A. and B., we use lile, if any, of these materials per year. Our sand-blasng machines get used once or
twice a year (low enough that they are considering decommissioning them) and we have one vehicle that
sll uses propane and some grills. We don’t consume enough to have any regular shipments or billing, and it
is bought on a company card on an as-needed basis.

10/4/24, 11:23 AM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100358…3/6
The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module
manufacturing plant and coang line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene,
dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl
ketone, naphthalene, perchloroethylene, phenol, styrene, trichloroethylene, and xylene.* * Any individual
HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for that
chemical, as provided for in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions for the
compounds listed above. I also need a log that shows the comparison/calculaon of the emission limit of
the ETV to the emission of the HAP.

Please see aachment labeled Sec 2. All HAP emission levels should fall below the ETV. All individual and
combined HAPs emissions for the rolling 12-month period are provided as well.

The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmaon that natural gas is the only fuel source ulized in the 60 kW and 80 kW generators.

Let us know if further confirmaon is needed.

The owner/operator shall install a diesel-fired emergency engine that is cerfied to meet a NOx emission
rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30 g/hp-hr for each
of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW engines onsite.

Please see aached files labeled “Genset8 100kw Spec Sheet,” “Genset10 125kw Spec Sheet,” and “Genset
9 40kw Spec Sheet”
Our 100, 125, and 40kw generators are EPA Tier III compliant.

The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling
12-month period during non-emergency situaons. There is no me limit on the use of the engines during
emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator was
operated onsite, including of the date, hours operaon, and reason the generator was operated. Also, if
you have any maintenance logs for the generators that show it is being maintained according to
manufacturer's recommendaons, that would be appreciated.
10/4/24, 11:23 AM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100358…4/6

Please see aachment labeled “Generator Usage from Aug 2023 to July 2024”.

The owner/operator shall only combust diesel fuel that meets the definion of ultra-low sulfur diesel
(ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel ulized onsite is
classified as ULSD.

Please see aachment labeled “July 2024 Diesel Invoice”.

For abrasive blasng, is the media that is used in abrasive blasng sll glass beads?

We have confirmed with our spares department that they are sll glass beads.

For the coang of the plasc parts, what is the VOC content of the paint that is ulized for coang? On
previous inspecons it was noted that the VOC content of the paint was 4.4 lb/gal. Are you sll ulizing the
same paints as noted in the inspecon conducted in 2021?

As for the paint that is ulized for coang, we have over 50 paints that are regularly used and each has its
own VOC content. The 4.4 lb/gal. was the average of these paints. Our current average is 5.81 lb/gal and we
calculate the VOC emissions based on the usage for each product with their individual VOC content.

Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>; Brent Pedersen <[e-mail]>; Kent
Parkinson <[e-mail]>; Sco Billings <[e-mail]>; Jamieson Oleson
<[e-mail]>
Subject: Re: Records Request for Inspecon

[Quoted text hidden]
7 attachments
10/4/24, 11:23 AM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100358…5/6
Sec 1 - Records Request DEQ.xlsx
624K
Generator Usage from Aug 2023 to July 2024.xlsx
18K
July 2024 Diesel Invoice - Proof of Low-Sulfur.pdf
468K
Genset 9 40kw Spec Sheet.pdf
349K
Genset 8 100kw Spec Sheet.pdf
349K
Genset 10 125 kw Spec Sheet.pdf
373K
Sec 2 - Records Request DEQ - Air Emission Tracking.pdf
67K
Jordan Garahana <[e-mail]>Tue, Sep 3, 2024 at 10:17 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>, Brent Pedersen <[e-mail]>, Kent Parkinson
<[e-mail]>, Scott Billings <[e-mail]>, Jamieson Oleson
<[e-mail]>
Hey Brian,
Thanks for getting back to me with the information I have requested. I will let you know if there is anything else I need for
my inspection.
Thanks,
Jordan
[Quoted text hidden]
10/4/24, 11:23 AM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100358…6/6
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Tuesday, November 12, 2024 2:17 PM
To: Brian Boudreaux <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
Jordan Garahana <[e-mail]>Thu, Nov 14, 2024 at 12:05 PM
To: Brian Boudreaux <[e-mail]>
Hey Brian,
If you could send me the SDS for some of your most used paints and maybe the one that has the highest VOC/lb content
that you can find if you are able to provide that. This is in reference to state rule R307-353-5 Table 1 for Plastic Parts
Coatings for Automobiles. I need to verify that the paints don't exceed the VOC lb/gal in that table based on their usage.
Here is a link to that rule for reference. Please let me know if you have any questions.
Thanks,
Jordan
[Quoted text hidden]
Brian Boudreaux <[e-mail]>Wed, Nov 20, 2024 at 2:23 PM
To: Jordan Garahana <[e-mail]>
Hello Jordan!
Sorry this took us a lile bit to get together for you. We realized we had the older SDSs in our files, and the
newer SDSs have the VOCs. We have been geng our VOCs from a database we created a few years ago, and
that is where all the informaon we look for us. Here are the top 3 SDSs that cover around 75% of our paint
usage each month. Just let us know if there is any more informaon or clarificaon you need.
Thanks,
Brian L. Boudreaux, CSP MSOSH
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-561982501003…7/104
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United Stateswww.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Thursday, November 14, 2024 12:05 PM
To: Brian Boudreaux <[e-mail]>
Subject: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[Quoted text hidden]
3 attachments
G52BU17_EDS_English_.pdf
118K
T1_643661400A_G56BU68 EDS.pdf
13K
642685400A_G52BU97_EDS_English.pdf
13K
Jordan Garahana <[e-mail]>Wed, Nov 20, 2024 at 3:04 PM
To: Chad Gilgen <[e-mail]>
Hey Chad,
I requested SDS information from Autoliv about the paints and they gave me the SDS for their three most used, which
included the highest VOC content out of all the paints they used. The VOC content for the highest used is 4.56 lb/gal and
according to R307-353-5 Table 1, this falls under the prime flexible coating for interior products, which is 4.5. This product
is distributed to the source from Sherwin Williams. Would this product be considered out of compliance and provide
compliance assistance stating that they need to find a new product? Or is this paint acceptable?
Thanks,
Jordan
[Quoted text hidden]
3 attachments
G52BU17_EDS_English_.pdf
118K
T1_643661400A_G56BU68 EDS.pdf
13K
642685400A_G52BU97_EDS_English.pdf
13K
Chad Gilgen <[e-mail]>Thu, Dec 5, 2024 at 8:28 PM
To: Jordan Garahana <[e-mail]>
Hi Jordan,
Yes, I think that may be the way to go. Before doing that, though, ask the source contact to look at the Coating Category in
Table 1 and confirm what category their coatings fall under (interior or exterior, baked or air-dried, etc.).
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-561982501003…8/104
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]>Mon, Dec 9, 2024 at 4:31 PM
To: Brian Boudreaux <[e-mail]>
Hey Brian,
Sorry for the delayed response to the information I requested about the paints, I was waiting for more information from my
supervisor before providing a response. Since these paints fall under a state rule, R307-353 for plastic parts coatings, can
you identify on the table in R307-353-5 Table 1 what the paints are used for specifically? I have attached the rule to this
email for your reference.
Thanks,
Jordan
[Quoted text hidden]
R307-353.pdf
97K
Jordan Garahana <[e-mail]>Mon, Dec 16, 2024 at 2:16 PM
To: Brian Boudreaux <[e-mail]>
Hey Brian,
Just checking in to see if you had had a chance to review the email and information I had sent. Please let me know as
soon as possible.
Thanks,
Jordan
[Quoted text hidden]
Brian Boudreaux <[e-mail]>Mon, Dec 16, 2024 at 2:24 PM
To: Jordan Garahana <[e-mail]>
I'm currently checking with my environmental guru to make sure I am reading this right. As of right now, all of
the paints that were sent are basecoats and we use a bake process since we don’t have any forced air that goes onto
the covers. As for exempons, we could possibly fall under (2) since we would be subject to the requirements from our
customers. I don’t know if an exempon will be necessary, though. Let me see what my local env guy says to be sure
Thanks,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-561982501003…9/104
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:16 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[Quoted text hidden]
Jordan Garahana <[e-mail]>Mon, Dec 16, 2024 at 2:36 PM
To: Brian Boudreaux <[e-mail]>
Hye Brian,
No worries. Please let me know what they say once they provide you with an answer.
Thanks,
Jordan
[Quoted text hidden]
10 attachments
image.png
48K
image.png
49K
Outlook-kgwppzka.png
49K
Outlook-egqni55h.png
8K
Outlook-pqjsyvah.png
49K
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…10/104
Outlook-rlg31te3.png
8K
Outlook-hm51dzuc.png
49K
Outlook-ji3zmdkx.png
8K
Outlook-qtkjvxow.png
49K
Outlook-yop2k5o5.png
8K
Brian Boudreaux <[e-mail]>Tue, Dec 17, 2024 at 7:27 AM
To: Jordan Garahana <[e-mail]>
Our environmental guru agrees with me. The customer mandates the specific types of paints that we use, so
we believe that exempon 2 would apply to the work that we do.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:36 PM
[Quoted text hidden]

[Quoted text hidden]
Jordan Garahana <[e-mail]>Tue, Dec 17, 2024 at 8:13 AM
To: Chad Gilgen <[e-mail]>
Hey Chad,

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…11/104
Autoliv believes they fall under exemption number 2 of R307-353-3 since that is an existing coating line. Do you have any
thoughts on their response for this?
Thanks,
Jordan
---------- Forwarded message ---------
From: Brian Boudreaux <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
2 attachments
Outlook-hvr2a0gv.png
49K
Outlook-lnvzj4pc.png
8K
Chad Gilgen <[e-mail]>Tue, Dec 17, 2024 at 9:56 AM
To: Jordan Garahana <[e-mail]>
Jordan,
The exemption from R307-353 they reference only applies if they are subject to another one of our coating rules such as
R307-350, 352, or 354. They would need to provide an explanation detailing which one of the coating rules applies in
order to be exempt from 353.
They also received a new AO on August 28, 2024, with condition II.B.2.a specifically stating they are subject to R307-353.
If they believed they were exempt from this rule, the AO modification process would have been the best time to address
that so they could have the appropriate rule referenced.
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]>Mon, Dec 23, 2024 at 10:37 AM
To: Brian Boudreaux <[e-mail]>
Hey Brian,
I consulted my manager on what you responded with regarding R307-353-3 and this is what he had to say in regards to the
exemption:
"The exemption from R307-353 they reference only applies if they are subject to another one of our coating rules such as
R307-350, 352, or 354. They would need to provide an explanation detailing which one of the coating rules applies in
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…12/104
order to be exempt from 353.
They also received a new AO on August 28, 2024, with condition II.B.2.a specifically stating they are subject to R307-353.
If they believed they were exempt from this rule, the AO modification process would have been the best time to address
that so they could have the appropriate rule referenced."
If you think your company is exempt from R307-353, which of those other rules listed do you think would apply to your
business best? Please let me know if you have any questions.
Thanks,
Jordan
[Quoted text hidden]
Brian Boudreaux <[e-mail]>Mon, Jan 6, 2025 at 6:55 AM
To: Jordan Garahana <[e-mail]>
Good morning!
I realize you sent this two weeks ago, but we are now back in office. I will follow up with this email and get
back to you shortly.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United Stateswww.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 23, 2024 10:37 AM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using theReport Phishing button.]
Hey Brian,
I consulted my manager on what you responded with regarding R307-353-3 and this is what he had to say in regards to the
exemption:
"The exemption from R307-353 they reference only applies if they are subject to another one of our coating rules such as
R307-350, 352, or 354. They would need to provide an explanation detailing which one of the coating rules applies in
order to be exempt from 353.
They also received a new AO on August 28, 2024, with condition II.B.2.a specifically stating they are subject to R307-353.
If they believed they were exempt from this rule, the AO modification process would have been the best time to address
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…13/104
that so they could have the appropriate rule referenced."
If you think your company is exempt from R307-353, which of those other rules listed do you think would apply to your
business best? Please let me know if you have any questions.
Thanks,
Jordan
On Tue, Dec 17, 2024 at 7:27 AM Brian Boudreaux <[e-mail]> wrote:
Our environmental guru agrees with me. The customer mandates the specific types of paints that we use,
so we believe that exempon 2 would apply to the work that we do.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:36 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails usingthe Report Phishing button.]
Hye Brian,
No worries. Please let me know what they say once they provide you with an answer.
Thanks,
Jordan
On Mon, Dec 16, 2024 at 2:24 PM Brian Boudreaux <[e-mail]> wrote:
I'm currently checking with my environmental guru to make sure I am reading this right. As of right now,
all of the paints that were sent are basecoats and we use a bake process since we don’t have any forced air that
goes onto the covers. As for exempons, we could possibly fall under (2) since we would be subject to the
requirements from our customers. I don’t know if an exempon will be necessary, though. Let me see what my
local env guy says to be sure
Thanks,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…14/104
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:16 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using
the Report Phishing button.]
Hey Brian,
Just checking in to see if you had had a chance to review the email and information I had sent. Please let me know as
soon as possible.
Thanks,
Jordan
On Mon, Dec 9, 2024 at 4:31 PM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Sorry for the delayed response to the information I requested about the paints, I was waiting for more information
from my supervisor before providing a response. Since these paints fall under a state rule, R307-353 for plastic
parts coatings, can you identify on the table in R307-353-5 Table 1 what the paints are used for specifically? I have
attached the rule to this email for your reference.
Thanks,
Jordan
On Wed, Nov 20, 2024 at 2:23 PM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan!
Sorry this took us a lile bit to get together for you. We realized we had the older SDSs in our files,
and the newer SDSs have the VOCs. We have been geng our VOCs from a database we created a
few years ago, and that is where all the informaon we look for us. Here are the top 3 SDSs that
cover around 75% of our paint usage each month. Just let us know if there is any more informaon
or clarificaon you need.
Thanks,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…15/104
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Thursday, November 14, 2024 12:05 PM
To: Brian Boudreaux <[e-mail]>
Subject: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails
using the Report Phishing button.]
Hey Brian,
If you could send me the SDS for some of your most used paints and maybe the one that has the highest VOC/lb
content that you can find if you are able to provide that. This is in reference to state rule R307-353-5 Table 1 for
Plastic Parts Coatings for Automobiles. I need to verify that the paints don't exceed the VOC lb/gal in that table
based on their usage. Here is a link to that rule for reference. Please let me know if you have any questions.
Thanks,
Jordan
On Thu, Nov 14, 2024 at 11:42 AM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan,
Sorry that I took so long to respond - I have been out of office all week so far. As to your queson,
we have roughly over 70 different paints on our records that we cycle through. How would you like
to receive the SDSs? Would it work best to show you our most heavily used paints, a few at
random, a certain number? Whatever works best for you, but we do have a significant amount due
to the demands of the different customers - everyone has their own shade of black.

The process we use for calculang our emissions includes the VOC content from each paint which
we get from the individual SDS’s. Just let me know how you will like to proceed and I can send
them over to you.
Thanks,
Brian L. Boudreaux, CSP MSOSH
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…16/104
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Tuesday, November 12, 2024 2:17 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspiciousemails using the Report Phishing button.]
Hey Brian,
I have one more additional request about the paints you listed in your response. Do you happen to have more
information specifically about the VOC content in lbs/gallon of the paints that are used for coatings? If you have
something from your paint provider like an SDS or data sheet that shows that VOC content would be helpful.
Thanks,
Jordan
On Tue, Sep 3, 2024 at 10:17 AM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Thanks for getting back to me with the information I have requested. I will let you know if there is anything
else I need for my inspection.
Thanks,
Jordan
On Thu, Aug 29, 2024 at 3:24 PM Brian Boudreaux <[e-mail]> wrote:
Hey Jordan,
I wanted to provide you with the answers we have gathered around your queson. Please let
me know if you have any other quesons for us.
The owner/operator shall not exceed the following consumpon limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasng media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumpon amounts for the
items listed above.

Please see aachment labeled Sec 1.
For A. and B., we use lile, if any, of these materials per year. Our sand-blasng machines get
used once or twice a year (low enough that they are considering decommissioning them) and
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…17/104
we have one vehicle that sll uses propane and some grills. We don’t consume enough to have
any regular shipments or billing, and it is bought on a company card on an as-needed basis.

The owner/operator shall not exceed the following VOC and HAP emissions in the airbag
module manufacturing plant and coang line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for
formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene,
cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride,
methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene,
trichloroethylene, and xylene.* * Any individual HAP included in this list shall have an
emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for
in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions
for the compounds listed above. I also need a log that shows the comparison/calculaon of
the emission limit of the ETV to the emission of the HAP.

Please see aachment labeled Sec 2. All HAP emission levels should fall below the ETV. All
individual and combined HAPs emissions for the rolling 12-month period are provided as well.

The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmaon that natural gas is the only fuel source ulized in the 60 kW and 80 kW
generators.

Let us know if further confirmaon is needed.

The owner/operator shall install a diesel-fired emergency engine that is cerfied to meet a
NOx emission rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine;
and 3.30 g/hp-hr for each of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63
Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW
engines onsite.

Please see aached files labeled “Genset8 100kw Spec Sheet,” “Genset10 125kw Spec Sheet,”
and “Genset 9 40kw Spec Sheet”
Our 100, 125, and 40kw generators are EPA Tier III compliant.

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…18/104
The owner/operator shall not operate each emergency engine on site for more than 100 hours
per rolling 12-month period during non-emergency situaons. There is no me limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator
was operated onsite, including of the date, hours operaon, and reason the generator was
operated. Also, if you have any maintenance logs for the generators that show it is being
maintained according to manufacturer's recommendaons, that would be appreciated.

Please see aachment labeled “Generator Usage from Aug 2023 to July 2024”.

The owner/operator shall only combust diesel fuel that meets the definion of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel ulized
onsite is classified as ULSD.

Please see aachment labeled “July 2024 Diesel Invoice”.

For abrasive blasng, is the media that is used in abrasive blasng sll glass beads?

We have confirmed with our spares department that they are sll glass beads.

For the coang of the plasc parts, what is the VOC content of the paint that is ulized for
coang? On previous inspecons it was noted that the VOC content of the paint was 4.4 lb/gal.
Are you sll ulizing the same paints as noted in the inspecon conducted in 2021?

As for the paint that is ulized for coang, we have over 50 paints that are regularly used and
each has its own VOC content. The 4.4 lb/gal. was the average of these paints. Our current
average is 5.81 lb/gal and we calculate the VOC emissions based on the usage for each product
with their individual VOC content.

Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>; Brent Pedersen
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…19/104
<[e-mail]>; Kent Parkinson <[e-mail]>; Sco Billings
<[e-mail]>; Jamieson Oleson <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hey Biran,
Sorry about the date on when I need the records. If you could provide that to me by August 30 that would
be great. Please let me know if you have any questions or need more time than that to compile everything.
Thanks,
Jordan
On Fri, Aug 23, 2024 at 11:07 AM Brian Boudreaux <[e-mail]> wrote:
Thank you, Jordan. My team will get on this.
Just to be clear, you want this by the end of business on Monday?
From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 10:19 AM
To: Brian Boudreaux <[e-mail]>
Subject: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hello Leonard,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's division of Air
Quality. I am requesting some records as part of an inspection of the facility's operations located at 1000
West 3300 South in Ogden. These are the records I am looking for:
The owner/operator shall not exceed the following consumption limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasting media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumption amounts for the items
listed above.
The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module
manufacturing plant and coating line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene,
dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl
ketone, naphthalene, perchloroethylene, phenol, styrene, trichloroethylene, and xylene.* * Any individual
HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for
that chemical, as provided for in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions for
the compounds listed above. I also need a log that shows the comparison/calculation of the
emission limit of the ETV to the emission of the HAP.
The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmation that natural gas is the only fuel source utilized in the 60 kW and 80 kW
generators.
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…20/104
The owner/operator shall install a diesel-fired emergency engine that is certified to meet a NOx emission
rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30 g/hp-hr for each
of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW engines
onsite.
The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling
12-month period during non-emergency situations. There is no time limit on the use of the engines
during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator was
operated onsite, including the date, hours of operation, and reason the generator was operated.
Also, if you have any maintenance logs for the generators that show it is being maintained
according to manufacturer's recommendations, that would be appreciated.
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel
(ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel utilized onsite
is classified as ULSD.
For abrasive blasting, is the media that is used in abrasive blasting still glass beads?
For the coating of the plastic parts, what is the VOC content of the paint that is utilized for coating? On
previous inspections it was noted that the VOC content of the paint was 4.4 lb/gal. Are you still utilizing
the same paints as noted in the inspection conducted in 2021?
Please let me know if you have any questions about the records I am requesting. Please have this for
me by Monday, August 26.
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…21/104
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…22/104
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…23/104
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…24/104
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
Brian Boudreaux <[e-mail]>Mon, Jan 6, 2025 at 1:58 PM
To: Jordan Garahana <[e-mail]>
Hello,
In reviewing the Air Permit, we found that the R307-353 is the best one that fits our process. This is already in our
AO as far as we can tell, so it would not require any revisions. Perhaps I am reading all of this wrong. Let's go back to
your original queson. In the Table you referenced - R307-353-5, this would be considered an air-dried coang for an
interior part. These items are typically covers that go over the airbags when installed within a vehicle. I'm sorry for my
confusion - sll geng used to reading these air permits.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…25/104
From: Jordan Garahana <[e-mail]>
Sent: Monday, December 23, 2024 10:37 AM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using the
Report Phishing button.]
Hey Brian,
I consulted my manager on what you responded with regarding R307-353-3 and this is what he had to say in regards to the
exemption:
"The exemption from R307-353 they reference only applies if they are subject to another one of our coating rules such as
R307-350, 352, or 354. They would need to provide an explanation detailing which one of the coating rules applies in
order to be exempt from 353.
They also received a new AO on August 28, 2024, with condition II.B.2.a specifically stating they are subject to R307-353.
If they believed they were exempt from this rule, the AO modification process would have been the best time to address
that so they could have the appropriate rule referenced."
If you think your company is exempt from R307-353, which of those other rules listed do you think would apply to your
business best? Please let me know if you have any questions.
Thanks,
Jordan
On Tue, Dec 17, 2024 at 7:27 AM Brian Boudreaux <[e-mail]> wrote:
Our environmental guru agrees with me. The customer mandates the specific types of paints that we use,
so we believe that exempon 2 would apply to the work that we do.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:36 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using
the Report Phishing button.]
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…26/104
Hye Brian,
No worries. Please let me know what they say once they provide you with an answer.
Thanks,
Jordan
On Mon, Dec 16, 2024 at 2:24 PM Brian Boudreaux <[e-mail]> wrote:
I'm currently checking with my environmental guru to make sure I am reading this right. As of right now,
all of the paints that were sent are basecoats and we use a bake process since we don’t have any forced air that
goes onto the covers. As for exempons, we could possibly fall under (2) since we would be subject to the
requirements from our customers. I don’t know if an exempon will be necessary, though. Let me see what my
local env guy says to be sure
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:16 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using
the Report Phishing button.]
Hey Brian,
Just checking in to see if you had had a chance to review the email and information I had sent. Please let me know as
soon as possible.
Thanks,
Jordan
On Mon, Dec 9, 2024 at 4:31 PM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Sorry for the delayed response to the information I requested about the paints, I was waiting for more information
from my supervisor before providing a response. Since these paints fall under a state rule, R307-353 for plastic
parts coatings, can you identify on the table in R307-353-5 Table 1 what the paints are used for specifically? I have
attached the rule to this email for your reference.
Thanks,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…27/104
Jordan
On Wed, Nov 20, 2024 at 2:23 PM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan!
Sorry this took us a lile bit to get together for you. We realized we had the older SDSs in our files,
and the newer SDSs have the VOCs. We have been geng our VOCs from a database we created a
few years ago, and that is where all the informaon we look for us. Here are the top 3 SDSs that
cover around 75% of our paint usage each month. Just let us know if there is any more informaon
or clarificaon you need.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United Stateswww.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Thursday, November 14, 2024 12:05 PM
To: Brian Boudreaux <[e-mail]>
Subject: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emailsusing the Report Phishing button.]
Hey Brian,
If you could send me the SDS for some of your most used paints and maybe the one that has the highest VOC/lb
content that you can find if you are able to provide that. This is in reference to state rule R307-353-5 Table 1 for
Plastic Parts Coatings for Automobiles. I need to verify that the paints don't exceed the VOC lb/gal in that table
based on their usage. Here is a link to that rule for reference. Please let me know if you have any questions.
Thanks,
Jordan
On Thu, Nov 14, 2024 at 11:42 AM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan,
Sorry that I took so long to respond - I have been out of office all week so far. As to your queson,
we have roughly over 70 different paints on our records that we cycle through. How would you like
to receive the SDSs? Would it work best to show you our most heavily used paints, a few at
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…28/104
random, a certain number? Whatever works best for you, but we do have a significant amount due
to the demands of the different customers - everyone has their own shade of black.

The process we use for calculang our emissions includes the VOC content from each paint which
we get from the individual SDS’s. Just let me know how you will like to proceed and I can send
them over to you.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Tuesday, November 12, 2024 2:17 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious
emails using the Report Phishing button.]
Hey Brian,
I have one more additional request about the paints you listed in your response. Do you happen to have more
information specifically about the VOC content in lbs/gallon of the paints that are used for coatings? If you have
something from your paint provider like an SDS or data sheet that shows that VOC content would be helpful.
Thanks,
Jordan
On Tue, Sep 3, 2024 at 10:17 AM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Thanks for getting back to me with the information I have requested. I will let you know if there is anything
else I need for my inspection.
Thanks,
Jordan
On Thu, Aug 29, 2024 at 3:24 PM Brian Boudreaux <[e-mail]> wrote:
Hey Jordan,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…29/104
I wanted to provide you with the answers we have gathered around your queson. Please let
me know if you have any other quesons for us.
The owner/operator shall not exceed the following consumpon limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasng media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumpon amounts for the
items listed above.

Please see aachment labeled Sec 1.
For A. and B., we use lile, if any, of these materials per year. Our sand-blasng machines get
used once or twice a year (low enough that they are considering decommissioning them) and
we have one vehicle that sll uses propane and some grills. We don’t consume enough to have
any regular shipments or billing, and it is bought on a company card on an as-needed basis.

The owner/operator shall not exceed the following VOC and HAP emissions in the airbag
module manufacturing plant and coang line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for
formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene,
cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride,
methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene,
trichloroethylene, and xylene.* * Any individual HAP included in this list shall have an
emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for
in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions
for the compounds listed above. I also need a log that shows the comparison/calculaon of
the emission limit of the ETV to the emission of the HAP.

Please see aachment labeled Sec 2. All HAP emission levels should fall below the ETV. All
individual and combined HAPs emissions for the rolling 12-month period are provided as well.

The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmaon that natural gas is the only fuel source ulized in the 60 kW and 80 kW
generators.

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…30/104
Let us know if further confirmaon is needed.

The owner/operator shall install a diesel-fired emergency engine that is cerfied to meet a
NOx emission rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine;
and 3.30 g/hp-hr for each of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63
Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW
engines onsite.

Please see aached files labeled “Genset8 100kw Spec Sheet,” “Genset10 125kw Spec Sheet,”
and “Genset 9 40kw Spec Sheet”
Our 100, 125, and 40kw generators are EPA Tier III compliant.

The owner/operator shall not operate each emergency engine on site for more than 100 hours
per rolling 12-month period during non-emergency situaons. There is no me limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator
was operated onsite, including of the date, hours operaon, and reason the generator was
operated. Also, if you have any maintenance logs for the generators that show it is being
maintained according to manufacturer's recommendaons, that would be appreciated.

Please see aachment labeled “Generator Usage from Aug 2023 to July 2024”.

The owner/operator shall only combust diesel fuel that meets the definion of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel ulized
onsite is classified as ULSD.

Please see aachment labeled “July 2024 Diesel Invoice”.

For abrasive blasng, is the media that is used in abrasive blasng sll glass beads?

We have confirmed with our spares department that they are sll glass beads.

For the coang of the plasc parts, what is the VOC content of the paint that is ulized for
coang? On previous inspecons it was noted that the VOC content of the paint was 4.4 lb/gal.
Are you sll ulizing the same paints as noted in the inspecon conducted in 2021?

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…31/104
As for the paint that is ulized for coang, we have over 50 paints that are regularly used and
each has its own VOC content. The 4.4 lb/gal. was the average of these paints. Our current
average is 5.81 lb/gal and we calculate the VOC emissions based on the usage for each product
with their individual VOC content.

Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>; Brent Pedersen
<[e-mail]>; Kent Parkinson <[e-mail]>; Sco Billings
<[e-mail]>; Jamieson Oleson <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hey Biran,
Sorry about the date on when I need the records. If you could provide that to me by August 30 that would
be great. Please let me know if you have any questions or need more time than that to compile everything.
Thanks,
Jordan
On Fri, Aug 23, 2024 at 11:07 AM Brian Boudreaux <[e-mail]> wrote:
Thank you, Jordan. My team will get on this.
Just to be clear, you want this by the end of business on Monday?
From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 10:19 AM
To: Brian Boudreaux <[e-mail]>
Subject: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hello Leonard,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…32/104
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's division of Air
Quality. I am requesting some records as part of an inspection of the facility's operations located at 1000
West 3300 South in Ogden. These are the records I am looking for:
The owner/operator shall not exceed the following consumption limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasting media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumption amounts for the items
listed above.
The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module
manufacturing plant and coating line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene,
dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl
ketone, naphthalene, perchloroethylene, phenol, styrene, trichloroethylene, and xylene.* * Any individual
HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for
that chemical, as provided for in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions for
the compounds listed above. I also need a log that shows the comparison/calculation of the
emission limit of the ETV to the emission of the HAP.
The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmation that natural gas is the only fuel source utilized in the 60 kW and 80 kW
generators.
The owner/operator shall install a diesel-fired emergency engine that is certified to meet a NOx emission
rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30 g/hp-hr for each
of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW engines
onsite.
The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling
12-month period during non-emergency situations. There is no time limit on the use of the engines
during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator was
operated onsite, including the date, hours of operation, and reason the generator was operated.
Also, if you have any maintenance logs for the generators that show it is being maintained
according to manufacturer's recommendations, that would be appreciated.
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel
(ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel utilized onsite
is classified as ULSD.
For abrasive blasting, is the media that is used in abrasive blasting still glass beads?
For the coating of the plastic parts, what is the VOC content of the paint that is utilized for coating? On
previous inspections it was noted that the VOC content of the paint was 4.4 lb/gal. Are you still utilizing
the same paints as noted in the inspection conducted in 2021?
Please let me know if you have any questions about the records I am requesting. Please have this for
me by Monday, August 26.
Thanks,
Jordan Garahana
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…33/104
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…34/104
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…35/104
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…36/104
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
Jordan Garahana <[e-mail]>Mon, Jan 6, 2025 at 3:18 PM
To: Chad Gilgen <[e-mail]>
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…37/104
Hey Chad,
I received a response from Brian about R307-353 and the exemption he thought he qualified for from this rule. After he
reviewed with his team, he stated that R307-353 does apply and that based on the table within R307-353, the coating is an
air-dried coating for interior parts since these go on the airbags, making the VOC limit 5.0 lb/gal. He previously stated that
the highest VOC coating used was 4.56 lb/gal, which would make his operations compliant with R307-353. I think since he
is new at this position he was confused/unsure about how to interpret the rule in regard to his operations. Please let me
know if there is anything else I need to provide from him for my memo in order to get this filed.
Thanks,
Jordan
---------- Forwarded message ---------
From: Brian Boudreaux <[e-mail]>
Date: Mon, Jan 6, 2025 at 1:59 PM
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspection
To: Jordan Garahana <[e-mail]>
Hello,
In reviewing the Air Permit, we found that the R307-353 is the best one that fits our process. This is already in our
AO as far as we can tell, so it would not require any revisions. Perhaps I am reading all of this wrong. Let's go back to
your original queson. In the Table you referenced - R307-353-5, this would be considered an air-dried coang for an
interior part. These items are typically covers that go over the airbags when installed within a vehicle. I'm sorry for my
confusion - sll geng used to reading these air permits.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United Stateswww.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 23, 2024 10:37 AM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using theReport Phishing button.]
Hey Brian,
I consulted my manager on what you responded with regarding R307-353-3 and this is what he had to say in regards to the
exemption:
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…38/104
"The exemption from R307-353 they reference only applies if they are subject to another one of our coating rules such as
R307-350, 352, or 354. They would need to provide an explanation detailing which one of the coating rules applies in
order to be exempt from 353.
They also received a new AO on August 28, 2024, with condition II.B.2.a specifically stating they are subject to R307-353.
If they believed they were exempt from this rule, the AO modification process would have been the best time to address
that so they could have the appropriate rule referenced."
If you think your company is exempt from R307-353, which of those other rules listed do you think would apply to your
business best? Please let me know if you have any questions.
Thanks,
Jordan
On Tue, Dec 17, 2024 at 7:27 AM Brian Boudreaux <[e-mail]> wrote:
Our environmental guru agrees with me. The customer mandates the specific types of paints that we use,
so we believe that exempon 2 would apply to the work that we do.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United Stateswww.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:36 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails usingthe Report Phishing button.]
Hye Brian,
No worries. Please let me know what they say once they provide you with an answer.
Thanks,
Jordan
On Mon, Dec 16, 2024 at 2:24 PM Brian Boudreaux <[e-mail]> wrote:
I'm currently checking with my environmental guru to make sure I am reading this right. As of right now,
all of the paints that were sent are basecoats and we use a bake process since we don’t have any forced air that
goes onto the covers. As for exempons, we could possibly fall under (2) since we would be subject to the
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…39/104
requirements from our customers. I don’t know if an exempon will be necessary, though. Let me see what my
local env guy says to be sure
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:16 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails using
the Report Phishing button.]
Hey Brian,
Just checking in to see if you had had a chance to review the email and information I had sent. Please let me know as
soon as possible.
Thanks,
Jordan
On Mon, Dec 9, 2024 at 4:31 PM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Sorry for the delayed response to the information I requested about the paints, I was waiting for more information
from my supervisor before providing a response. Since these paints fall under a state rule, R307-353 for plastic
parts coatings, can you identify on the table in R307-353-5 Table 1 what the paints are used for specifically? I have
attached the rule to this email for your reference.
Thanks,
Jordan
On Wed, Nov 20, 2024 at 2:23 PM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan!
Sorry this took us a lile bit to get together for you. We realized we had the older SDSs in our files,
and the newer SDSs have the VOCs. We have been geng our VOCs from a database we created a
few years ago, and that is where all the informaon we look for us. Here are the top 3 SDSs that
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…40/104
cover around 75% of our paint usage each month. Just let us know if there is any more informaon
or clarificaon you need.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Thursday, November 14, 2024 12:05 PM
To: Brian Boudreaux <[e-mail]>
Subject: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emailsusing the Report Phishing button.]
Hey Brian,
If you could send me the SDS for some of your most used paints and maybe the one that has the highest VOC/lb
content that you can find if you are able to provide that. This is in reference to state rule R307-353-5 Table 1 for
Plastic Parts Coatings for Automobiles. I need to verify that the paints don't exceed the VOC lb/gal in that table
based on their usage. Here is a link to that rule for reference. Please let me know if you have any questions.
Thanks,
Jordan
On Thu, Nov 14, 2024 at 11:42 AM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan,
Sorry that I took so long to respond - I have been out of office all week so far. As to your queson,
we have roughly over 70 different paints on our records that we cycle through. How would you like
to receive the SDSs? Would it work best to show you our most heavily used paints, a few at
random, a certain number? Whatever works best for you, but we do have a significant amount due
to the demands of the different customers - everyone has their own shade of black.

The process we use for calculang our emissions includes the VOC content from each paint which
we get from the individual SDS’s. Just let me know how you will like to proceed and I can send
them over to you.
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…41/104
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Tuesday, November 12, 2024 2:17 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious
emails using the Report Phishing button.]
Hey Brian,
I have one more additional request about the paints you listed in your response. Do you happen to have more
information specifically about the VOC content in lbs/gallon of the paints that are used for coatings? If you have
something from your paint provider like an SDS or data sheet that shows that VOC content would be helpful.
Thanks,
Jordan
On Tue, Sep 3, 2024 at 10:17 AM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Thanks for getting back to me with the information I have requested. I will let you know if there is anything
else I need for my inspection.
Thanks,
Jordan
On Thu, Aug 29, 2024 at 3:24 PM Brian Boudreaux <[e-mail]> wrote:
Hey Jordan,
I wanted to provide you with the answers we have gathered around your queson. Please let
me know if you have any other quesons for us.
The owner/operator shall not exceed the following consumpon limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasng media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…42/104
I need a record from August 2023 to July 2024 showing the consumpon amounts for the
items listed above.

Please see aachment labeled Sec 1.
For A. and B., we use lile, if any, of these materials per year. Our sand-blasng machines get
used once or twice a year (low enough that they are considering decommissioning them) and
we have one vehicle that sll uses propane and some grills. We don’t consume enough to have
any regular shipments or billing, and it is bought on a company card on an as-needed basis.

The owner/operator shall not exceed the following VOC and HAP emissions in the airbag
module manufacturing plant and coang line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for
formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene,
cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride,
methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene,
trichloroethylene, and xylene.* * Any individual HAP included in this list shall have an
emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for
in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions
for the compounds listed above. I also need a log that shows the comparison/calculaon of
the emission limit of the ETV to the emission of the HAP.

Please see aachment labeled Sec 2. All HAP emission levels should fall below the ETV. All
individual and combined HAPs emissions for the rolling 12-month period are provided as well.

The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmaon that natural gas is the only fuel source ulized in the 60 kW and 80 kW
generators.

Let us know if further confirmaon is needed.

The owner/operator shall install a diesel-fired emergency engine that is cerfied to meet a
NOx emission rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine;
and 3.30 g/hp-hr for each of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63
Subpart ZZZZ, R307-401-8]
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…43/104
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW
engines onsite.

Please see aached files labeled “Genset8 100kw Spec Sheet,” “Genset10 125kw Spec Sheet,”
and “Genset 9 40kw Spec Sheet”
Our 100, 125, and 40kw generators are EPA Tier III compliant.

The owner/operator shall not operate each emergency engine on site for more than 100 hours
per rolling 12-month period during non-emergency situaons. There is no me limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator
was operated onsite, including of the date, hours operaon, and reason the generator was
operated. Also, if you have any maintenance logs for the generators that show it is being
maintained according to manufacturer's recommendaons, that would be appreciated.

Please see aachment labeled “Generator Usage from Aug 2023 to July 2024”.

The owner/operator shall only combust diesel fuel that meets the definion of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel ulized
onsite is classified as ULSD.

Please see aachment labeled “July 2024 Diesel Invoice”.

For abrasive blasng, is the media that is used in abrasive blasng sll glass beads?

We have confirmed with our spares department that they are sll glass beads.

For the coang of the plasc parts, what is the VOC content of the paint that is ulized for
coang? On previous inspecons it was noted that the VOC content of the paint was 4.4 lb/gal.
Are you sll ulizing the same paints as noted in the inspecon conducted in 2021?

As for the paint that is ulized for coang, we have over 50 paints that are regularly used and
each has its own VOC content. The 4.4 lb/gal. was the average of these paints. Our current
average is 5.81 lb/gal and we calculate the VOC emissions based on the usage for each product
with their individual VOC content.

Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United Stateswww.autoliv.com
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…44/104

From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>; Brent Pedersen
<[e-mail]>; Kent Parkinson <[e-mail]>; Sco Billings
<[e-mail]>; Jamieson Oleson <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hey Biran,
Sorry about the date on when I need the records. If you could provide that to me by August 30 that would
be great. Please let me know if you have any questions or need more time than that to compile everything.
Thanks,
Jordan
On Fri, Aug 23, 2024 at 11:07 AM Brian Boudreaux <[e-mail]> wrote:
Thank you, Jordan. My team will get on this.
Just to be clear, you want this by the end of business on Monday?
From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 10:19 AM
To: Brian Boudreaux <[e-mail]>
Subject: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report
suspicious emails using the Report Phishing button.]
Hello Leonard,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's division of Air
Quality. I am requesting some records as part of an inspection of the facility's operations located at 1000
West 3300 South in Ogden. These are the records I am looking for:
The owner/operator shall not exceed the following consumption limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasting media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumption amounts for the items
listed above.
The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module
manufacturing plant and coating line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene,
dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl isobutyl
ketone, naphthalene, perchloroethylene, phenol, styrene, trichloroethylene, and xylene.* * Any individual
HAP included in this list shall have an emission limit less than the Emission Threshold Value (ETV) for
that chemical, as provided for in R307-410-5.
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…45/104
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions for
the compounds listed above. I also need a log that shows the comparison/calculation of the
emission limit of the ETV to the emission of the HAP.
The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmation that natural gas is the only fuel source utilized in the 60 kW and 80 kW
generators.
The owner/operator shall install a diesel-fired emergency engine that is certified to meet a NOx emission
rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30 g/hp-hr for each
of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW engines
onsite.
The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling
12-month period during non-emergency situations. There is no time limit on the use of the engines
during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator was
operated onsite, including the date, hours of operation, and reason the generator was operated.
Also, if you have any maintenance logs for the generators that show it is being maintained
according to manufacturer's recommendations, that would be appreciated.
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel
(ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel utilized onsite
is classified as ULSD.
For abrasive blasting, is the media that is used in abrasive blasting still glass beads?
For the coating of the plastic parts, what is the VOC content of the paint that is utilized for coating? On
previous inspections it was noted that the VOC content of the paint was 4.4 lb/gal. Are you still utilizing
the same paints as noted in the inspection conducted in 2021?
Please let me know if you have any questions about the records I am requesting. Please have this for
me by Monday, August 26.
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…46/104
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…47/104
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…48/104
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…49/104
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
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.
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…50/104
Chad Gilgen <[e-mail]>Fri, Jan 10, 2025 at 10:30 AM
To: Jordan Garahana <[e-mail]>
Hi Jordan,
Thanks for gathering that additional information. It looks like this one is good for the memo to be written and submitted.
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.
On Mon, Jan 6, 2025 at 3:18 PM Jordan Garahana <[e-mail]> wrote:
Hey Chad,
I received a response from Brian about R307-353 and the exemption he thought he qualified for from this rule. After he
reviewed with his team, he stated that R307-353 does apply and that based on the table within R307-353, the coating is
an air-dried coating for interior parts since these go on the airbags, making the VOC limit 5.0 lb/gal. He previously stated
that the highest VOC coating used was 4.56 lb/gal, which would make his operations compliant with R307-353. I think
since he is new at this position he was confused/unsure about how to interpret the rule in regard to his operations.
Please let me know if there is anything else I need to provide from him for my memo in order to get this filed.
Thanks,
Jordan
---------- Forwarded message ---------
From: Brian Boudreaux <[e-mail]>
Date: Mon, Jan 6, 2025 at 1:59 PM
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspection
To: Jordan Garahana <[e-mail]>
Hello,
In reviewing the Air Permit, we found that the R307-353 is the best one that fits our process. This is already in our
AO as far as we can tell, so it would not require any revisions. Perhaps I am reading all of this wrong. Let's go back to
your original queson. In the Table you referenced - R307-353-5, this would be considered an air-dried coang for an
interior part. These items are typically covers that go over the airbags when installed within a vehicle. I'm sorry for
my confusion - sll geng used to reading these air permits.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…51/104
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 23, 2024 10:37 AM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails usingthe Report Phishing button.]
Hey Brian,
I consulted my manager on what you responded with regarding R307-353-3 and this is what he had to say in regards to
the exemption:
"The exemption from R307-353 they reference only applies if they are subject to another one of our coating rules such
as R307-350, 352, or 354. They would need to provide an explanation detailing which one of the coating rules applies in
order to be exempt from 353.
They also received a new AO on August 28, 2024, with condition II.B.2.a specifically stating they are subject to R307-
353. If they believed they were exempt from this rule, the AO modification process would have been the best time to
address that so they could have the appropriate rule referenced."
If you think your company is exempt from R307-353, which of those other rules listed do you think would apply to your
business best? Please let me know if you have any questions.
Thanks,
Jordan
On Tue, Dec 17, 2024 at 7:27 AM Brian Boudreaux <[e-mail]> wrote:
Our environmental guru agrees with me. The customer mandates the specific types of paints that we
use, so we believe that exempon 2 would apply to the work that we do.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…52/104
From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:36 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails usingthe Report Phishing button.]
Hye Brian,
No worries. Please let me know what they say once they provide you with an answer.
Thanks,
Jordan
On Mon, Dec 16, 2024 at 2:24 PM Brian Boudreaux <[e-mail]> wrote:
I'm currently checking with my environmental guru to make sure I am reading this right. As of right
now, all of the paints that were sent are basecoats and we use a bake process since we don’t have any forced air
that goes onto the covers. As for exempons, we could possibly fall under (2) since we would be subject to the
requirements from our customers. I don’t know if an exempon will be necessary, though. Let me see what my
local env guy says to be sure
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, December 16, 2024 2:16 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspicious emails
using the Report Phishing button.]
Hey Brian,
Just checking in to see if you had had a chance to review the email and information I had sent. Please let me know
as soon as possible.
Thanks,
Jordan
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…53/104
On Mon, Dec 9, 2024 at 4:31 PM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
Sorry for the delayed response to the information I requested about the paints, I was waiting for more information
from my supervisor before providing a response. Since these paints fall under a state rule, R307-353 for plastic
parts coatings, can you identify on the table in R307-353-5 Table 1 what the paints are used for specifically? I
have attached the rule to this email for your reference.
Thanks,
Jordan
On Wed, Nov 20, 2024 at 2:23 PM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan!
Sorry this took us a lile bit to get together for you. We realized we had the older SDSs in our files,
and the newer SDSs have the VOCs. We have been geng our VOCs from a database we created a
few years ago, and that is where all the informaon we look for us. Here are the top 3 SDSs that
cover around 75% of our paint usage each month. Just let us know if there is any more informaon
or clarificaon you need.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Thursday, November 14, 2024 12:05 PM
To: Brian Boudreaux <[e-mail]>
Subject: [SUSPICIOUS LINK IN EMAIL] Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspiciousemails using the Report Phishing button.]
Hey Brian,
If you could send me the SDS for some of your most used paints and maybe the one that has the highest
VOC/lb content that you can find if you are able to provide that. This is in reference to state rule R307-353-5
Table 1 for Plastic Parts Coatings for Automobiles. I need to verify that the paints don't exceed the VOC lb/gal in
that table based on their usage. Here is a link to that rule for reference. Please let me know if you have any
questions.
Thanks,
Jordan
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…54/104
On Thu, Nov 14, 2024 at 11:42 AM Brian Boudreaux <[e-mail]> wrote:
Hello Jordan,
Sorry that I took so long to respond - I have been out of office all week so far. As to your
queson, we have roughly over 70 different paints on our records that we cycle through. How
would you like to receive the SDSs? Would it work best to show you our most heavily used
paints, a few at random, a certain number? Whatever works best for you, but we do have a
significant amount due to the demands of the different customers - everyone has their own
shade of black.

The process we use for calculang our emissions includes the VOC content from each paint
which we get from the individual SDS’s. Just let me know how you will like to proceed and I can
send them over to you.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Tuesday, November 12, 2024 2:17 PM
To: Brian Boudreaux <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Report suspiciousemails using the Report Phishing button.]
Hey Brian,
I have one more additional request about the paints you listed in your response. Do you happen to have
more information specifically about the VOC content in lbs/gallon of the paints that are used for coatings? If
you have something from your paint provider like an SDS or data sheet that shows that VOC content would
be helpful.
Thanks,
Jordan
On Tue, Sep 3, 2024 at 10:17 AM Jordan Garahana <[e-mail]> wrote:
Hey Brian,
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…55/104
Thanks for getting back to me with the information I have requested. I will let you know if there is anything
else I need for my inspection.
Thanks,
Jordan
On Thu, Aug 29, 2024 at 3:24 PM Brian Boudreaux <[e-mail]> wrote:
Hey Jordan,
I wanted to provide you with the answers we have gathered around your queson. Please let
me know if you have any other quesons for us.
The owner/operator shall not exceed the following consumpon limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasng media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumpon amounts for the
items listed above.

Please see aachment labeled Sec 1.
For A. and B., we use lile, if any, of these materials per year. Our sand-blasng machines get
used once or twice a year (low enough that they are considering decommissioning them) and
we have one vehicle that sll uses propane and some grills. We don’t consume enough to
have any regular shipments or billing, and it is bought on a company card on an as-needed
basis.

The owner/operator shall not exceed the following VOC and HAP emissions in the airbag
module manufacturing plant and coang line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for
formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene,
cumene, dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride,
methanol, methyl isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene,
trichloroethylene, and xylene.* * Any individual HAP included in this list shall have an
emission limit less than the Emission Threshold Value (ETV) for that chemical, as provided for
in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP
emissions for the compounds listed above. I also need a log that shows the
comparison/calculaon of the emission limit of the ETV to the emission of the HAP.

Please see aachment labeled Sec 2. All HAP emission levels should fall below the ETV. All
individual and combined HAPs emissions for the rolling 12-month period are provided as
well.

The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmaon that natural gas is the only fuel source ulized in the 60 kW and 80 kW
generators.
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…56/104

Let us know if further confirmaon is needed.

The owner/operator shall install a diesel-fired emergency engine that is cerfied to meet a
NOx emission rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW
engine; and 3.30 g/hp-hr for each of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40
CFR 63 Subpart ZZZZ, R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW
engines onsite.

Please see aached files labeled “Genset8 100kw Spec Sheet,” “Genset10 125kw Spec
Sheet,” and “Genset 9 40kw Spec Sheet”
Our 100, 125, and 40kw generators are EPA Tier III compliant.

The owner/operator shall not operate each emergency engine on site for more than 100
hours per rolling 12-month period during non-emergency situaons. There is no me limit
on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each
generator was operated onsite, including of the date, hours operaon, and reason the
generator was operated. Also, if you have any maintenance logs for the generators that
show it is being maintained according to manufacturer's recommendaons, that would be
appreciated.

Please see aachment labeled “Generator Usage from Aug 2023 to July 2024”.

The owner/operator shall only combust diesel fuel that meets the definion of ultra-low
sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel ulized
onsite is classified as ULSD.

Please see aachment labeled “July 2024 Diesel Invoice”.

For abrasive blasng, is the media that is used in abrasive blasng sll glass beads?

We have confirmed with our spares department that they are sll glass beads.

For the coang of the plasc parts, what is the VOC content of the paint that is ulized for
coang? On previous inspecons it was noted that the VOC content of the paint was 4.4
lb/gal. Are you sll ulizing the same paints as noted in the inspecon conducted in 2021?
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…57/104

As for the paint that is ulized for coang, we have over 50 paints that are regularly used
and each has its own VOC content. The 4.4 lb/gal. was the average of these paints. Our
current average is 5.81 lb/gal and we calculate the VOC emissions based on the usage for
each product with their individual VOC content.

Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 11:09 AM
To: Brian Boudreaux <[e-mail]>
Cc: Akira Kimbrough <[e-mail]>; Brent Pedersen
<[e-mail]>; Kent Parkinson <[e-mail]>; Sco Billings
<[e-mail]>; Jamieson Oleson <[e-mail]>
Subject: Re: Records Request for Inspecon

[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hey Biran,
Sorry about the date on when I need the records. If you could provide that to me by August 30 that would
be great. Please let me know if you have any questions or need more time than that to compile
everything.
Thanks,
Jordan
On Fri, Aug 23, 2024 at 11:07 AM Brian Boudreaux <[e-mail]> wrote:
Thank you, Jordan. My team will get on this.
Just to be clear, you want this by the end of business on Monday?
From: Jordan Garahana <[e-mail]>
Sent: Friday, August 23, 2024 10:19 AM
To: Brian Boudreaux <[e-mail]>
Subject: Records Request for Inspecon

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…58/104
[EXTERNAL EMAIL: Do not click links or attachments unless you recognize the sender and know the content is safe. Reportsuspicious emails using the Report Phishing button.]
Hello Leonard,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's division of
Air Quality. I am requesting some records as part of an inspection of the facility's operations located at
1000 West 3300 South in Ogden. These are the records I am looking for:
The owner/operator shall not exceed the following consumption limits in the airbag module
manufacturing plant:
A. 1,000 pounds of sand-blasting media per rolling 12-month period
B. 6,000,000 gallons of propane per rolling 12-month period
C. 3,000,000 gallons of gasoline per rolling 12-month period
D. 3,000,000 gallons of diesel fuel #2 per rolling 12-month period
E. 60,000,000 cubic feet of natural gas per rolling 12-month period
I need a record from August 2023 to July 2024 showing the consumption amounts for the items
listed above.
The owner/operator shall not exceed the following VOC and HAP emissions in the airbag module
manufacturing plant and coating line:
65.84 tons per rolling 12-month period for VOCs 0.25 tons per rolling 12-month period for
formaldehyde
0.25 tons per rolling 12-month period for glycol ethers
4.44 tons per rolling 12-month period for toluene
15.70 tons per rolling 12-month period for the combined HAPs: acetonitrile, benzene, cumene,
dichlorobenzene, ethyl benzene, ethylene glycol, hexane, methylene chloride, methanol, methyl
isobutyl ketone, naphthalene, perchloroethylene, phenol, styrene, trichloroethylene, and xylene.* *
Any individual HAP included in this list shall have an emission limit less than the Emission Threshold
Value (ETV) for that chemical, as provided for in R307-410-5.
I need the rolling 12-month total from August 2023 to July 2024 for VOC and HAP emissions for
the compounds listed above. I also need a log that shows the comparison/calculation of the
emission limit of the ETV to the emission of the HAP.
The owner/operator shall use natural gas as fuel in the 60 kW and 80 kW engines.
I need confirmation that natural gas is the only fuel source utilized in the 60 kW and 80 kW
generators.
The owner/operator shall install a diesel-fired emergency engine that is certified to meet a NOx
emission rate of 2.80 g/hp-hr for the 125 kW engine; 2.78 g/hp-hr for the 100 kW engine; and 3.30
g/hp-hr for each of the 40 kW engines; or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ,
R307-401-8]
I need a record that shows the NOx emission rates for the 125 kW, 100 kW, and 40 kW engines
onsite.
The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of the
engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
I need the rolling 12-month total from August 2023 to July 2024 for the hours each generator
was operated onsite, including the date, hours of operation, and reason the generator was
operated. Also, if you have any maintenance logs for the generators that show it is being
maintained according to manufacturer's recommendations, that would be appreciated.
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel
(ULSD), which has a sulfur content of 15 ppm or less.
I need a recent bill of sale from your diesel fuel provider that shows the diesel fuel utilized
onsite is classified as ULSD.
For abrasive blasting, is the media that is used in abrasive blasting still glass beads?
For the coating of the plastic parts, what is the VOC content of the paint that is utilized for coating? On
previous inspections it was noted that the VOC content of the paint was 4.4 lb/gal. Are you still utilizing
the same paints as noted in the inspection conducted in 2021?
Please let me know if you have any questions about the records I am requesting. Please have this for
me by Monday, August 26.
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…59/104
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…60/104
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…61/104
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…62/104
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
Jordan Garahana
Environmental Scientist | Minor
Source Compliance
M: (385)
271-2871
airquality.utah.gov
Emails to and from this email address
may be considered public records and thus subject to Utah GRAMA requirements.
***************************************************************
Consider the environment before printing this message.
To read the Companies' Information and Confidentiality Notice, follow this link:
https://www.autoliv.com/autoliv-email-disclaimer
***************************************************************
--
1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…63/104
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]>Fri, Jan 10, 2025 at 10:49 AM
To: Brian Boudreaux <[e-mail]>
Hey Brian,
No worries and thanks for your response and the information you provided. Based on what you have provided me,
everything is compliant with the rule as long as your paints stay under that 5.0 lb.gal VOC limit based on their usage.
Thanks once again for your help and time with this!
Thanks,
Jordan
On Mon, Jan 6, 2025 at 1:59 PM Brian Boudreaux <[e-mail]> wrote:
Hello,
In reviewing the Air Permit, we found that the R307-353 is the best one that fits our process. This is already in our
AO as far as we can tell, so it would not require any revisions. Perhaps I am reading all of this wrong. Let's go back to
your original queson. In the Table you referenced - R307-353-5, this would be considered an air-dried coang for an
interior part. These items are typically covers that go over the airbags when installed within a vehicle. I'm sorry for
my confusion - sll geng used to reading these air permits.
Thanks,
Brian L. Boudreaux, CSP MSOSH
Shared Services Health and Safety Manager - OTC, AOA, and AOS
[e-mail]
801-664-6166
1000 West 3300 South, 84401, Ogden, United States
www.autoliv.com

1/13/25, 2:15 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5986676443053468615&simpl=msg-a:r-56198250100…64/104
page 1 of 3
FLASH POINT
72 °F PMCC
Specific Gravity
1.05
Product Weight
8.69 lb/gal
04 00 [2147]
ENVIRONMENTAL DATA SHEET
(Certified Product Data Sheet)
Date of Preparation
Aug 2, 2017
PRODUCT NUMBER
G52BU97
PRODUCT NAME
SOFT SWADE® Urethane Coating, FCA Global Black TX7
MANUFACTURER'S NAME
SHERWIN-WILLIAMS AUTOMOTIVE FINISHES
101 W. Prospect Avenue
Cleveland, OH 44115
This document includes all data required by 40 CFR 63.801(a) for a Certified Product Data Sheet under criteria specified in 40 CFR 63.805(a).
All data given below are MAXIMUM THEORETICAL VALUES based on the product AS CURRENTLY FORMULATED. Variations may occur
on individual batches due to adjustments made during production.
Hazard Category (for SARA 311.312)
| Acute | Chronic | Fire |
Volatile Ingredients
Chemical / Compound SARA 302 EHS CERCLA SARA 313 TC HAPS 112 % by Weight % by Volume
Light Aromatic Hydrocarbons
64742-95-6 N N N N 2 3
1,2,4-Trimethylbenzene
95-63-6 N N Y N 3 4
Diacetone Alcohol
123-42-2 N N N N 9 9
n-Butyl Acetate
123-86-4 N Y N N 29 34
2-Butoxyethyl Acetate
112-07-2 N N ******5 5
Regulated Compounds
SARA 302 EHS CERCLA SARA 313 TC HAPS 112 % by Weight % by Volume
*** Glycol Ethers (SARA)N N Y N 5
*** Glycol Ethers (HAPS)N N N Y 5
Volatile Organic Compounds - U.S. EPA
A.Coating Density 8.69 lb/gal 1041 g/l
B.Total Volatiles 50.6% by wt.59.3% by vol.
C.Federally exempt solvents:
Water 0.0% by wt.0.0% by vol.
D.Organic Volatiles 50.6% by wt.59.3% by vol.
E.Percent Non-Volatile 49.4% by wt.40.7% by vol.
F.VOC Content 4.39 lb/gal 526 g/l total
4.39 lb/gal 526 g/l less exempt solvents
10.79 lb/gal 1293 g/l of solids
1.02 lb/lb 1.02 kg/kg of solids
50.6%by wt LVP-VOC
Maximum Incremental Reactivity (MIR) (per US EPA Aerosol Ctg Rule, MIR Values 2009)
1.05
G52BU97
page 2 of 3
Volatile Organic Compounds - California
A.Coating Density 8.69 lb/gal 1041 g/l
B.Total Volatiles 50.6% by wt.59.3% by vol.
C.Exempt solvents:
Water 0.0% by wt.0.0% by vol.
D.Organic Volatiles 50.6% by wt.59.3% by vol.
E.Percent Non-Volatile 49.4% by wt.40.7% by vol.
F.VOC Content 4.39 lb/gal 526 g/l total
4.39 lb/gal 526 g/l less exempt solvents
10.79 lb/gal 1293 g/l of solids
1.02 lb/lb 1.02 kg/kg of solids
50.6%by wt LVP-VOC
Maximum Incremental Reactivity (MIR) (per California Air Resources Board Aerosol Products Regulation, MIR Values 2010)
1.05
Volatile Organic Compounds - South Coast Air Quality Management District, California, US
A.Coating Density 8.69 lb/gal 1041 g/l
B.Total Volatiles 50.6% by wt.59.3% by vol.
C.Exempt solvents:
Water 0.0% by wt.0.0% by vol.
D.Organic Volatiles 50.6% by wt.59.3% by vol.
E.Percent Non-Volatile 49.4% by wt.40.7% by vol.
F.VOC Content 4.39 lb/gal 526 g/l total
4.39 lb/gal 526 g/l less exempt solvents
10.79 lb/gal 1293 g/l of solids
1.02 lb/lb 1.02 kg/kg of solids
50.6%by wt LVP-VOC
Volatile Organic Compounds - EU Directive 2010/75/EU
Total Volatiles 50.6% by wt.59.3% by vol.
VOC Content 4.39 lb/gal 526 g/l
Hazardous Air Pollutants (Clean Air Act, Section 112(b))
Volatile HAPS 0.39 lb/gal 0.047 kg/l
0.97 lb/gal 0.116 kg/l of solids
0.09 lb/lb 0.09 kg/kg of solids
Air Quality Data
Density of Organic Solvent Blend
7.41 lb/gal
Photochemically Reactive
Yes
Additional Regulatory Information
US EPA TSCA:
Not Applicable
Relevant identified uses of the substance or mixture and uses advised against:
Not Applicable
Waste Disposal
Waste from this product may be hazardous as defined under the Resource Conservation and Recovery Act (RCRA) 40 CFR 261.
Waste must be tested for ignitability to determine the applicable EPA hazardous waste numbers.
Addition of reducers or other additives to this product may substantially alter the above data. Since conditions of use are outside our control, we make no
warranties, express or implied, and assume no liability in connection with any use of this information.
G52BU97
page 3 of 3
page 1 of 3
FLASH POINT
79 °F PMCC
Specific Gravity
1.05
Product Weight
8.72 lb/gal
01 00 [3117]
ENVIRONMENTAL DATA SHEET
(Certified Product Data Sheet)
Date of Preparation
Nov 14, 2017
PRODUCT NUMBER
G56BU68
PRODUCT NAME
G56, GM Jet Black 600R
MANUFACTURER'S NAME
SHERWIN-WILLIAMS AUTOMOTIVE FINISHES
101 W. Prospect Avenue
Cleveland, OH 44115
This document includes all data required by 40 CFR 63.801(a) for a Certified Product Data Sheet under criteria specified in 40 CFR 63.805(a).
All data given below are MAXIMUM THEORETICAL VALUES based on the product AS CURRENTLY FORMULATED. Variations may occur
on individual batches due to adjustments made during production.
Hazard Category (for SARA 311.312)
| Acute | Chronic | Fire |
Volatile Ingredients
Chemical / Compound SARA 302 EHS CERCLA SARA 313 TC HAPS 112 % by Weight % by Volume
Ethylbenzene
100-41-4 N Y Y Y 0.3 < 1
Xylene
1330-20-7 N Y Y Y 2 2
Diacetone Alcohol
123-42-2 N N N N 7 8
Acetone
67-64-1 N Y N N 5 7
Methyl n-Propyl Ketone
107-87-9 N N N N 6 7
Methyl Isobutyl Ketone
108-10-1 N Y Y Y 2 2
Ethyl 3-Ethoxypropionate
763-69-9 N N N N 5 6
n-Butyl Acetate
123-86-4 N Y N N 16 19
Dimethyl Glutarate
1119-40-0 N N N N 2 2
Volatile Organic Compounds - U.S. EPA
A.Coating Density 8.72 lb/gal 1044 g/l
B.Total Volatiles 45.5% by wt.54.2% by vol.
C.Federally exempt solvents:
Water 0.0% by wt.0.0% by vol.
Acetone 5.2% by wt.6.8% by vol.
D.Organic Volatiles 40.3% by wt.47.4% by vol.
E.Percent Non-Volatile 54.5% by wt.45.8% by vol.
F.VOC Content 3.51 lb/gal 421 g/l total
3.77 lb/gal 452 g/l less exempt solvents
7.67 lb/gal 920 g/l of solids
0.74 lb/lb 0.74 kg/kg of solids
40.3%by wt LVP-VOC
Maximum Incremental Reactivity (MIR) (per US EPA Aerosol Ctg Rule, MIR Values 2009)
0.75
G56BU68
page 2 of 3
Volatile Organic Compounds - California
A.Coating Density 8.72 lb/gal 1044 g/l
B.Total Volatiles 45.5% by wt.54.2% by vol.
C.Exempt solvents:
Water 0.0% by wt.0.0% by vol.
Acetone 5.2% by wt.6.8% by vol.
D.Organic Volatiles 40.3% by wt.47.4% by vol.
E.Percent Non-Volatile 54.5% by wt.45.8% by vol.
F.VOC Content 3.51 lb/gal 421 g/l total
3.77 lb/gal 452 g/l less exempt solvents
7.67 lb/gal 920 g/l of solids
0.74 lb/lb 0.74 kg/kg of solids
40.3%by wt LVP-VOC
Maximum Incremental Reactivity (MIR) (per California Air Resources Board Aerosol Products Regulation, MIR Values 2010)
0.75
Volatile Organic Compounds - South Coast Air Quality Management District, California, US
A.Coating Density 8.72 lb/gal 1044 g/l
B.Total Volatiles 45.5% by wt.54.2% by vol.
C.Exempt solvents:
Water 0.0% by wt.0.0% by vol.
Acetone 5.2% by wt.6.8% by vol.
D.Organic Volatiles 40.3% by wt.47.4% by vol.
E.Percent Non-Volatile 54.5% by wt.45.8% by vol.
F.VOC Content 3.51 lb/gal 421 g/l total
3.77 lb/gal 452 g/l less exempt solvents
7.67 lb/gal 920 g/l of solids
0.74 lb/lb 0.74 kg/kg of solids
40.3%by wt LVP-VOC
Volatile Organic Compounds - EU Directive 2010/75/EU
Total Volatiles 45.5% by wt.54.2% by vol.
VOC Content 3.96 lb/gal 475 g/l
Hazardous Air Pollutants (Clean Air Act, Section 112(b))
Volatile HAPS 0.32 lb/gal 0.039 kg/l
0.71 lb/gal 0.085 kg/l of solids
0.06 lb/lb 0.06 kg/kg of solids
Air Quality Data
Density of Organic Solvent Blend
7.32 lb/gal
Photochemically Reactive
Yes
Additional Regulatory Information
US EPA TSCA:
Not Applicable
Relevant identified uses of the substance or mixture and uses advised against:
Not Applicable
Waste Disposal
Waste from this product may be hazardous as defined under the Resource Conservation and Recovery Act (RCRA) 40 CFR 261.
G56BU68
page 3 of 3
Waste must be tested for ignitability to determine the applicable EPA hazardous waste numbers.
Addition of reducers or other additives to this product may substantially alter the above data. Since conditions of use are outside our control, we make no
warranties, express or implied, and assume no liability in connection with any use of this information.
page 1 of 4
ENVIRONMENTAL DATA SHEET
(Certified Product Data Sheet)
29 00 [2383]
Date of Preparation
Sep 14, 2024
PRODUCT NUMBER
G52BU17
PRODUCT NAME
SOFT SWADE® Urethane Coating, Chrysler DX9 Black
MANUFACTURER'S NAME
SHERWIN-WILLIAMS AUTOMOTIVE FINISHES
101 W. Prospect Avenue
Cleveland, OH 44115
This document includes all data required by 40 CFR 63.801(a) for a Certified Product Data Sheet under criteria specified in 40 CFR 63.805(a).
All data given below are MAXIMUM THEORETICAL VALUES based on the product AS CURRENTLY FORMULATED and rely on information
provided to us by our raw material suppliers. Our suppliers often provide an estimated value or range less than a certain upper limit.  We
calculate MAXIMUM THEORETICAL VALUES using defined values, if provided, or the upper limit reported by our supplier. Additionally,
the suppliers’ information may include amounts present in the product as unintentional byproducts or impurities.  Variations may occur in
individual batches due to adjustments made during production.
Hazard Category (for SARA 311.312)
G52BU17 = | Acute | Chronic | Fire |
Product Weight
8.63 lb/gal
Specific Gravity
1.04
FLASH POINT
72 °F PMCC
Volatile Ingredients
Chemical / Compound SARA 302 EHS CERCLA SARA 313 TC HAPS 112 % by Weight % by Volume
Ethylbenzene
100-41-4 N Y Y Y 0.4 0.5
Xylene
1330-20-7 N Y Y Y 2 3
Light Aromatic Hydrocarbons
64742-95-6 N N N N 3 4
Cumene
98-82-8 N Y Y Y 0.2 0.3
Trimethylbenzene
25551-13-7 N N N N 2 2
Diacetone Alcohol
123-42-2 N N N N 8 8
Methyl Isobutyl Ketone
108-10-1 N Y Y Y 2 2
n-Butyl Acetate
123-86-4 N Y N N 29 34
2-Butoxyethyl Acetate
112-07-2 N N Y - Glycol Ethers
(SARA)
Y - Glycol Ethers
(HAPS)5 5
Regulated Compounds
SARA 302 EHS CERCLA SARA 313 TC HAPS 112 % by Weight % by Volume
Mercury (as Hg)N N Y N 0.0000002
Lead (as Pb)N N Y N 0.000003
Glycol Ethers (SARA)N N Y N 5
Glycol Ethers (HAPS)N N N Y 5
G52BU17
page 2 of 4
Volatile Organic Compounds - U.S. EPA / Canada
G52BU17
LB/Gal g/L
Coating Density 8.63 1033
By wt By vol
Total Volatiles 52.9%61.6%
Federally exempt solvents
Water 0.0%0.0%
Organic Volatiles 52.9%61.6%
Percent Non-Volatile 47.1%38.4%
VOC Content LB/Gal g/L
Total 4.56 546
Less exempt solvents 4.56 546
Of solids 11.89 1425
Of solids 1.12 lb/lb 1.12 kg/kg
By wt
By wt LVP-VOC 52.7%
Maximum Incremental Reactivity (MIR) (per US EPA Aerosol Ctg Rule, MIR Values 2009) 1.17
Volatile Organic Compounds - California
G52BU17
LB/Gal g/L
Coating Density 8.63 1033
By wt By vol
Total Volatiles 52.9%61.6%
Exempt solvents
Water 0.0%0.0%
Organic Volatiles 52.9%61.6%
Percent Non-Volatile 47.1%38.4%
VOC Content LB/Gal g/L
Total 4.56 546
Less exempt solvents 4.56 546
Of solids 11.89 1425
Of solids 1.12 lb/lb 1.12 kg/kg
By wt
By wt LVP-VOC 52.7%
Maximum Incremental Reactivity (MIR) (per California Air Resources Board Aerosol Products Regulation, MIR Values 2010) 1.15
G52BU17
page 3 of 4
Volatile Organic Compounds - South Coast Air Quality Management District, California, US
G52BU17
LB/Gal g/L
Coating Density 8.63 1033
By wt By vol
Total Volatiles 52.9%61.6%
Exempt solvents
Water 0.0%0.0%
Organic Volatiles 52.9%61.6%
Percent Non-Volatile 47.1%38.4%
VOC Content LB/Gal g/L
Total 4.56 546
Less exempt solvents 4.56 546
Of solids 11.89 1425
Of solids 1.12 lb/lb 1.12 kg/kg
Volatile Organic Compounds - EU Directive 2004/42/EC
G52BU17
By wt By vol
Total Volatiles 72.4%79.0%
VOC Content LB/Gal g/L
Total 6.25 748
Volatile Organic Compounds - EU Directive 2010/75/EU
G52BU17
By wt By vol
Total Volatiles 52.9%61.6%
VOC Content LB/Gal g/L
Total 4.56 546
Volatile Organic Compounds - Mexico
G52BU17
LB/Gal g/L
Coating Density 8.63 1033
By wt By vol
Total Volatiles 52.9%61.6%
Exempt solvents
Water 0.0%0.0%
Organic Volatiles 52.9%61.6%
Percent Non-Volatile 47.1%38.4%
VOC Content LB/Gal g/L
Total 4.56 546
Less exempt solvents 4.56 546
Of solids 11.89 1425
Of solids 1.12 lb/lb 1.12 kg/kg
G52BU17
page 4 of 4
Hazardous Air Pollutants (Clean Air Act, Section 112(b))
G52BU17
LB/Gal kg/L
Volatile HAPS 0.80 0.095
Of solids 2.08 0.249
Of solids 0.19 lb/lb 0.19 kg/kg
Air Quality Data
Density of Organic Solvent Blend
7.41 lb/gal
Photochemically Reactive
Yes
Waste Disposal
Waste from this product may be hazardous as defined under the Resource Conservation and Recovery Act (RCRA) 40 CFR 261.
Waste must be tested for ignitability to determine the applicable EPA hazardous waste numbers.
The addition of any material to this product can change the composition, hazards and risks of the product and may substantially alter the above data. Since
conditions of use are outside our control, we make no warranties, express or implied, and assume no liability in connection with any use of this information.