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HomeMy WebLinkAboutDAQ-2025-0014761 DAQC-CI104200001-25 Site ID 10420 (B1) MEMORANDUM TO: FILE – ATLAS MOLDED PRODUCTS – Expanded Polystyrene Mfg. Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Susan Weisenberg, Environmental Scientist DATE: February 12, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: December 11, 2024 SOURCE LOCATION: 111 West Fireclay Avenue Murray, UT 84107 DIRECTIONS: From I-15 South bound, take exit 301, 4500 South/Taylorsville Expressway. Look for the white warehouse building surrounded by apartments. SOURCE CONTACTS: Pete Sorensen, Maintenance Manager 385-628-3465, psorensen@atlasroofing.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Expandable polystyrene synthetic resin plant producing packaging material (peanuts) and foam blocks. The packaging material is made by injecting a bead of polystyrene chips containing -6% pentane, petroleum derived blowing agent, into steam. The steam heats and moistens the polystyrene chips. Pentane contained in the chips, along with the steam, expands and softens the chips. The expanded packaging material is blown into large fabric hoppers and stored until it is cooled and then packaged for sale. Foam blocks are made by exposing sand-grain sized polystyrene beads to steam inside a press. The beads are first expanded in a steam pre-expander and loaded into a fabric storage hopper. The stored expanded beads are then injected into the block press where they are exposed to steam heat. The foam blocks are later cut to size and shipped. Pentane emissions are now controlled using a VOC abatement system that uses the boiler to combust pentane captured from the process. Pentane emissions from the pre-expander, block mold, and bead aging areas are captured and conveyed to the existing natural gas boiler. Pentane-laden steam captured and removed from the block mold and pre-expander is passed through a condenser to remove excess moisture. The pentane- laden air is fed into an enclosure which is constructed around the bead storage area. The enclosure is maintained under negative pressure to ensure effective capture of the pentane. A portion of the air in the bead storage area enclosure is continuously removed and delivered to the natural gas fired boiler for combustion, which will thermally 0 . ) $ . ) - " 2 destroy the pentane. Because the pentane-laden air has a different heat value than natural gas, an oxygen controller was installed to adjust the air to fuel ratio entering the boiler to ensure consistent combustion conditions under the varying pentane load. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104200009-17, dated April 12, 2017 NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Atlas Molded Products Expanded Polystyrene Mfg. Plant 111 West Fireclay Avenue 111 West Fireclay Avenue Murray, UT 84107 Murray, UT 84107 SIC Code: 3086: (Plastics Foam Products) 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] 3 I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No modifications to the permitted equipment have occurred since the previous inspection. Digital records are maintained and kept for a minimum of two years. Good pollution control is maintained for the permitted equipment and processes. Maintenance is recorded. No UAC R307-107 applicable breakdowns have occurred during the previous 12-months. The 2023 activity year Emissions Inventory was submitted and is attached to this inspection memo. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Expandable Polystyrene Manufacturing Facility II.A.2 Expandable Polystyrene Equipment A. One (1) densifier B. One (1) pre-expander C. Bead storage bags D. Block molding equipment E. Packaging storage bags F. Two (2) packaging expanders G. Misc. wire cutters II.A.3 One (1) Boiler Maximum Equipment Rating: 12.5 MMBTU/hr Fuel Type: Natural Gas/Pentane II.A.4 VOC Abatement System A. One (1) Negative Pressure Enclosure B. One (1) Condenser C. One (1) Oxygen Trim System Note: This system captures pentane emissions from the pre-expander, block mold, and bead aging areas via an enclosure which is under negative pressure and conveys them to the Boiler as a fuel source. II.A.5 One (1) Emergency Fire Sprinkler Pump Maximum Equipment Rating: 160 bhp Fuel Type: Diesel Status: In Compliance. The permitted equipment was observed during the inspection. Item II.A.2.F (The two packaging expanders) has been removed. II.B Requirements and Limitations II.B.1 Site-wide Operating Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. The diesel-powered fire sprinkler pump - 20% opacity 4 B. The natural gas boiler - 10% opacity C. All other points - 20% opacity. [R307-401-8] Status: In Compliance. II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. For sources that are subject to NSPS, opacity shall be determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [40 CFR 60, R307-401-8] Status: In Compliance. No visible emissions were observed from any point or vent. The observations were conducted in a manner consistent with Method 9. See the attached VEO. II.B.1.b The owner/operator shall use only natural gas or pentane as fuel in the boiler. [R307-401-8] Status: In Compliance. This facility uses only a combination of pentane and natural gas in the boiler. II.B.2 Volatile Organic Compound (VOC) Limitations II.B.2.a The owner/operator shall install and operate a VOC Abatement System at all times of plant operation. The Abatement System shall control pentane emissions from the pre-expander, block mold, and bead aging areas. Pentane laden air captured from the pre-expander, block mold, and bead aging areas shall be delivered from the bead aging enclosure to the boiler for use as a fuel source. An oxygen trim system will ensure consistent combustion conditions in the boiler from the use of both natural gas and pentane. [R307-401-8] Status: In Compliance. The VOC abatement system has been installed and is operating as designed. Pentane emissions from the pre-expander, block mod, and bead aging areas are captured in a negative pressure enclosure. The pentane-laden air is then captured and sent to the boiler to be used as a fuel source. This system is electronically monitored. Alarms are triggered if the negative pressure falls below the manufacturer recommended rates. II.B.2.b The plant-wide VOC emissions from non-combustion points shall not exceed the following: 64.6 tons per rolling 12-month period Compliance with the limitation shall be determined on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months. The VOC emissions shall be determined by maintaining a record of VOC emitting materials used each month. The record shall include the following data for each material used: A. Names of all VOC emitting materials B. Amount and location of materials containing VOCs used on a monthly basis and summed for every location and for the entire plant each month C. Percent by weight of all VOCs in each material used and VOCs retained in the manufactured product shall be tested if directed by the Director. The test method shall 5 be approved by the Director. D. The amount of VOCs emitted monthly by each material used shall be calculated by the following procedure or other method approved by the Director: VOC = % VOC by Weight/100 x [VOC emitting material used] x [VOC (pentane) removal efficiency] E. The amount of VOCs, shipped out as hazardous waste, or retained in the manufactured product for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307-401-8] Status: In Compliance. The plant-wide VOC emissions from the 12-month rolling period of January 2024 through December 2024 was reported as 23.41. The calculations are based on the control efficiency rate and the emission rate after the VOC destruction. See the attached submitted spreadsheet for the EPS process. II.B.3 Emergency Fire Pump Requirements II.B.3.a The owner/operator may operate the emergency diesel powered fire sprinkler pump only in the event of a fire or for the purpose of regular maintenance checks and readiness testing. Maintenance checks and readiness testing is limited to 100 hours per rolling 12-month period. [R307-401-8] Status: In Compliance. The emergency fire pump was operated for 6.2 hours during the 12 months for the calendar year of 2024. The pump is operated once a month for exercising and twice annually for servicing purposes. See the attached "Emmut Fire Pump Run- Hours” log. II.B.3.a.1 Records documenting pump usage shall be kept in a log and they shall show the date the pump was used, the duration in hours of the pump usage, and the reason for each pump usage. [R307-401-8] Status: In Compliance. Records are maintained for documenting the pump engine use. II.B.3.b The owner/operator shall use fuel oil as fuel in the fire pump. [R307-401-8] Status: In Compliance. II.B.3.c The sulfur content of the fuel oil shall not exceed 15 ppm by weight. [R307-203] Status: In Compliance. II.B.3.c.1 Sulfur content shall be determined by ASTM Method D-4294-89 of approved equivalent. Certification of the fuel oil shall be either by the owner/operators own testing or test reports from the fuel oil marketer. [R307-203] Status: In Compliance. Only ULSD fuel is used. Reladyne certifies their product as meeting the federally required sulfur content of 15 ppm by weight or less. See the attached invoice and email correspondence from Atlas Molded Products. 6 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) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. The current boiler was installed as a replacement boiler on the November 1, 2007 AO. All Part 60 Dc 60.48c notification requirements were submitted as part of the NOI for this AO on August 22, 2007. No modifications to this boiler have occurred since the installation date. Part 60 Dc 60.48c (g) 2 requires that the operator record the amount of fuel combusted, but does not set a limit. See the attached natural gas records. Pentane fuel use is not regulated under this subpart but is recorded on the VOC log as destroyed VOC captured and sent to the boiler. As per 60.48c(i), records are kept on site for a minimum of two years. MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The maintenance manager, stated during this inspection that none of the equipment on site had changed since the current 2017 AO was issued. The emergency fire pump engine was identified as being installed in 1994 on the inspection memo DAQC-0273-19, dated February 12, 2019. This engine operated for a reported total of 6.2 hours during the calendar year of 2024. The records included the date, duration, and reason for use. Regular maintenance is performed and documented by the contracted company Smith Power Products. These records are maintained at the site office and were reviewed at the time of this inspection. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. The requirements of this Rule are incorporated by Conditions II.B.3.c and II.B.3.c.1. Stationary Sources [R307-210] Status: In Compliance. This Rule incorporates NSPS Subpart Dc Emission Standards for natural gas boilers. See the Federal Requirement Section for more information. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This Rule incorporates MACT ZZZZ NESHAP Standards for Stationary Reciprocating Internal Combustion Engines. See the Federal Requirement Section for more information. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. The entrances and truck operation areas surrounding this facility are paved. The source contact is reportedly trained to observe visible emissions. No visible dust or other emissions were observed during this inspection. 7 NOx and CO Emission Control for Natural Gas-Fired Boilers Greater Than 5.0 MMBtu [R307-316] Status: Not applicable at this time due to the combined fuel use of the installed boiler. R307-316-2(a) states that this Rule applies to boilers that are fueled exclusively by natural gas. Atlas Molded Products uses captured pentane gas for fuel as a method of VOC control. The current boiler was installed in 2007. This issue may be reviewed in the future in the event that this operation changes the location of the plant due to losing the lease at the Murray location. Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: In Compliance. Atlas Molded Products’ VOC emissions are present only in the form of gas and solid pellets. No VOC materials were observed spilled, discarded, stored in open containers, or handled in a way that would result in greater evaporation of VOCs. EMISSION INVENTORY: An Emissions Inventory was submitted for the 2023 Activity Year and is attached to this memo. Listed below are the Actual Emissions Inventory provided from Atlas Molded Products – Expanded Polystyrene Mfg. Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN104200009-17, dated April 12, 2017, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/year Carbon Monoxide 4.43 Nitrogen Oxides 4.57 Particulate Matter – PM10 0.43 Particulate Matter – PM2.5 0.43 Sulfur Dioxide 0.05 Volatile Organic Compounds 64.60 Hazardous Air Pollutant PTE lbs/year Generic HAPs 340.00 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions are on record for the last five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order DAQE-AN104200009-17, dated April 12, 2017, NSPS Subpart Dc, and MACT Subpart ZZZZ, Atlas Molded Products should be considered to be in compliance. The source appeared to be well maintained and operated. Records were made available during the inspection and via email after the site visit. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: This source contact stated that this operation may lose their lease in the future. The requirement to obtain a new AO in the event of a change of location was discussed. Check for a modified AO at a new location prior to the next inspection. Otherwise, inspect as usual maintaining the same frequency. NSR RECOMMENDATIONS: The VOC limit established by Condition II.B.2.b of the current AO exceeds the new Major Source threshold of 50 tons per year recently 8 established by EPA. Minor Source NSPS should work with this operation to reevaluate their VOC PTE. Equipment item II.A.2.F, the two packaging expanders, should be considered for removal from the permit as the equipment is no longer on site. Be aware that this facility may change the location site due to losing their lease. The requirement to submit a NOI for a change in address was discussed with the site contact. ATTACHMENTS: VEO, email correspondence, VOC Emissions Table, Natural Gas consumption log, emergency fire pump engine hour log, diesel fuel invoice, and 2023 Activity Year Emissions Summary Report. Susan Weisenberg <sweisenberg@utah.gov> Re: records to complete the December 11 inspection 1 message Pete Sorensen <psorensen@atlasroofing.com>Fri, Feb 7, 2025 at 7:48 PM To: Susan Weisenberg <sweisenberg@utah.gov> Susan, Oh, my goodness! I got so completely tied up with traveling out-of-state to one of our sister plants and with our own boiler's repairs that this totally skipped my mind. Attached are the items you requested (i.e., fire pump runtime calculations, low sulfur diesel fuel receipt and 12- month rolling VOC). One thing I'd like to point out is the receipt for the fuel is the most recent receipt. We do not purchase a lot of fuel - because we do not run our fire pump for extended periods of time, (we only ran a total of 6.2 hrs. for the entire year). As you probably remember, our former plant GM, (Jes L.), had gone to work for a different company and unfortunately, he was the only one here who maintained that portion of the report 12-month plan VOC report. Our current GM, Mark, has contacted our corporate EHS for assistance in putting this report together. I believe that Mark and I need some training to keep this updated. I apologize for the delay. Br, Gary Peter Sorensen Maintenance Manager   Atlas Molded Products Office: 801-479-9918 Mobile: 385-628-8680 111 West Fireclay Avenue Murray, Utah 84107 Web: www.atlasmoldedproducts.com Email: psorensen@atlasroofing.com From: Susan Weisenberg <sweisenberg@utah.gov> Sent: Wednesday, January 29, 2025 9:51 AM To: Pete Sorensen <psorensen@atlasroofing.com> Subject: Fwd: records to complete the December 11 inspecon CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. 2/11/25, 7:02 PM State of Utah Mail - Re: records to complete the December 11 inspection https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3183522145625348392%7Cmsg-f:1823455747133650350…1/2 Hello, It looks like this email may have been sent to the wrong contact person. The below is a records request to complete the Division of Air Quality inspection at your site conducted on December 11, 2024. To date, I am unable to find a response with the required information. Please review and get back to me with the information or resend the response. Thanks, contact me if you have any questions. The 12-month rolling total reporting period is for December 2023 to November 2024. Susan Weisenberg, Environmental Scientist Office: 385-306-6512 ---------- Forwarded message --------- From: Susan Weisenberg <sweisenberg@utah.gov> Date: Wed, Dec 11, 2024 at 3:41 PM Subject: records to complete the December 11 inspection To: Mark Casper <mcasper@atlasroofing.com> Thank you for meeting with me this morning and showing me the Atlas Molded Products facility. As discussed, I will need the following to complete the inspection. 1- as per Condition II.B.2.a - the most recent 12-month rolling total available for plant-wide VOC emissions. 2 - as per II.B.3.a - the most recent 12-month total hours the fire pump engine operated for maintenance and testing. 3 - As per Condition II.B.3.c - a recent invoice indicating that low sulfur diesel fuel is used for the fire pump engine. Thanks, let me know if you have any questions or comments.. Susan Weisenberg, Environmental Scientist Office: 385-306-6512 2 attachments RELADYNE 61746.pdf 3017K Atlas Molded Products_Murray UT Rolling 12 Month Emissions Summary.xlsx 19K 2/11/25, 7:02 PM State of Utah Mail - Re: records to complete the December 11 inspection https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3183522145625348392%7Cmsg-f:1823455747133650350…2/2 Susan Weisenberg <sweisenberg@utah.gov> Re: records to complete the December 11 inspection 1 message Susan Weisenberg <sweisenberg@utah.gov>Tue, Feb 11, 2025 at 8:00 AM To: Pete Sorensen <psorensen@atlasroofing.com> Thanks for your response. I received and reviewed your records. Just as a reminder, you stated during my site visit that this operation may relocate in the next couple of years due to leasing issues at this address. Please contact the DAQ NSR Minor Source Engineering Section to obtain a new Approval Order prior to installing this equipment at a new site. The operating conditions may be subject to change at a different location. See the link below for more information about setting up a meeting to get a new air quality permit. https://utconcierge.qualtrics.com/jfe/form/SV_dopwfGzXwNaCjhc Susan Weisenberg, Environmental Scientist Office: 385-306-6512 2/11/25, 7:00 PM State of Utah Mail - Re: records to complete the December 11 inspection https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3183522145625348392%7Cmsg-a:r-740813975495726122…1/1 Raw Material Consumption Raw Material Consumption 12-Month Rolling Raw Material COA - Pentane Average Total VOC Pre- Destruction (Lbs.)(Ton)(Lbs.)(%)(Lbs) 2022 October 461,533 231 6,451,305 4.92 1152 85 2022 November 0 5,959,301 85 2022 December 0 5,464,841 85 2023 January 39,654 20 5,052,200 4.74 85 85 2023 February 33,071 17 4,512,412 5.22 78 85 2023 March 231,749 116 4,044,746 4.71 527 85 2023 April 368,488 184 3,917,269 5.44 963 85 2023 May 493,165 247 3,820,043 5.14 1240 85 2023 June 482,892 241 3,730,208 5.57 1415 85 2023 July 448,428 224 3,668,682 5.17 1086 85 2023 August 419,453 210 3,585,520 5.26 1057 85 2023 September 404,404 202 3,382,837 5.07 958 85 2023 October 364,357 182 3,285,661 5.32 910 85 2023 November 424,878 212 3,710,539 5.16 1048 85 2023 December 400,318 200 4,110,857 5.65 1141 85 2024 January 416,175 208 4,487,378 5.32 1060 85 2024 February 469,675 235 4,923,982 5.16 1165 85 2024 March 497,576 249 5,189,809 5.45 1280 85 2024 April 460,644 230 5,281,965 5.46 1255 85 2024 May 421,170 211 5,209,970 5.43 1134 85 2024 June 422,591 211 5,149,669 5.29 1089 85 2024 July 513,369 257 5,214,610 5.24 1257 85 2024 August 430,894 215 5,226,051 5.38 1064 85 2024 September 375,362 188 5,197,009 5.46 933 85 2024 October 415,193 208 5,247,845 5.39 1019 85 2024 November 316,058 158 5,139,025 5.17 766 85 2024 December 282,878 141 5,021,585 4.62 660 85 2025 January 0 2025 February 0 Date - Year Date - Month Max Emissions Control Efficiency Process Monthly Emission Natural Gas Monthly Emission Site wide Monthly Emission Rolling Emission %(Ton)(Ton)(Ton)(Ton) 0.21 1.99 0.005 2 29.13 0.21 0 0.006 0.01 26.9 0.21 0 0.007 0.01 24.67 0.21 0.16 0.005 0.17 22.74 0.21 0.15 0.005 0.16 20.56 0.21 0.96 0.006 0.96 18.35 0.21 1.76 0.005 1.76 17.9 0.21 2.22 0.005 2.23 17.37 0.21 2.36 0.005 2.36 17.06 0.21 2.03 0.005 2.04 16.74 0.21 1.93 0.005 1.94 16.29 0.21 1.8 0.005 1.8 15.44 0.21 1.7 0.006 1.71 15.14 0.21 1.92 0.006 1.93 17.07 0.21 1.98 0.006 1.99 19.05 0.21 1.94 0.006 1.95 20.83 0.21 2.12 0.005 2.13 22.8 0.21 2.38 0.006 2.38 24.22 0.21 2.2 0.006 2.21 24.67 0.21 2 0.006 2.01 24.45 0.21 1.96 0.006 1.96 24.05 0.21 2.36 0.008 2.37 24.38 0.21 2.03 0.007 2.04 24.47 0.21 1.8 0.006 1.8 24.47 0.21 1.96 0.008 1.97 24.74 0.21 1.43 0.008 1.44 24.25 0.21 1.15 0.005 1.15 23.41 Calendar Year 2020 Emission Calendar Year 2021 Calendar Year 2021 Emission Calendar Year 2021 Emission Calendar Year 2022 Calendar Year 2022 Emission (lbs)(a) Calendar Year 2022 Emission (Ton) Calendar Year 2023 Calendar Year 2023 Emission (lbs)(a) Calendar Year 2023 Emission (Ton) Calendar Year 2024 Calendar Year 2024 Emission (lbs)(a) Calendar Year 2024 Emission (Ton) Calendar Year 2025 Calendar Year 2025 Emission (lbs)(a) Calendar Year 2025 Emission (Ton) (Ton)(MMCF) (lbs)(a)(Ton)(MMCF)(MMCF)(MMCF)(MMCF) Jan 1.986 10.923 0.005 2.318 12.75 0.006 2.64 14.52 0.00726 1.971 10.8405 0.00542 2.192 12.056 0.006028 0 0 0 Feb 1.985 10.9175 0.005 1.917 10.54 0.005 2.229 12.2595 0.00613 1.853 10.1915 0.005096 1.958 10.769 0.005385 0 0 0 Mar 2.146 11.803 0.006 1.76 9.68 0.005 2.204 12.122 0.006061 2.223 12.2265 0.006113 2.085 11.4675 0.005734 0 0 0 Apr 2.002 11.011 0.006 1.738 9.56 0.005 1.977 10.8735 0.005437 1.903 10.4665 0.005233 2.222 12.221 0.006111 0 0 0 May 1.907 10.4885 0.005 1.826 10.04 0.005 2.013 11.0715 0.005536 1.943 10.6865 0.005343 2.23 12.265 0.006133 0 0 0 Jun 1.884 10.362 0.005 1.914 10.53 0.005 1.988 10.934 0.005467 1.893 10.4115 0.005206 2.029 11.1595 0.00558 0 0 0 Jul 1.611 8.8605 0.004 1.848 10.16 0.005 1.855 10.2025 0.005101 1.944 10.692 0.005346 2.817 15.4935 0.007747 0 0 0 Aug 1.324 7.282 0.004 1.874 10.31 0.005 1.921 10.5655 0.005283 1.934 10.637 0.005319 2.534 13.937 0.006969 0 0 0 Sep 1.325 7.2875 0.004 1.827 10.05 0.005 2.013 11.0715 0.005536 1.868 10.274 0.005137 2.216 12.188 0.006094 0 0 0 Oct 1.716 9.438 0.005 1.91 10.51 0.005 1.94 10.67 0.005335 2.048 11.264 0.005632 2.916 16.038 0.008019 0 0 0 Nov 1.909 10.4995 0.005 2.07 11.39 0.006 2.2 12.1 0.00605 2.277 12.5235 0.006262 3.029 16.6595 0.00833 0 0 0 Dec 2.164 11.902 0.006 2.335 12.84 0.006 2.4 13.2 0.0066 2.214 12.177 0.006089 1.853 10.1915 0.005096 0 0 0 Total 21.959 120.77 0.06 23.337 128.35 0.064 25.38 139.59 0.069795 24.071 132.3905 0.066195 28.081 154.4455 0.077223 0 0 0 Month Calendar Year 2020 (MMCF) Calendar Year 2020 Emission (lbs)(a) 2024 MONTH DATE W.O.# RUN TYPE RUN HR METER NOVEMBER 11/3/2023 16819 EX 31.8 DECEMBER 12/8/2023 16950 EX 31.9 JANUARY 17-Jan 17109 EX 32 FEBRUARY 26-Feb 17293 EX 32.4 MARCH 27-Mar 17442 EX 33.6 APRIL 4-Apr 17618 EX 33.8 MAY 13-Jun 16350 EX 34.2 JUNE 25-Aug 16534 ANN(1)36.9 JULY 9-Jul 16680 EX 37 AUGUST 16-Aug 18142 EX 37.5 SEPTEMBER 16-Sep 18301 EX 37.9 OCTOBER 24-Oct N/A ANN(2)38 6.2 hrs. EMMUT FIRE PUMP RUN-HOURS For Year: TOTAL RUNHOURS: 2023 Emissions Inventory Report Atlas Molded Products (10420) 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)0.09598 <.00001 0.09598 PM10-FIL PM10 Filterable 0.02374 <.00001 0.02374 PM25-PRI PM2.5 Primary (Filt + Cond)0.09598 <.00001 0.09598 PM25-FIL PM2.5 Filterable 0.02374 <.00001 0.02374 PM-CON PM Condensible 0.07122 <.00001 0.07122 SO2 Sulfur Dioxide 0.00845 <.00001 0.00845 NOX Nitrogen Oxides 1.26388 <.00001 1.26388 VOC Volatile Organic Compounds 25.45987 <.00001 25.45987 CO Carbon Monoxide 1.05268 <.00001 1.05268 7439921 Lead 0.00001 <.00001 0.00001 NH3 Ammonia 0.04005 <.00001 0.04005 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 <.00001 107028 Acrolein (HAP)VOC <.00001 7440382 Arsenic (HAP)PM <.00001 71432 Benzene (HAP)VOC 0.00003 7440417 Beryllium (HAP)PM <.00001 106990 1,3-Butadiene (HAP)VOC <.00001 7440439 Cadmium (HAP)PM 0.00001 7440473 Chromium (HAP)PM 0.00002 7440484 Cobalt (HAP)PM <.00001 50000 Formaldehyde (HAP)VOC 0.00094 110543 Hexane (HAP)VOC 0.02249 7439965 Manganese (HAP)PM <.00001 7439976 Mercury (HAP)- <.00001 91203 Naphthalene (HAP)VOC 0.00001 7440020 Nickel (HAP)PM 0.00003 130498292 PAH, total (HAP)PM <.00001 7782492 Selenium (HAP)PM <.00001 108883 Toluene (HAP)VOC 0.00004 1330207 Xylenes (Mixed Isomers) (HAP)VOC <.00001 91576 2-Methylnaphthalene (HAP)PM <.00001 *Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated. 1/2 2/2