DAQ-2025-001566

1
DAQC-CI105100001-25
Site ID 10510 (B1)

MEMORANDUM

TO: FILE – DELUXE MANUFACTURING OPERATIONS – Coldset Printing Presses
& Stamping

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: March 20, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: November 13, 2024

SOURCE LOCATION: 5820 West Harold Gatty Drive
Salt Lake City, UT 84116
SOURCE CONTACTS: Lynn Grundvig, EHS Manager
435-830-0590 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Deluxe Manufacturing operates a printing press facility that
prints business cards, envelopes, stationery, bank cheques for
small businesses, bank deposit slips, and manufactures hand
stamps. All the printing presses use the offset lithography
technique. Digital printing is used primarily for bank cheques.
There are three main processes involved in the printing process.
The pre-press process involves the creation of an image on the
printing plate using a substrate (polymer, heavy paper, or
aluminum). The press process involves using the plate as an
image for ink transfer to a rubber blanket and then to the printing
surface as the non-image areas rejects the ink. Images from
metal plates are transferred to rubber blankets or rollers and then
to the print media using the mass production printing technique
of offset lithography. The image information is put on thin metal
plates which are dampened by water and ink by rollers on the
press. The oil-based ink adheres to the image area, the water to
the non-image area. The inked area is then transferred to a rubber
cylinder or "blanket" and then onto the paper as it passes around
the blanket.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN105100011-24, dated January
24, 2024

) $ ' $ '
2
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Deluxe Manufacturing Operations - Coldset
Printing Presses & Stamping

5820 West Harold Gatty Drive 5820 West Harold Gatty Drive
Salt Lake City, UT 84116 Salt Lake City, UT 84116

SIC Code: 2761: (Manifold Business Forms)

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] Status: Out of Compliance. The source has modified the equipment. See Section II for more details. No limits set forth in this AO appear to have been exceeded. The equipment appeared to be properly operated and maintained according to manufacturer recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. The source renewed their AO in January 2024. As such, no emissions were reported for 2023. The source was reminded to submit an emissions report in 2027 for the 2026 reporting year.

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. See the attached notification letter addressed to Alan Humpherys and dated September 6, 2024.

3
Section II: SPECIAL PROVISIONS

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

II.A.1 Deluxe Manufacturing Operations Printing operations
II.A.2 Digital Offset Press Two (2) HP 100K digital offset presses
II.A.3 Digital Press One (1) HP 7900 digital press
II.A.4 Printing Press One (1) HP T250 thermal inkjet printing press
II.A.5 Printing Presses Five (5) two-color Heidelberg GTO 52 presses
II.A.6 Printing Presses Nineteen (19) DCOP presses
II.A.7 Printing Presses One (1) Heidelberg 6-color speedmaster printing press
II.A.8 Printing Presses Two (2) Ryobi presses
II.A.9 Printing Presses Three (3) Halm jet presses
II.A.10 Machine Cleaners/Oilers Three (3) numbering machine cleaners/oilers
II.A.11 Printing Press One (1) six-color Didde press
II.A.12 Printing Press One (1) four-color Didde press
II.A.13 Printing Press One (1) four-color Heidelberg GTO 52 press
II.A.14 Printing Press One (1) two-color super jet press
II.A.15 Support Equipment One (1) folder
II.A.16 Support Equipment One (1) collator
II.A.17 Support Equipment One (1) Kodak plate maker
II.A.18 Various Boilers Rating: < 5 MMBtu/hr each Fuel: Natural gas (Exempt equipment; for information only)
4
II.A.19 Finishing Area One (1) finishing operation area
II.A.20 UV Curing Units Six (6) electrical UV curing units (for information only)
Status: Out of Compliance. The four-color Heidelberg GTO 52 press in Condition
II.A.13 has been swapped out for a 6-color Heidelberg speedmaster printing
press similar to Condition II.A.7. No Notice of Intent was submitted prior to
changing the equipment. A Compliance Advisory (DAQC-1239-24) was issued
on December 18, 2024. The source responded on January 8, 2024. An Early
Settlement Agreement (DAQC-124-25) was issued on February 10, 2025. The
source submitted payment on February 19, 2025. A Signed Early Settlement
Agreement (DAQC-249-25) was issued on March 7, 2025. No further action is
recommended at this time.

The source operates two parts washers for solvent cleaning operations. These
use aqueous cleaner with no associated emissions. Safety Data Sheets have been
retained for review, via a GRAMA request, and they can be found in the DAQ
network folder at the following location \COMPLY\SECTION\Minor Source
GRAMA Records\10510 Deluxe Manufacturing 2024.

II.B Requirements and Limitations
II.B.1 Site-Wide Requirements and Limitations
II.B.1.a The owner/operator shall not allow visible emissions from any emission point to exceed 20% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. No visible emissions were observed from any point at the time of inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.
II.B.2 VOC and HAP Limitations.
II.B.2.a The owner/operator shall not emit more than 20.42 tons of VOCs per rolling 12-month period from the printer presses, cleaning solvents, and associated operations. [R307-401-8]
II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed].
[R307-401-8]

II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated
above to provide the monthly total VOC emissions. [R307-401-8]

5
II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC-emitting material B. The maximum percent by weight of VOCs in each material used C. The density of each material used D. The volume of each VOC-emitting material used E. The amount of VOCs emitted from each material F. The amount of VOCs reclaimed and/or controlled from each material G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8] Status: In Compliance. Emissions appear to be calculated correctly. For the rolling 12-month period from October 23 - September 24, a total of 6.14 tons of VOC emissions were reported. See the attached table for more information. II.B.2.b The owner/operator shall not use any material containing HAPs in inks, fountain solution, and
cleaning solvents. [R307-401-8]

Status: In Compliance. None of the inks, fountain solutions, or cleaning solvents contain
any HAPs. Safety Data Sheets have been retained for review, via a GRAMA request, and
they can be found in the DAQ network folder at the following location
\COMPLY\SECTION\Minor Source GRAMA Records\10510 Deluxe Manufacturing 2024.

II.B.2.c The owner/operator shall comply with the applicable requirements in UAC R307-325, Ozone
Nonattainment and Maintenance Areas: General Requirements, and R307-351, Graphic Arts.
[R307-325, R307-351]

Status: In Compliance. See the area source rules below for more information.

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:

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

Status: In Compliance. No VOC containing materials were observed spilled, discarded, stored in
open containers, or handled in any other way that would result in greater evaporation.

6
Degreasing [R307-335]

Status: In Compliance. Two parts washers are used by the source. Both lids closed at the time of
inspection. Excess solvent and waste drains into covered containers. The waste tanks and containers
had no visible leaks and appeared to be in good operating condition. The parts washers use
ArmaKleen BIO 24 Concentrate. Safety Data Sheets have been retained for review, via a GRAMA
request, and they can be found in the DAQ network folder at the following location
\COMPLY\SECTION\Minor Source GRAMA Records\10510 Deluxe Manufacturing 2024.
Graphic Arts [R307-351]

Status: In Compliance. All inks and coatings comply with the VOC content limits established in
Tables 1 and 2 of this area source rule. All cleaning materials have a vapor pressure of less than 10
mm Hg at 68 degrees Fahrenheit. Safety Data Sheets have been retained for review, via a GRAMA
request, and they can be found in the DAQ network folder at the following location
\COMPLY\SECTION\Minor Source GRAMA Records\10510 Deluxe Manufacturing 2024.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Deluxe
Manufacturing Operations - Coldset Printing Presses & Stamping on the Approval Order (AO)
DAQE-AN105100011-24, dated January 24, 2024. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 317.00
Carbon Monoxide 0.22
Nitrogen Oxides 0.13
Particulate Matter - PM10 0.02
Particulate Matter - PM2.5 0.02
Sulfur Dioxide 0.00
Volatile Organic Compounds 20.43

Hazardous Air Pollutant PTE lbs/yr

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN105100011-24,
dated January 24, 2024, the overall status is: Out of Compliance.
The facility was operating with unpermitted equipment. A
Compliance Advisory (DAQC-1239-24) was issued on
December 18, 2024. The source responded on January 8, 2024.
An Early Settlement Agreement (DAQC-124-25) was issued on
February 10, 2025. The source submitted payment on February
19, 2025. A Signed Early Settlement Agreement
(DAQC-249-25) was issued on March 7, 2025. No further action
is recommended at this time.

7
HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Ensure that equipment list matches AO. Safety glasses are
required PPE for this inspection.

NSR RECOMMENDATIONS: Look out for notification to modify equipment list to include the
correct presses and parts washers that are on site.

ATTACHMENTS: VEO form, email correspondence, VOC emissions, 1.8
notification, SDS
Daniel Riddle <[e-mail]>
10510 Follow up to air quality inspection
6 messages
Daniel Riddle <[e-mail]> Wed, Nov 13, 2024 at 2:35 PM
To: [e-mail]
Lynn,
Thank you for taking the time to meet with me today for your air quality inspection. As discussed, here are the records I
need to complete my inspection report:
From AO DAQE-AN105100011-24 (attached):
Condition II.B.2.a - VOC emissions (Jan 23 - Sept 24)
Condition II.B.2.b - proof that no HAPs are in any inks, fountain solution, or cleaning solvents
For UAC R307-351 (attached)
List of all materials from 307-351-5, Tables 1 and 2 with their SDS or EDS or TDS showing that VOC content does not
exceed the limits in the tables for any individual product.
Please also include the SDS for the solution used in the two parts washers.
Please provide these records by November 18, 2024. Thanks and let me know if you have any questions.
Best,
Daniel
2 attachments
R307-351.pdf
95K
DAQ-2024-004688.pdf
3281K
Grundvig, Lynn <[e-mail]> Fri, Nov 15, 2024 at 8:42 AM
To: Daniel Riddle <[e-mail]>
Hi Daniel,
Three items are attached.
1. Deluxe SLC VOC Log October 2023-September 2024 Summary.
2. Deluxe SLC VOC Log October 2023-September 2024.
3. SLC Chemicals Onsite.
Lynn Grundvig
Environmental, Safety and Health Manager
11/21/24, 3:16 PM State of Utah Mail - 10510 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6290486660773724060&simpl=msg-a:r-27244817438849…1/5
Message originates from outside our organization. Use caution with correspondence, attachments or hyperlinks (URLs).
5820 W Harold Gatty Dr
Salt Lake City UT 84116
C: 435.830.0590
deluxe.com | NYSE: dlx
From: Daniel Riddle <[e-mail]>
Sent: Wednesday, November 13, 2024 2:36 PM
To: Grundvig, Lynn <[e-mail]>
Subject: [EXTERNAL] 10510 Follow up to air quality inspection
[Quoted text hidden]
3 attachments
Deluxe SLC VOC Log October 2023-September 2024 Summary.xlsx
13K
Deluxe SLC VOC Log October 2023-September 2024.xlsx
97K
SLC Chemicals Onsite.xlsx
42K
Grundvig, Lynn <[e-mail]> Fri, Nov 15, 2024 at 8:49 AM
To: Daniel Riddle <[e-mail]>
Daniel,
All product SDS’s are attached except for ink. I’ll send in a separate file.
Lynn Grundvig
Environmental, Safety and Health Manager
11/21/24, 3:16 PM State of Utah Mail - 10510 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6290486660773724060&simpl=msg-a:r-27244817438849…2/5
Message originates from outside our organization. Use caution with correspondence, attachments or hyperlinks (URLs).
5820 W Harold Gatty Dr
Salt Lake City UT 84116
C: 435.830.0590
deluxe.com | NYSE: dlx
From: Daniel Riddle <[e-mail]>
Sent: Wednesday, November 13, 2024 2:36 PM
To: Grundvig, Lynn <[e-mail]>
Subject: [EXTERNAL] 10510 Follow up to air quality inspection
Lynn,
[Quoted text hidden]
4 attachments
All Parts Washer SDS.pdf
413K
All Cleaning Solvent SDS.pdf
797K
All Coatings SDS.pdf
1618K
All Fountain Solution SDS.pdf
263K
Grundvig, Lynn <[e-mail]> Fri, Nov 15, 2024 at 9:58 AM
To: Daniel Riddle <[e-mail]>
11/21/24, 3:16 PM State of Utah Mail - 10510 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6290486660773724060&simpl=msg-a:r-27244817438849…3/5
Message originates from outside our organization. Use caution with correspondence, attachments or hyperlinks (URLs).
Message originates from outside our organization. Use caution with correspondence, attachments or hyperlinks (URLs).
From: Daniel Riddle <[e-mail]>
Sent: Wednesday, November 13, 2024 2:36 PM
To: Grundvig, Lynn <[e-mail]>
Subject: [EXTERNAL] 10510 Follow up to air quality inspection
Lynn,
[Quoted text hidden]
2 attachments
Ink 03.pdf
1370K
Ink 04.pdf
7656K
Grundvig, Lynn <[e-mail]> Fri, Nov 15, 2024 at 9:59 AM
To: Daniel Riddle <[e-mail]>
From: Daniel Riddle <[e-mail]>
Sent: Wednesday, November 13, 2024 2:36 PM
To: Grundvig, Lynn <[e-mail]>
Subject: [EXTERNAL] 10510 Follow up to air quality inspection
Lynn,
[Quoted text hidden]
Ink 01.pdf
35963K
Daniel Riddle <[e-mail]> Mon, Nov 18, 2024 at 8:22 AM
To: "Grundvig, Lynn" <[e-mail]>
11/21/24, 3:16 PM State of Utah Mail - 10510 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6290486660773724060&simpl=msg-a:r-27244817438849…4/5
Thanks Lynn - I'll look these records over and let you know if I need anything else.
[Quoted text hidden]
11/21/24, 3:16 PM State of Utah Mail - 10510 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6290486660773724060&simpl=msg-a:r-27244817438849…5/5
Rolling 12-Month Totals for VOC and Individual HAP
VOC
tons
24-Sep 0.42
24-Aug 0.53
24-Jul 0.44
24-Jun 0.51
24-May 0.49
24-Apr 0.53
24-Mar 0.48
24-Feb 0.44
24-Jan 0.5
23-Dec 0.5
23-Nov 0.47
23-Oct 0.83
Rolling Totals 6.14
Annual Limits 20.42
Percent of Permit Allowance 30.08%
Exceedance?NO
Note1: The products used at the site do not contain HAPs.
Year & Month
# Internal

Internal
September 06, 2024

Utah Department of Environmental Quality
Division of Air Quality
Mr. Alan Humphreys
P.O. Box 144820
Salt Lake City, UT 84114-4820
Via email: [e-mail]

Re: Construction Completion Notification
Deluxe Manufacturing Operations
5820 West Harold Gatty Drive
Salt Lake City, Utah
Project Number: N105100011
Permit Number: DAQE-AN105100011-24

Dear Mr. Humpherys:

Deluxe Manufacturing Operation is notifying the agency that the equipment constructions authorized
under Approval Order (AO) received on January 24, 2024, have been completed. The following
equipment were constructed under the AO:

ƒ Two (2) HP 100K Digital Offset Presses
ƒ One (1) HP 7900 Digital Offset Press
ƒ One (1) HP T250 Inkjet Printing Press

The equipment was constructed within 18 months of the AO date per Utah Administrative Code R307-
401-18 and permit General Provision I.8.

Please do not hesitate to contact me at 435.830.0590 or [e-mail] if you have any
questions or require further information regarding this matter.

Sincerely,

Lynn R Grundvig