HomeMy WebLinkAboutDAQ-2025-0009641
DAQC-CI104910001-25
Site ID 10491 (B1)
MEMORANDUM
TO: FILE – HOLCIM SOLUTIONS AND PRODUCTS US, LLC – Foam Insulation
Manufacturing Facility
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: February 10, 2025
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County
INSPECTION DATE: May 22, 2024
SOURCE LOCATION: 3790 Great Lakes Drive
West Valley City, UT 84120
SOURCE CONTACT: Alex Smith, Plant Manager Operations, 801-301-1082,
Alex.smith@holcim.com
OPERATING STATUS: In operation
PROCESS DESCRIPTION: Holcim Solutions operates a closed cell foam production facility for
commercial roofing applications. Top and bottom sheets of facer
materials arrive by rail, and the liquid chemicals arrive by truck. A
polyester polyol is mixed with methyl di-isocyanate (MDI), catalyst,
surfactants, and blowing agent pentane. The chemical mixture is
injected between two sheets of facer material, which resembles a
thick, fibrous paper material. The chemical expands between the facer
materials to fill the gap between two spacer dies. The product feeds
through a trimmer to cut the rough edge off at a 4-foot width. The
hardened board is then cut in lengths as specified by the customer. A
Regenerative Thermal Oxidizer (RTO) has a VOC destruction
efficiency (DRE) of 98% at 1,500 degrees Fahrenheit. A baghouse
captures dust from the cutting operation. A Marsh Patrion Plus
digital/inkjet matrix printer labels the foam board. Two Hitachi
digital/inkjet printers label the plastic wrapped bundles. A gluing
operation uses hot melt glue to attach strips to the end of boards. The
cut boards are stock piled in stacks of about 10 boards wrapped in
plastic and are then shipped to a construction site for use as a building
material. The boards typically lay a foundation for a sealed poly
rubber roof used on large warehouse type buildings.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104910012-19, dated
April 8, 2019
/ :
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SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Holcim Solutions and Products US, LLC
Foam Insulation Manufacturing Facility
6534 West 150 South 6534 West 150 South
Salt Lake City, UT 84104 Salt Lake City, UT 84104
SIC Code: 3086: (Plastics Foam Products)
Section I: GENERAL PROVISIONS
I.1
I.2
I.3
I.4
I.5
I.6
I.7
I.8
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]
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 (2)-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]
At all times, including periods of start-up, 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]
The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]
The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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. [R3 07-10 1]
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. [R307-401-1 8]
Status: In Compliance. There were no modifications to the equipment or processes
approved by this AO. Holcim Solutions did not exceed any limits set forth in this AO.
Holcim Solutions maintains records for at least two years, and also maintains records of
3
maintenance activities performed on approved equipment. See weekly PM of the Dust
Collector and the RTO in the attachment. Holcim Solutions indicated that there were no
breakdowns resulting in an emissions event. According to the 2022 Emissions Inventory
Report, the emissions indicated compliance with the PTEs of this AO.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Holcim, Salt Lake City Facility
Insulation Production
II.A.2 Regenerative Thermal Oxidizer (RTO)
RTO manufactured Crawford Equipment and Engineering (CEE), designed to provide 98%
VOC destruction at l ,500°F with an average retention time of 1.0 second
II.A.3 Dust Collector for Cutting Area
Type: Reverse Jet Collector
Exhaust Concentration: 0.016 gr/dscf
II.A.4 Electric Parts Cleaning Oven
II.A.5
II.A.6
Roof Vent
Hot Storage Tanks
Tanks store isocyanate, polyester polyol, surfactant and octoate. Tanks are fitted with a
pressure relief valve venting outside of the building.
II.A.7 Cold Storage Tanks
Tanks store flame retardant, material mixed blends
II.A.8 Cold Storage Tanks Located Outside of the Building
One 20,000 gallon tank storing pentane
II.A.9 Small Combustion Sources
All units below 5 MMBtu/hr
Status: In Compliance. There was no new or unapproved equipment observed onsite.
II.B Requirements and Limitations
II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted while in operation
in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. There were no visible emissions observed during this inspection.
The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9.
See the attachment for additional information.
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II.B.1.b
II.B.1.b.1
II.B.1.c
II.B.1.d
II.B.1.d.1
The following production limits shall not be exceeded:
A. 1,600 lbs maximum per hour of blowing agent from the foam manufacturing process
B. 12,900 lbs maximum pe r hour of foam products fed to the saw-cut area for trimming
C. 3,580,000 lbs of blowing agent per rolling 12-month period
[R307-401-8)
Records of production shall be kept for all periods when the plant is in operation. Production
shall be determined by supervisor monitoring and maintaining an operation log. The records
of production shall be kept on a daily basis. [R307-401-8]
Status: In Compliance. The rolling 12-month production limits from June 2023 to May
2024 indicated the following:
A. 668.22 lbs maximum per hour of blowing agent from the foam manufacturing process
B. 10,602.56 lbs maximum per hour of foam products fed to the saw-cut area for
trimming
C. 1,458,281.60 lbs of blowing agent per rolling 12-month period
Records of production were kept for all periods when the plant was operating. Daily
operations log was maintained. See the production of the blowing agent in a rolling
12-month in the email attachment.
The RTO shall control the emissions from the laminator, chemical pumps and laydown table.
[R307-401-8]
Status: In Compliance. The RTO does control the emissions from the laminator, chemical
pumps, and laydown table.
The following operating parameters in the RTO shall be maintained within the indicated
ranges:
A. Combustion chamber temperature of 1500°F +/- 10%
B. A flow rate of 8,000 to 10,000 ACFM shall be maintained.
[R307-401-8)
Status: In Compliance. During this inspection, the RTO temperature indicated 1,509
degrees Fahrenheit, and the flow rate indicated 8,540 ACFM. See records of the
combustion chamber temperatures and the flow rates in the attachment.
The owner/operator shall install, calibrate, maintain, and operate monitoring devices for the
continuous measurement of the temperature and flow rate of the gas stream through the
combustion chamber of the RTO. Continuous recording for the monitoring devices is not
required. However, daily records of readings shall be maintained. All instruments shall be
calibrated in accordance with the manufacturer's instructions or recommendations at least once
every 12-month period. [R307-401-8]
Status: In Compliance. The Flow Meters were calibrated on January 29, 2024, by Western
States Calibration. The Temperature Gauge for the RTO was calibrated by Kurz
Instruments Inc. on August 15, 2022, and placed in service on August 31, 2023, with the
next calibration due in August 2024. See the attachment for additional information.
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II.B.1.e
II.B.1.e.1
II.B.1.f
II.B.1.f.1
II.B.1.f.2
The owner/operator shall not exceed 150 hours per rolling 12-month period for maintenance of
the RTO. [R307-401-8]
Status: In Compliance. The hours of maintenance of the RTO in a rolling 12-month period
from June 2023 to May 2024 indicated 56.6 days. See the attachment for additional
information.
Compliance with the RTO limitation above shall be determined on a rolling 12-month total.
No later than 20 days after the end of the month, a new 12-month total shall be calculated
using data from the previous 12 months. Records of maintenance shall be kept for all periods
when the plant is in operation. Hours of maintenance shall be determined by supervisor
monitoring and maintaining of a maintenance log. [R307-401-8]
Status: In Compliance. Holcim Solutions maintains records of the hours of RTO
maintenance in a maintenance log. See the attachment for additional information.
The dust collector pressure drop shall not be less than 1.0 inch of water column or more than
8 .0 inches of water column, plus or minus 1.0 inch of water column. [R307-401-8]
Daily recording of the reading of the dust collector pressure drop is required. The pressure
drop shall be monitored with pressure drop indicator located such that an inspector/operator
can safely read the output at any time. [R307-401-8)
Status: In Compliance. During this inspection, the pressure drop reading indicated 3.0
inches of water column. Records of pressure drop readings reviewed indicated compliance
with this AO condition. See the attachment for additional information.
All instruments shall be calibrated according to the manufacturer's instructions at least once
every 12 months. [R307-401-8]
Status: In Compliance. According to Holcim Solutions, no calibration is required of the
Manometers per the manufacturer. A second Manometer Unit verifies the reading from the
first Manometer Unit. Zero is verified and noted on the Log Sheet. See the pressure drop
readings in the attachment. See the email attachment for additional information on the
manufacturer’s recommendation.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs have
been found to apply to this installation. This AO in no way releases the owner or operator from any liability
for compliance with all other applicable federal, state, and local regulations including UAC R307.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-305 - Nonattainment and Maintenance Areas for PM10: Emission Standards
Status: In Compliance. There were no visible emissions observed during this inspection. The opacity
observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment for
additional information.
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R307-335 - Degreasing
Status: In Compliance. Holcim Solutions uses the Safety-Kleen Premium Solvent to clean tools,
equipment, and machinery. The tools and equipment are left to soak in the Parts Washer for some
time. When the tools and equipment are removed, they are dried using a rag. Used rags are placed in
a closed container and transported for offsite disposal by Heritage Environmental. The spent solvent
is picked up by Safety-Kleen for offsite disposal. During this inspection, the Degreaser was closed
when not in use. See the email attachment for additional information.
R307-342 - Adhesives and Sealants
Status: In Compliance. Holcim Solutions uses a glue-gun to apply hot melt glue to attach strips to the
end of boards. The Bostik Thermgrip (R) 2345 does not contain any VOC. See the Certified Product
Data Sheet in the attachment.
EMISSION INVENTORY: According to the 2022 Emissions Inventory Report, the emissions
indicated compliance with the PTEs of this AO.
Listed below are the Actual Emissions Inventory for the 2022 Emissions Inventory Report provided by Holcim
Solutions and Products US, LLC – Foam Insulation Manufacturing Facility. A comparison of the estimated
total potential emissions (PTE) on AO: DAQE-AN104910012-19, dated April 8, 2019. PTE are supplied for
supplemental purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 8,909 ---
Carbon Monoxide 6.17 0.69
Nitrogen Oxides 7.38 0.83
Particulate Matter - PM10 3.84 0.91
Particulate Matter - PM2.5 3.84 0.06
Sulfur Oxides 0.04 0.001
Volatile Organic Compounds 87.84 58.93
Volatile Organic Compounds - Fugitive
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 38
Generic HAPs (CAS #GHAPS) 6
Hexane (CAS #110543) 934
Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 8
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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: Holcim Solutions is in compliance with the conditions of Approval
Order (AO) DAQE-AN104910012-19, dated April 8, 2019. Holcim
Solutions maintains good housekeeping practices. A new AO was
approved on June 28, 2023, for the new location. Holcim Solutions
moved to the new location at the end of May 2024.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots, safety
glasses, and reflective vest. Use the new AO approved on June 28,
2023, for the new location.
NSR RECOMMENDATIONS: None at this time.
ATTACHMENTS: Applicable Supporting Documentation Included