DAQ-2025-000285

DAQE-GN102700013-25

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Eric Lewis
Align Precision - Cedar City, LLC
526 Aviation Way
Cedar City, UT 84721
[e-mail]

Dear Mr. Lewis:

RE: Revocation of Approval Order DAQE-412-00
Project Number: N102700013

On January 7, 2025, the Division of Air Quality (DAQ) received your request to revoke Approval Order
(AO) DAQE-412-00, dated July 6, 2000. Align Precision – Cedar City LLC requested this AO be revoked
and replaced with a Small Source Exemption under UAC R307-401-9. The DAQ has revoked the
above-referenced AO effective as of the date of this letter.

In December of 2021, the source underwent an undocumented ownership change from Metalcraft
Technologies INV., LLC to Align Precision - Cedar City LLC. The ownership change is reflected in this
letter, and documentation of this change has been included in the source file.

As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the
invoice.

If you have any questions, please contact Lucia Mason who can be reached at [phone].

Sincerely,
{{$s }}

Bryce C. Bird
Director

BCB:LM:jg

cc: EPA Region 8
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

January 15, 2025
. .... '
.
fa --I
I ;
11 II! I
DEPARTMFYT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Michael 0 . Leavin
Glwcmor
Dianne R. Nielson. Ph .D.
Exccu11 ve Director
Ursula Kramer
Dircc1or
July 6, 2000
Susie Barney
I ~ ~ I
150 North 1950 West
P.O. Box 1~820
Salt Lake City. Utah 841 14-4820
(80 I) 536-4000 Voice
(80 I) 536-4099 Fax
(801) 536--4414 T.D.D.
Web: www.deq.state.ut.us
Environmental Engineer
Metalcraft Technologies, Inc .
498 North 2774 West
Cedar City, UT 84720
Dear Ms. Barney:
DAQE-412-00
Re: Approval Order for Addition of Two Passivation Tanks and Removal of Chromic Acid Anodize
Tank, Iron County, CDS-B, ATT. HAPs
The attached document is an Approval Order fo r the above-referenced project.
Future correspondence on this Approval Order should include the engineer's name as well as the DAQE
number as shown on the upper right-hand comer of this letter. Please direct any technical questions you
may have on this project to Mr. Jon Black. He may be reached at [phone].
Sincerely,
Ursula Kramer, Executive Secretary
Utah Air Quality Board
UK:JB:re
cc: Southwest Utah Public Health Department
DAQ-2000-004042
-
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
APPROVAL ORDER FOR ADDITION OF TWO
PASSIVATION TANKS AND REMOVAL OF CHROMIC
ACID ANODIZE TANK
Prepared By: Jon Black, Engineer
[phone]
APPROVAL NUMBER
DAQE-412-00
Date: July 6, 2000
Source Contact
Metalcraft Technologies
Susie Barney
[phone]
Ursula Kramer
Executive Secretary
Utah Air Quality Board
Abstract
Metalcraft Technologies, Inc. (Metalcraft), has submitted a Notice of Intent (NOi), dated October 28,
1999, with additional information submitted on March 3, 2000, requesting a modification to the
Approval Order (AO) dated December 1, 1999, (DAQE-937-99), for their aircraft parts manufacturing
facility in Cedar City, Utah. The proposed modification is for the addition of two passivation tanks and
the removal of the chromic acid anodize tank. Metalcraft is located in Iron County which is an
attainment area of the National Ambient Air Quality Standards (NAAQS) for all pollutants. New
Source Performance Standards (NSPS) do not apply to this source. National Emission Standards for
Hazardous Air Pollutants (NESHAP) 40 CFR 63, Subpart N -National Emissions Standards for
Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing
Tanks will no longer apply to this source due to the removal of the chromic acid anodize tank. Title
V of the 1990 Clean Air Act will no longer apply to this source. The emissions will change as follows:
HAPs + 0.16 ton/year of nitric acid. Best Available Control Technology (BACT) will require the
passivation tanks to be equipped with lids that will remain closed at all times unless parts are being put
into or removed from them. It has been determined that the conditions of the Utah Administrative
Code R307-401-6 have been met and the Executive Secretary will issue an Approval Order. A JO-day
public comment period was completed and no comments were received.
The project has been evaluated and found to be consistent with the requirements of the Utah Air Quality
Rules (UAQR) and the Utah Air Conservation Act. This air quality AO authorizes the project with the
following conditions, and failure to comply with any of the conditions may constitute a violation of this
order.
General Conditions:
I. This Approval Order (AO) applies to the following company:
Site Office
Metalcraft Technologies, Inc.
498 North 2774 West
Cedar City, Utah 84720
Phone Number [phone]
Fax Number [phone]
The equipment listed in this AO shall be operated at the following location:
PLANT LOCATION:
498 North 2774 West, Cedar City, Utah, Iron County
Universal Transverse Mercator (UTM) Coordinate System:
4,172.9 kilometers Northing, 314.7 kilometers Easting, Zone 12
2. Definitions of terms, abbreviations, and references used in this AO conform to those used
in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of
Federal Regulations (40 CFR). These definitions take precedence, unless specifically
defined otherwise herein.
DAQE-412-00
Page 3
3. Metalcraft Technologies. Inc., shall install and operate the two passivation tanks and shall
conduct its operations of the aircraft parts manufacturing facility in accordance with the
terms and conditions of this AO, which was written pursuant to Metalcraft's Notice of
Intent submitted to the Division of Air Quality (DAQ) on October 28, 1999 and
additional information submitted to the DAQ on March 3, 2000.
4. This AO shall replace the AO dated December 1, 1999 (DAQE-937-99).
5. The approved installations shall consist of the following equipment or equivalent*:
A. Natural Gas Curing Oven
Design Capacity: 700,000 BTU/hr
B. Natural Gas Paint Bum-Off Oven
Design Capacity: 800,000 BTU/hr
C. Natural Gas Treatment Oven #1
Design Capacity: 3,400,000 BTU/hr
D. Natural Gas Treatment Oven #2
Design Capacity: 3,200,000 BTU/hr
E. Seven Paint Booths with particulate filters
F. Two Alodine Lines
G. One Titanium Etching Line
H. One Anodizing Line (including a sulfuric acid tank, and a sulfuric boric acid
tank)
I. Water Treatment System (including seven holding tanks, three purification tanks,
a clarifier, and a filter press).
J. One Sunstrand Parts Maker (with 2,200 acfm filter collection system)
K. Two Natural Gas Air Make-up Heaters
L.
Design Capacity: 5,000,000 BTU/hr each
Space Heaters
Design Capacity: 350,000 BTU/hr each
M. Passivation Tank (225 gallon) *
Tank Dimensions: 47"x42"x27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz per gallon
Evaporation Rate: 3%
N. Passivation Tank (l 00 gallon) *
DAQE-412-00
Page'4
Tank Dimensions: 36"x28"x29" (assuming 4" freeboard)
Nitric Acid Concentration: 32-57 oz per gallon
Evaporation Rate: 3%
* Equivalency shall be determined by the Executive Secretary.
Any future changes or modifications to the equipment and processes approved by this AO
that could affect the emissions covered by this AO must be approved in accordance with
R307-401-1, UAC.
6. Metalcraft shall notify the Executive Secretary in writing when the installation of the
equipment listed in Condition #5.M & 5.N has been completed and is operational, as an
initial compliance inspection is required. To insure proper credit when notifying the
Executive Secretary, send your correspondence to the Executive Secretary, attn:
Compliance Section.
If installation has not been completed within eighteen months from the date of this AO,
the Executive Secretary shall be notified in writing on the status of the installation. At
that time, the Executive Secretary shall require documentation of the continuous
installation of the operation and may revoke the AO in accordance with R307-401-11,
UAC.
Limitations and Tests Procedures
7. Visible emissions from the following emission points shall not exceed the following
values:
A. All paint booths exhaust stacks -5% opacity
B. Passivation tank exhaust stack -5% opacity
C. All natural gas combustion stacks - l 0% opacity
D. All other points -20% opacity
Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and
intermittent sources shall use procedures similar to Method 9, but the requirement for
observations to be made at 15-second intervals over a six-minute period shall not apply.
Any time-interval with no visible emissions shall not be included.
8. The consumption limits of the following materials shall not be exceeded without prior
approval in accordance with R307-401 , UAC:
A.
B.
C.
D.
Alodine 1200S or equivalent* -
Sodium Chromate -
Hydrofluoric Acid -
Nova Coat 1100 or equivalent* -
a5 pounds per romni: 12-montb period.
~ pounds per rollini: 12-montb period.
ill &;allons per rollini: 12-month
~
ill i:allons per rollin~ 12-montb
~
DAQE-412-00
Page 5
E. Acidic Chromated Deoxidizer -ill pou nds per rollio~ I 2-month
pmod..
Records of consumption shall be kept for all periods when the plant is in operation. The
consumption shall be determined by sales invoices or by any other method as acceptable
to the Executive Secretary or representatives of the Executive Secretary. Records of
consumption, shall be made avai lable to the Executive Secretary or representatives of the
Executive Secretary upon request.
9. The owner/operator shall use only natural gas as fuel. If any other fuel is to be used, an
AO shall be required in accordance with R307-401 , UAC.
Volatile or,mnic Compound <VOC) and Hazardous Air Pollutants <HAPs} Limitations
10. The paint spray booths shall be equipped with sets of paint arrestor particulate filters. or
equivalent, to control particulate emissions. All air exiting the booth shall pass through
this control system before being vented to the atmosphere (outside building/operation).
Equivalency determinations, when requested by the owner/operator, shall be submitted
to the Executive Secretary for approval.
11. The plant-wide emissions of VOCs and HAPs from the paint booths, alodine lines,
titanium etching line, anodizing line and associated operations shall not exceed:
14.43 tons per rolling 12-month period for voes
40.00 pounds per rolling 12-month period for chromium compounds
627.42 pounds per rolling 12-month period for ethyl benzene
1,222.00 pounds per rolling 12-month period for ethylene glycol
6.41 pounds per rolling 12-month period for hydrofluoric acid
0.22 pounds per rolling 12-rnonth period for lead
1,721.44 pounds per rolling 12-month period for methyl ethyl ketone
1,547.30 pounds per rolling 12-month period for methyl isobutyl ketone
112.38 pounds per rolling 12-month period for methyl amul keytone
0,12 pounds per rolling 12-month period for nickel oxide
319.92 pounds per rolling 12-month period for nitric acid
6.75 pounds per rollim~ 12-month period fo r potassium ferricyanide
155.30 pounds per rolling 12-month period for toluene
555.50 pounds per rolling 12-month period for triethylamine
1,377.00 pounds per rolling 12-month period for Xylene
3.85 tons total per rolling 12-month period for all HAPs combined
This value shall not be exceeded without prior approval, in accordance wi th R307-40 I,
UAC. Compliance with each 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.
•
DAQE-412-00
Page 6
The plant-wide emissions of voes and HAPs emitted to the atmosphere shall be
determined by maintaining a record of voe potential and HAP potential contained in
materials used each month. The record shall include the following data for each item
used:
A. Name of the voe and HAPs emitting material, such as: paint, adhesive, solvent.
thinner, reducers, chemical compounds, isocyanates, etc.
B. The weight and use location (name of paint booth or plant facility) of the voe
potential and HAP potential of the material(s) listed in A, in pounds per gallon.
e. Percent by weight of all voe potential and HAP potential for each individual
material listed in A. The percent by weight of the voe and HAP potentials can
be obtained from the manufacturers' MSDSs. The owner/operator can obtain
MSDS data from the manufacturers of the materials and retain the information
on-site.
D. Amount and location of materials containing voes and HAPs used on a monthly
basis and summed for every location and for the entire plant each month.
E. To calculate the above potentials contained in the material listed in D, use the
following procedure:
F.
VOC or HAPs =%Volatile by Wejght x [Density (lb..)] x Gal Consumed x J.Jon...
( 100) (gal) 2000 lb
The amount of voe content potential (potential air emissions) and HAP
potential (potential air emissions) in pounds contained in materials deposited as
solid or hazardous waste for the month shall be quantified and subtracted from
the quantities calculated above. This is done to allow quantification by the
source of the total voes and HAPs emissions. (The assumption is that all the
two above-potentials of the materials applied to a product evaporate and are
therefore considered emissions).
G. Records of consumption of voes and HAPs shall be kept for all periods when
the plant is in operation. Records of consumption shall be made available to the
Executive Secretary or Executive Secretary's representative upon request, and
the records shall include the two-year period prior to the date of the request.
Records & Miscellaneous
12. 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 Approval Order 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 Executive Secretary which may
DAQE-412-00
Page 7
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. and the records shall
be maintained for a period of two years. Maintenance records shall be made available to
the Executive Secretary or Executive Secretary's representative upon request, and the
records shall include the two-year period prior to the date of the request.
13. The owner/operator shall comply with R307-107, UAC. This rule addresses unavoidable
breakdown reporting requirements. The full text of U AC R307-107 General
Requirements. Unavoidable Breakdown, is included as Appendix A. However, to be in
compliance, this facility must operate in accordance with the most current version of the
UAC, R307-107.
All records referenced in this AO which are required to be kept by the owner/operator, shall be made
available to the Executive Secretary or Executive Secretary's representative upon request. and the records
shall include the two-year period prior to the date of the request. All records shall be kept for a period of
two years. A summary of those records that are required as part of this Approval Order is included herein.
This summary shall not be considered an additional requirement, but is included for informational
purposes only. The condition that requires that these records be kept as part of the compliance with this
AO is listed following the individual record. Examples of records to be kept at this source shall include
the following as applicable:
Consumption
VOC and/or HAPs emission records
Maintenance records
Upset, breakdown episodes
Condition number 8
Condition number 11
Condition number 12
Condition number 13
The list above may not be a complete list of all records that are required to be kept by Metalcraft
Technologies, Inc. For a complete list of required records check all AO conditions, and all
applicable Federal regulations such as NSPS, NESHAPS, and MACT standards that apply to this
source.
Any future modifications to the equipment approved by this order must also be approved in accordance
with R307-401, UAC.
The Executive Secretary shall be notified in writing if the company is sold or changes its name.
Under R307-150-l, UAC, the Executive Secretary may require a source to submit an emission inventory
for any full or partial year on reasonable notice.
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.
A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting
the Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of Intent
(NOi) guide, and other air quality documents and forms may also be obtained on the Internet at the
following web site: http://www.eq.state.ut.us/eqair/aq_home.htm.
DAQE-412-00
Page 8
Annual emissions for this source (the entire plant) are currently calculated at the following values:
Pollutant Tons/yr
A. PMIO ................................ 0.48
B. S01 ...............•.•••.•.••••••.•• 1.00
C. NO, ................................ 2.40
D. CO ................................. 0.41
E. voe .............................. 14.43
F. HAPs
HAPs consist of the following amounts in Pounds/Year.
Chromium compounds . . . . . . . . . . . . 40.00
Ethyl benzene .................. 627.42
Ethylene glycol . . . . . . . . . . . . . . . . 1,222.00
Hydrofluoric Acid ................. 6.41
Lead ............................ 0.22
Methyl ethyl ketone ............. 1,721.44
Methyl isobutyl ketone .......... 1,547.30
Methyl amul keytone . . . . . . . . . . . . . 112.38
Nitric Acid . . . . . . . . . . . . . . . . . . . . . 319. 92
Nickel oxide . . . . . . . . . . . . . . . . . . . . . 0.12
Potassium ferricyanide .............. 6.75
Toluene . . . . . . . . . . . . . . . . . . . . . . . 155.30
Triethylamine . . . . . . . . . . . . . . . . . . 555.50
Xylene ....................... 1,377.00
The annual emission estimations above are for the purpose of determining the applicability of Prevention
of Significant Deterioration, nonattainment area, maintenance area, and Title V source requirements of
the UAC R307. They are not to be used for determining compliance.
Approved By:
Ursula Kramer, Executive Secretary
Utah Air Quality Board
DAQE-412-00
Page 9
R307. Environmental Quality, Air Quality.
Appendix A
UAC R307-107
R307-107. General Requirements: Unavoidable Breakdown.
R307-107-1. Application.
R307-107 applies to all regulated pollutants including those for which there are National Ambient Air Quality
Standards. Except as otherwise provided in R307-I07, emissions resulting from an unavoidable breakdown will not be deemed
a violation oi these regulations. If excess emissions are predictable. they must be authorized under the variance procedure in
R307-102-4. Breakdowns that are caused entirely or in part by poor maintenance. careless operation. or any other preventable
upset condition or preventable equipment breakdown shall not be considered unavoidable breakdown.
R307-107-2. Reporting.
A breakdown for any period longer than 2 hours must be reported to the executive secretary within 3 hours of the
beginning of the breakdown if reasonable. but in no case longer than 18 hours after the beginning of the breakdown. During
times other than normal office hours, breakdowns for any period longer than 2 hours shall be initially reported to the
Environmental Health Emergency Response Coordinator. Telephone [phone]. Within 7 calendar days of the beginning
of any breakdown of longer than 2 hours, a written report shall be submitted to the executive secretary which shall include the
cause and nature of the event. estimated quantity of pollutant (total and excess). time of emissions and steps taken to control the
emissions and to pre\'ent recurrence. The submittal of such information shall be used by the executive secretary in determining
whether a violation has occurred and/or the need of further enforcement action.
R307-107-3. Penalties.
Failure to comply with the reporting procedures of R307-107-2 will constitute a violation of these regulations.
R307-107-4. Procedures.
The owner or operator of an installation suffering an unavoidable breakdown shall assure that emission limitations
and visible emission limitations are exceeded for only as short a period of time as reasonable. The owner or operator shall take
all reasonable measures which may include but are not limited to the immediate curtailment of production. operations. or
activities at all installations of the source if necessary to limit the total aggregate emissions from the source to no greater than
the aggregate allowable emissions averaged over the periods provided in the source's approval orders or R307. In the event that
production. operations or activities cannot be curtailed so as to so limit the total aggregate emissions without jeopardizing
equipment or safety or measures taken would result in even greater excess emissions. the owner or operator of the source shall
use the most rapid. reasonable procedure to reduce emissions. The owner or operator of any installation subject to a SIP
emission limitation pursuant to these rules shall be deemed to have complied with the provisions of R307-107 if the emission
limitation has not been exceeded.
R307-107-S. Violation.
Failure to comply with curtailment actions required by R307-I07-4 will constitute a violation ofR307-107.
R307-107-6. Emissions Standards.
Other provisions of R307 may require more stringent controls than listed herein. in which case those requirements
must be met.
KEY: air pollution. breakdown*, excess emissions*
1998 19-2-104
j
r
Michael 0. l..eavin
Governor
Dianne R. Nielson, Ph.D.
Executive Director
Ursula Kramer
Director
May 19, 2000
Susie Barney
Stt .;e of Utah
DEPARTMENT OF ENVIRONMENT AL QUALITY
DIVISION OF AIR QUALITY
150 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
[phone] Voice
(80 I) 5 36-4099 Fax
(80 1)536-44l4T.D.D.
Web: www.deq.state.ut.us
Environmental Engineer
Metalcraft Technologies, Inc.
498 North 2774 West
Cedar City, UT 84720
Dear Ms. Barney:
DAQE-297-00
Re: Intent to Approve Addition of Two Passivation Tanks and Removal of Chromic Acid Anodize
Tank, Iron County, CDS-B, ATT, HAPs
The attached document is an Intent to Approve for the above-referenced project. The Approval Order will
only be issued following the Executive Secretary's evaluation and approval.
Future correspondence on this Intent to Approve should include the engineer's name as well as the DAQE
number as shown on the upper right-hand comer of this letter. Please direct any technical questions you
may have on this project to Mr. Jon Black. He may be reached at [phone].
Sincerely,
)/'?,, / ';/z,;~--
ynn R. Menlove, Manager
New Source Review Section
LRM:JB:re
cc: Southwest Utah Public Health Department ~
STATE OF UTAH
Department of Environmental Quality
Division of . · r Quality
INTENT TO APPROVE ADDITION OF TWO
PASSIVATION TANKS AND REMOVAL OF CHROMIC
ACID ANODIZE TANK
Prepared By: Jon Black, Engineer
[phone]
INTENT TO APPROVE NUMBER
DAQE-297-00
Date: May 19, 2000
Source Contact
Metalcraft Technologies
Susie Barney
( 435) 586-3871
Ursula Kramer
Executive Secretary
Utah Air Quality Board
Abstract
Meta/craft Technologies, Inc. (Meta/craft), has submitted a Notice of Intent (NOi), dated October 28,
1999, with additional information submitted on March 3, 2000, requesting a modification to the
Approval Order(AO) dated December 1, 1999, (DAQE-937-99),for their aircraft parts manufacturing
facility in Cedar City, Utah. The proposed modification is for the addition of two passivation tanks
and the removal of the chromic acid anodize tank. Meta/craft is located in Iron County which is an
attainment area of the National Ambient Air Quality Standards (NAAQS) for all pollutants. New
Source Performance Standards (NSPS) do not apply to this source. National Emission Standards for
Hazardous Air Pollutants (NESHAP) 40 CFR 63, Subpart N -National Emissions Standards for
Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing
Tanks will no longer apply to this source due to the removal of the chromic acid anodize tank. Title
V of the 1990 Clean Air Act will no longer apply to this source. The emissions will change as follows:
HAPs + 0.16 ton/year of nitric acid. Best Available Control Technology will require the passivation
tanks to be equipped with lids that will remain closed at all times unless parts are being put into or
removed from them. It has been determined that the conditions of the Utah Administrative Code
R307-401-6 have been met and the Executive Secretary intends to issue an Approval Order after a 1 O-
day public comment period is complete and the comments received are evaluated.
The Notice of Intent (NOD for the above-referenced project has been evaluated and has been found to
be consistent with the requirements of the Utah Air Quality Rules (UAQR) and the Utah Air
Conservation Act. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an Approval Order (AO) by the
Executive Secretary of the Utah Air Quality Board.
An NOi to issue an AO will be published in The Daily Spectrum on May 11, 2000. A IO-day period
following the publishing date will be allowed during which the proposal and evaluation of its impact on
air quality will be available for both you and the public to review and comment. If anyone so requests
within 15 days of publication of the notice, a hearing will be held. The hearing will be held as close as
practicable to the location of the source. Any comments received during the 10-day period and the
hearing, if held, will be evaluated.
Please review the proposed AO conditions during this period and make any comments you may have
before its closure. The proposed conditions of the AO may be changed as a result of the comments
received. Unless changed, the AO will be based upon the following conditions:
General Conditions:
1. This Approval Order (AO) applies to the following company:
Site Office
Metalcraft Technologies, Inc.
498 North 2774 West
Cedar City, Utah 84720
Phone Number [phone]
Fax Number [phone]
The equipment listed in this AO shall be operated at the following location:
DAQE-297-00
Page 3
PLANT LOCATION:
498 North 2774 West, Cedar City, Utah, Iron County
Universal Transverse Mercator (UTM) Coordinate System:
4,172.9 kilometers Northing, 314.7 kilometers Easting, Zone 12
2. Definitions of terms, abbreviations, and references used in this AO conform to those
used in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code
of Federal Regulations ( 40 CFR). These definitions take precedence, unless specifically
defined otherwise herein.
3. Metalcraft Technologies, Inc., shall install and operate the two passivation tanks and
shall conduct its operations of the aircraft parts manufacturing facility in accordance
with the terms and conditions of this AO, which was written pursuant to Metalcraft' s
Notice of Intent submitted to the Division of Air Quality (DAQ) on October 28, 1999
and additional information submitted to the DAQ on March 3, 2000.
4. This AO shall replace the AO dated December 1, 1999 (DAQE-937-99).
5. The approved installations shall consist of the following equipment or equivalent*:
A. Natural Gas Curing Oven
Design Capacity: 700,000 BTU/hr
B. Natural Gas Paint Bum-Off Oven
Design Capacity: 800,000 BTU/hr
C. Natural Gas Treatment Oven #1
Design Capacity: 3,400,000 BTU/hr
D. Natural Gas Treatment Oven #2
Design Capacity: 3,200,000 BTU/hr
E. Seven Paint Booths with particulate filters
F. Two Alodine Lines
G. One Titanium Etching Line
H. One Anodizing Line (including a sulfuric acid tank, and a sulfuric boric acid
tank)
I. Water Treatment System (including seven holding tanks, three purification
tanks, a clarifier, and a filter press).
J. One Sunstrand Parts Maker (with 2,200 acfm filter collection system)
DAQE-297-00
Page 4
K. Two Natural Gas Air Make-up Heaters
L.
Design Capacity: 5,000,000 BTU/hr each
Space Heaters
Design Capacity: 350,000 BTU/hr each
M. Passivation Tank (225 gallon)*
Tank Dimensions: 47"x42"x27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz per gallon
Evaporation Rate: 3%
N. Passivation Tank (100 gallon) *
Tank Dimensions: 36"x28"x29" (assuming 4" freeboard)
Nitric Acid Concentration: 32-57 oz per gallon
Evaporation Rate: 3%
* Equivalency shall be determined by the Executive Secretary.
Any future changes or modifications to the equipment and processes approved by this
AO that could affect the emissions covered by this AO must be approved in accordance
with R307-401-1, UAC.
6. Metalcraft shall notify the Executive Secretary in writing when the installation of the
equipment listed in Condition #5.M & 5.N has been completed and is operational, as an
initial compliance inspection is required. To insure proper credit when notifying the
Executive Secretary, send your correspondence to the Executive Secretary, attn:
Compliance Section.
If installation has not been completed within eighteen months from the date of this AO,
the Executive Secretary shall be notified in writing on the status of the installation. At
that time, the Executive Secretary shall require documentation of the continuous
installation of the operation and may revoke the AO in accordance with R307-401-11,
UAC.
Limitations and Tests Procedures
7. Visible emissions from the following emission points shall not exceed the following
values:
A. All paint booths exhaust stacks -5 % opacity
B. Passivation tank exhaust stack -5% opacity
C. All natural gas combustion stacks -10% opacity
D. All other points -20% opacity
Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and
intermittent sources shall use procedures similar to Method 9, but the requirement for
DAQE-297-00
Page 5
observations to be made at 15-second intervals over a six-minute period shall not apply.
Any time-interval with no visible emissions shall not be included.
8. The consumption limits of the following materials shall not be exceeded without prior
approval in accordance with R307-401, UAC:
A.
B.
C.
D.
E.
Alodine 1200S or equivalent* -
Sodium Chromate -
Hydrofluoric Acid -
Nova Coat 1100 or equivalent* -
Acidic Chromated Deoxidizer -
85 pounds per rolling 12-month period.
4 pounds per rolling 12-month period.
125 gallons per rolling 12-month
period.
135 gallons per rolling 12-month
period.
125 pounds per rolling 12-month
period.
Records of consumption shall be kept for all periods when the plant is in operation. The
consumption shall be determined by sales invoices or by any other method as acceptable
to the Executive Secretary or representatives of the Executive Secretary. Records of
consumption, shall be made available to the Executive Secretary or representatives of
the Executive Secretary upon request.
9. The owner/operator shall use only natural gas as fuel. If any other fuel is to be used, an
AO shall be required in accordance with R307-401, UAC.
Volatile Organic Compound (VOC) and Hazardous Air Pollutants (HAPs) Limitations
10. The paint spray booths shall be equipped with sets of paint arrestor particulate filters,
or equivalent, to control particulate emissions. All air exiting the booth shall pass
through this control system before being vented to the atmosphere ( outside
building/operation). Equivalency determinations, when requested by the
owner/operator, shall be submitted to the Executive Secretary for approval.
11. The plant-wide emissions of VOCs and HAPs from the paint booths, alodine lines,
titanium etching line, anodizing line and associated operations shall not exceed:
14.43 tons per rolling 12-month period for VOCs
40.00 pounds per rolling 12-month period for chromium compounds
627.42 pounds per rolling 12-month period for ethyl benzene
1,222.00 pounds per rolling 12-month period for ethylene glycol
6.41 pounds per rolling 12-month period for hydrofluoric acid
0.22 pounds per rolling 12-month period for lead
1,721.44 pounds per rolling 12-month period for methvl ethyl ketone
1,547.30 pounds per rolling 12-month period for methyl isobutyl ketone
112.38 pounds per rolling 12-month period for methvl amul kevtone
DAQE-297-00
Page 6
0.12 pounds per rolling 12-month period for nickel oxide
319.92 pounds per rolling 12-month period for nitric acid
6.75 pounds per rolling 12-month period for potassium ferricyanide
155.30 pounds per rolling 12-month period for toluene
555.50 pounds per rolling 12-month period for triethylamine
1,377.00 pounds per rolling 12-month period for Xylene
3.85 tons total per rolling 12-month period for all HAPs combined
This value shall not be exceeded without prior approval, in accordance with R307-401,
UAC. Compliance with each 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 plant-wide emissions of VOCs and HAPs emitted to the atmosphere shall be
determined by maintaining a record of VOC potential and HAP potential contained in
materials used each month. The record shall include the following data for each item
used:
A. Name of the VOC and HAPs emitting material, such as: paint, adhesive,
solvent, thinner, reducers, chemical compounds, isocyanates, etc.
B. The weight and use location (name of paint booth or plant facility) of the VOC
potential and HAP potential of the material(s) listed in A, in pounds per gallon.
C. Percent by weight of all VOC potential and HAP potential for each individual
material listed in A. The percent by weight of the VOC and HAP potentials can
be obtained from the manufacturers' MSDSs. The owner/operator can obtain
MSDS data from the manufacturers of the materials and retain the information
on-site.
D. Amount and location of materials containing VOCs and HAPs used on a
monthly basis and summed for every location and for the entire plant each
month.
E. To calculate the above potentials contained in the material listed in D, use the
following procedure:
VOC or HAPs =%Volatile by Weight x [Density (.Th..)] x Gal Consumed x ..l...!illL
(100) (gal) 2000 lb
F. The amount of VOC content potential (potential air emissions) and HAP
potential (potential air emissions) in pounds contained in materials deposited
as solid or hazardous waste for the month shall be quantified and subtracted
from the quantities calculated above. This is done to allow quantification by
the source of the total VOCs and HAPs emissions. (The assumption is that all
the two above-potentials of the materials applied to a product evaporate and are
therefore considered emissions).
DAQE-297-00
Page 7
G. Records of consumption of VOCs and HAPs shall be kept for all periods when
the plant is in operation. Records of consumption shall be made available to the
Executive Secretary or Executive Secretary's representative upon request, and
the records shall include the two-year period prior to the date of the request.
Records & Miscellaneous
12. 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 Approval Order 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 Executive Secretary 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, and the records shall
be maintained for a period of two years. Maintenance records shall be made available
to the Executive Secretary or Executive Secretary's representative upon request, and the
records shall include the two-year period prior to the date of the request.
13 . The owner/operator shall comply with R307-107, UAC. This rule addresses
unavoidable breakdown reporting requirements. The full text of UAC R307-107
General Requirements, Unavoidable Breakdown, is included as Appendix A. However,
to be in compliance, this facility must operate in accordance with the most current
version of the UAC, R307-107.
All records referenced in this AO which are required to be kept by the owner/operator, shall be made
available to the Executive Secretary or Executive Secretary's representative upon request, and the
records shall include the two-year period prior to the date of the request. All records shall be kept for
a period of two years. A summary of those records that are required as part of this Approval Order is
included herein. This summary shall not be considered an additional requirement, but is included for
informational purposes only. The condition that requires that these records be kept as part of the
compliance with this AO is listed following the individual record. Examples of records to be kept at this
source shall include the following as applicable:
Consumption
VOC and/or HAPs emission records
Maintenance records
Upset, breakdown episodes
Condition number 8
Condition number 11
Condition number 12
Condition number 13
The list above may not be a complete list of all records that are required to be kept by Metalcraft
Technologies, Inc. For a complete list of required records check all AO conditions, and all
applicable Federal regulations such as NSPS, NESHAPS, and MACT standards that apply to this
source.
DAQE-297-00
Page 8
Any future modifications to the equipment approved by this order must also be approved in accordance
with R307-401 , UAC.
The Executive Secretary shall be notified in writing if the company is sold or changes its name.
Under R307-150-1, UAC, the Executive Secretary may require a source to submit an emission inventory
for any full or partial year on reasonable notice.
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.
A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting
the Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of
Intent (NOI) guide, and other air quality documents and forms may also be obtained on the Internet at
the following web site: http://www.eq.state.ut.us/eqair/aq_home.htm
Annual emissions for this source (the entire plant) are currently calculated at the following values:
Pollutant Tons/yr
A. PM10 ................................ 0.48
B. S02 ...••....••••...............•.•. 1.00
C. NO, ................................ 2.40
D. CO ................................. 0.41
E. voe .............................. 14.43
F. HAPs
HAPs consist of the following amounts in Pounds/Year.
Chromium compounds . . . . . . . . . . . 40.00
Ethyl benzene . . . . . . . . . . . . . . . . 627.42
Ethylene glycol .............. 1,222.00
Hydrofluoric Acid ............... 6.41
Lead .......................... 0.22
Methyl ethyl ketone ........... 1,721.44
Methyl isobutyl ketone ........ 1,547.30
Methyl amul keytone . . . . . . . . . . . 112.38
Nitric Acid ................... 319.92
Nickel oxide . . . . . . . . . . . . . . . . . . . . 0 .12
Potassium ferricyanide . . . . . . . . . . . 6.75
Toluene . . . . . . . . . . . . . . . . . . . . . 155.30
Triethylamine ................ 555.50
Xylene ..................... 1,377.00
The annual emission estimations above are for the purpose of determining the applicability of Prevention
of Significant Deterioration, nonattainment area, maintenance area, and Title V source requirements of
the UAC R307 . They are not to be used for determining compliance.
DAQE-297-00
Page 9
The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred
in the issuance of an AO. An invoice will follow . You may pay this fee prior to the end of the comment
period. If there are comments or additional fees, you will be notified.
Sincerely,
,.... ynnR. Menlove, Manager
New Source Review Section
DAQE-297-00
Page 10
R307. Environmental Quality, Air Quality.
Appendix A
UAC R307-107
R307-107. General Requirements: Unavoidable Breakdown.
R307-107-1. Application.
R307-I 07 applies to all regulated pollutants including those for which there are National Ambient Air Quality
Standards. Except as otherwise provided in R307-I 07, emissions resulting from an unavoidable breakdown will not be deemed
a violation of these regulations. If excess emissions are predictable, they must be authorized under the variance procedure in
R307-l 02-4. Breakdowns that are caused entirely or in part by poor maintenance, careless operation, or any other preventable
uRset condition or preventable equipment breakdown shall not be considered unavoidable breakdown.
R307-107-2. Reporting.
A breakdown for any period longer than 2 hours must be reported to the executive secretary within 3 hours of the
beginning of the breakdown if reasonable, but in no case longer than 18 hours after the beginning of the breakdown. During
times other than normal office hours, breakdowns for any period longer than 2 hours shall be initially reported to the
Environmental Health Emergency Response Coordinator, Telephone [phone]. Within 7 calendar days of the beginning
of any breakdown of longer than 2 hours, a written report shall be submitted to the executive secretary which shall include the
cause and nature of the event, estimated quantity of pollutant (total and excess), time of emissions and steps taken to control the
emissions and to prevent recurrence. The submittal of such information shall be used by the executive secretary in determining
whether a violation has occurred and/or the need of further enforcement action.
R307-107-3. Penalties.
Failure to comply with the reporting procedures of R307-107-2 will constitute a violation of these regulations.
R307-107-4. Procedures.
The owner or operator of an installation suffering an unavoidable breakdown shall assure that emission limitations
and visible emission limitations are exceeded for only as short a period of time as reasonable. The owner or operator shall take
all reasonable measures which may include but are not limited to the immediate curtailment of production, operations, or
activities at all installations of the source if necessary to limit the total aggregate emissions from the source to no greater than
the aggregate allowable emissions averaged over the periods provided in the source's approval orders or R307. In the event that
production, operations or activities cannot be curtailed so as to so limit the total aggregate emissions without jeopardizing
equipment or safety or measures taken would result in even greater excess emissions, the owner or operator of the source shall
use the most rapid, reasonable procedure to reduce emissions. The owner or operator of any installation subject to a SIP
emission limitation pursuant to these rules shall be deemed to have complied with the provisions of R307-l 07 if the emission
limitation has not been exceeded.
R307-107-5. Violation.
Failure to comply with curtailment actions required by R307-107-4 will constitute a violation of R307-107.
R307-107-6. Emissions Standards.
Other provisions of R307 may require more stringent controls than listed herein, in which case those requirements
must be met.
KEY: air pollution, breakdown*, excess emissions*
1998 19-2-104
·-
Michael 0 . Leavitt
Governor
Dianne R. Nielson, Ph.D.
Executive Director
Ursula Kramer
Director
May 4, 2000
Stt~e of Utah
DEPARTMENT OF ENVIRONMENT AL QUALITY
DIVISION OF AIR QUALITY
150 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
[phone] Voice
[phone] Fax
[phone] T.D.D.
Web: www.deq.state.ut.us
The Daily Spectrum
Legal Advertising Department
PO Box 40
St. George, UT 84770
RE: Legal Notice of Intent to Approve
FILE COPY
DAQE-298-00
This letter will confirm the authorization to publish the attached NOTICE in the The Daily Spectrum on May
11, 2000.
Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality,
Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820.
Sincerely,
&:1N ✓f2. ,.
RffleEmery ~1
Office Technician
Utah Division of Air Quality
Enclosure
cc: Iron County
Iron Co Courthouse
PO Box429
68 S lOOE
Parowan UT 84761
Five County Association of Governments
906 N 1400W
PO Box 1550
St. George UT 84 771
DAQE-298-00
Page 2
NOTICE
The following notice of intent to construct, submitted in accordance with Section R307-401-1, Utah Air
Quality Rules, has been received for consideration by the Executive Secretary, Utah Air Quality Board:
Metalcraft Technologies
Location: 597 North 1500 West, Cedar City, UT 84720
Project Description: Metalcraft Technologies, Inc. (Metalcraft), has submitted a Notice of
Intent (NOI), dated October 28, 1999, with additional information submitted on March 3,
2000, requesting a modification to the Approval Order (AO) dated December 1, 1999
(DAQE-937-99), for their aircraft parts manufacturing facility in Cedar City, Utah. The
proposed modification is for the addition of two passivation tanks and the removal of the
chromic acid anodize tank. Metalcraft is located in Iron County which is an attainment area
of the National Ambient Air Quality Standards (NAAQS) for all pollutants. New Source
Performance Standards (NSPS) do not apply to this source. National Emission Standards for
Hazardous Air Pollutants (NESHAP) 40 CFR 63, Subpart N -National Emissions Standards
for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium
Anodizing Tanks will not longer apply to this source due to the removal of the chromic acid
anodize tank. Title V of the 1990 Clean Air Act will no longer apply to this source. It has
been determined that the conditions of the Utah Administrative Code R307-401-6 have been
met and the Executive Secretary intends to issue an Approval Order after a 10-day public
comment period is complete and the comments received are evaluated.
The emissions in tons per year will change as follows: HAPs + 0.16 tons/yr of nitric acid.
The engineering evaluation and air quality impact analysis have been completed and no new violations of
National Ambient Air Quality Standards or Prevention of Significant Deterioration Increments will occur. It
is the intent of the Executive Secretary to approve the construction project.
The construction proposal and estimate of the effect on local air quality are available for public inspection and
comment at the Utah Division of Air Quality, Department of Environmental Quality, 150 North 1950 West,
Salt Lake City, Utah 84114-4820. There will be a 10-day comment period held. Written comments received
by the Division, at the same address on or before May 21, 2000, will be considered in makin2 the final
decision on the approval/disapproval of the proposed construction.
If anyone so requests to the Executive Secretary at the Division in writing, within 15 days of publication of
the Notice, a hearing will be held to explain the project and technical rationale for the proposed action. The
hearing will be scheduled as close as practicable to the proposed project location. Comments obtained during
the hearing will be evaluated and considered by the Executive Secretary before making a final decision on the
approval/disapproval of the project.
Date of Notice: May 11, 2000
he Spectrum
A Marketing and Communications Company
, cation to the .t\pproval Order (AO) , Executive Secreti}.ry at the Division
dated D~~ember 1, ·i9~9 (DAQE-. ,in writing,' witlp.n 16 days .of,publi..: )F
937-99), for their aircraft parts man-. catiop._'of the Notice,' a hearing_ will .
ufacturing facility in ·Cedar City, be held· to explain th~ project' arid·
·Utah, The'. proposed modification· is ~linical ratio~ale !<>r the_ p~posed ff ION
for the addition-9f two pas§livation .. actio~ The hearing will be'scheduled."
. tanks iui,a. the· removal· of the . as · close ·1µ1· practicable to the '.pro-· ~=aft\:\~~an:t:: 6~=. ~=Jr~::nJ°::tt!~n~(JT AH SS.
whi~:is· a:n.·:attainmeilt:an,la'of~e~ evalua~d and considered ·by -~.e ASHINGTON
Nat1ona1·,.Ambient : Air, ,,Qwility: Executive Sette~ before making
Standar'ds (N.AAQS) for; J I1 pcillu-t a ·finai 'decision o'n. the app~oval/dis-·
tants:)i~w-s~urce -P;rfp;~anc~ · approvafofuie j,roj~.--. · . " ... \g duly sworn
Standardi"_iN'SPS) do,not .. apply-tq ·, · · • · , _ '
• this , ~ Natiohal "Emis!(ron Date of Notice: May 11;2oop -_, · /S that she is
Standards fol' . hazardous ' Air -, . . t t· t
Pollutaiits (NESHAP) 40 °CFR 63; ' ... _Pub#L,'J461 .pu"blished qc . resen a 1ve, a
Subpart-"N Nati_on~I _ Emi_ss~ons ·-1 .... : : ~ _ ~.Y l\,:~;;-·. :> :, • -~,:.:lr published at
Standards for Chrorm';!ID-~rmss1ons ;.Ji?. -~ ~es~ w· h' t C from ' hard and ·' Decorative '-'•• '-='t::urge, as tng on OUnty,
Chro~mn _El~ctrop_l~ting.·. and./ State of Utah, also distributed in
Chromium Anodizing 'J_'anks·will_not .
· Ionger-app1y to thii!.sop.rce aue to -Iron County, and that the notice:
th~ .removal. of.~-ctrr(!I!iiC, 51!-Cid 1 anodize· tank.· Title•.-v ~of-the -1990
qean~~will Mfopg~)t~.ftf
this source;· it .naa beeri<de~
that the1°:i;onfiltioQ's: 'o"'f :Cth~ ·_-Utab.., <_
Adminisfa:a\iie--:--Code :-xaut~0l-6 -
t.have-~efi-!inet" 'and the· Ex,ecu~e ,, seere~ ·mt«.JJM ,::,fu' "risay•/~, .
Approv~,:C)fdet after\~t~ ·~_:,
li_tj ;~ is complea ii.n:d,
the. comnients received-1lli'evaltfat--·~·:·;~-~:~~:~¢-( ~~.~·r·:,~~-.v;T :
-i_J ..-;•~--• --~. . j.
f The ep:,iesiou-~ -tons -~'y _. · -:'
[ __ chanp ~,~.rollpw,s; HAPs,':if~(&:-··
I to~ of':ffitrlc~acid. . . . ,":" c· ,•:( _: ~---.. -~. "-,: . . . ~ ;1:.:~ ""'· .~'•·'
'Fhe engineering evaluation· aitd-air.:~•
quality ~pact; analysis. h~ve~~.f
compJ.etecfatid no ·n~w· fiolatiiiae ot•·
N atfona:t'"•X:mbient' AW ·-Qiilility
·: Staiidardi ; ; .or. 'Preveafic,n ':: of
Signii$.cant · _ . . DetetiorJtion :..·
-Increnieiits'··wni ~-~--Jt Je. the i ,= ~ .-. ~ · mtent pf the' Executive &cretary to
, ~~1:IC~ -; < ,_ . approve the:t:OllBtrp.ction\pr:oject '.
or ,.. .. :·• • J t ~ -, -~t .,.;<s. ~ •• -• \_ :. ~11:..a~ ·..,, .. · .. ·.,.,,_ ~:,..:,,.i·.:
,. The following notice ofin~nt to ~n-Tl;t!:l coll8ti-aciion proposal'!lrid-:--esti-
. struct, submitted in accordill).ce with ·_ niate of'the-,ffect on local ·3ir,quali-.
f
Section R307401-1, Utah Air ty ate ·available for public-;inspe<;ti.on
9ua~ty,R~~s,.has·been r~<;e!~e4"/or: -and: c~tnm. 'ent _at th~Utahµ)ivision .
consideration. by_ _the . Ex-ci;_utive •· of . Air Quality, , Department of
'--------·Secret,µy. Utah Air Q{i$1itf~' ;·,_ Environment.al: Qiiiiliiy;;-,100-'Norlh
r,M~tal6;atl Thcl:iri<ilogies' -~il :: ](" 1950 ;:W!ls( Sl!lt. Lak¢ · qicy, .Utah ;: · ~; .. • :,:_;_ " \ -r\::: "':'.'.. ,.' 84114-4320~::will lie:a#cfay
Location: ··597 North 15~J Vest, · comment ~oo hel4: \Yn.!~11 <:9m~
;·Cedar City/UT 84 720 · -. rilents, ~ceived by. the Division,. at
:. Project ~:~p:i~n: ,::~~~·-~~=::~:~=!:
:~-Teclm!)logies,"'.Ih~; (Metal.:,<faft)_;1w · irig.; ~, --..i_'..,deei~i~~·~~
•~submitted. a N~tice of-Intent -<NQi), -· -appr~ial7dfsapproval ';oC~ the,'.:,Pro-
r .;'.dated October·2s;·1999; with":itddi-posedeonstniclion:"' /\-:'. :· '•"'.
:· tional information submitted on I· -· ·., ·"'" \. • .•, · · ~ ~ ;., . ·,•
. Mar.ch 3, 2QO_0, requesting ·a modifi:---If anyone so requests __ i;o ·~the
_.
'84770
' '
-65
LLlJr.K d 'i Y'Vfr!Lt::-
2071 N. Main St #2 Cedar City, UT 84720
Office [phone] FAX [phone]
PUB#: L3461
is a true copy of which is hereto
attached, was published in its issue
dated the 11 day
of MAY 2000 ----------and was published again in the
issues of said newspaper dated:
for a total of 1
Subscribed and sworn before me
this ...-+-+---day of
AT WASHINGTON COUNTY
NOTAT1Y PUBUC
SHAWrU. BROOKS
275 E. St. George Blvd.
St. Geor;ie, UT 84TT0
My Comn,l:;sion Expires
March 111th. 2001
STAT£ C'.> L'T,\ ff
~---------r ~-------------"' -,------------
Advert i Sing
Receipt
#1287 State of Utah Q
State of Utah/Dept of Environ. Qual ~; 1 , · .U
Utah Solid & Hazardous Waste Contro ~Vv
P.O. Box 144840
Salt Lake City, UT 84114-4840
Ad taker: 66 Salesperson: Classification:
Description Start Stop
01 The Spectrum 05/11/00 05/11/00
Payment Reference:
NOTICE
Cust#:
Ad#:
Phone:
Date:
2025
The Spectrum
275 E St. George Blvd.
St. George, UT 84770
Phone: [phone]
Fax: [phone]
03100958 000
04517624
(801 )538-6170
05/11/00
Ins. Cost/Day Surcharges
130,00
Total:
Tax:
Net:
Total
130.00
130.00
0.00
130.00
The following notice of intent to construct, submitted in accordance with Section R307-401-1 , Utah Air Prepaid: 0.00
Quality Rules, has been received for consideration by the Executive Secretary, Utah Air Quality (
Board: 130.00 )
Metalcraft Technologies Total Due . ------------
Location: 597 North 1500 West, Cedar City, UT 84720
Project Description: Metalcraft Technologies, Inc. (Metal craft}, has submitted a Notice of Intent (NOi),
dated October 28, 1999, with additional information submitted on March 3, 2000, requesting a
modification to the Approval Order (AO) dated December 1, 1999 (DAQE-937-99), for their aircraft
parts manufacturing facility in Cedar City, Utah. The proposed modification is for the addition of two
passivation tanks and the removal of the chromic acid anodize tank Metalcraft is located in Iron
County which is an attainment area of the National Ambient Air Quality Standards (NMQS) for all
pollutants. New Source Performance Standards (NSPS) do not apply to this source. National
6 -1tJ-oV RECEIVED .,_...._!
OAG APP ACCT JUN 1 '. ·i)• l Lv ..
Air Qua!i>;
RECEIVED RECEIVED
JUN 1 3 2'DJ JUN I ' 2fW
Air Quality -Teri Air Quality -Teri
FAX COVER SHEET
UTAH DIVISION OF AIR QUALITY
(NEW SOURCE REVIEW SECTION)
150 North 1950 West
P. 0 . Box 144820
Salt Lake City, Utah 84114-4820
FAX: [phone]
CONFIRMATION: [phone]
FROM:
PHONE:
DATE:
Renae Emery
Office Technician
[phone]
May 5, 2000
AGENCY/FIRM: The Daily Spectrum
ATTENTION: Legal Advertising Department
PHONE: [phone]
FAX NUMBER: [phone]
E-MAIL: [e-mail]
SUBJECT: Metalcraft Technologies
COMMENTS: Hard Copy to Follow
Number of Pages to Follow: _2 _
Date Logged: 05/05/2000
Date Faxed: 05/05/2000
Time: 10:00 am
Initials: RE
NEWS
**************************************************************************************************** 1 . . P, 01 * * TRANSACT I ON REPORT * * -------MAY-05-2000 FRI 09: 12 AM * * * * DATE START RECEIVER TX TIME PAGES TYPE NOTE M# DP* *--------------------------------* * MAY-05 08:53 AM 914356746264 1' 12" 3 SEND OK 748 *
* * *****************************************************************~**********************************
11-4 -99; 3:20P M;
· :\" /:t M.etalcraft
f, t t TECHNOLOGIES, INC.
498 North, 2774 West. C"dar Cily. UT 84720 • [phone] • FAX [phone]
597 North. ·1500 West. Cedar City, UT 84720 • (435) 586-387 1 • FAX [phone]
10840 Mulbcny Ave. ~ontana . CA 92337 • [phone] • FAX [phone]
215 Wcsr. 100 South, Salt 1.ake City, \JT 84101 • [phone] • FAX [phone]
www.melalcri::lft.nel
October 28. 1999
Mr. Jon Black
Ucah Di vision of Air Quality
Post Office Box 144820
Salt Lake City, Utah 84114-4820
Dear.Mr. Black,
;435 586 9442
RECEIVED
NOVO It 1999
Air Quality
Metalcraft Technologies, Inc. will be adding an additional capability for Passivation of stainless steel in our
headquarters facility located at 498 North 2774 West Cedar City. Utah 84720. This capability will involve
the addition of two JOO-gallon tanks with the following characteristics:
Tank I :
Tank Dimensions: 47"x 42"Jl 27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz: per gallon
Annual Usage: 3,864 lb
Evaporation Rate: 3%
Emission Rate: I 16 lb/yr
Tank 2:
Tank Dimensions: 36"x 28"x 29" (assuming 4" freehoard)
Nitric Acid Concentration: 32-57 oz per gallon
Annual Usage: 1,392 lb
Evaporation Rate: 3%
Emission Rate: 41.7 lh/yr
NITRIC ACID EMISSION INCREASES:
Our original NOi submitted on June 4, 1997 reported a total emission rate of 108.9 lb/yr for nitric acid.
he additional P.as:sin 10n anlcs wit! increase I.ti tn1al nitci ac,i:I emissio ns to _66.61-ti yr. The Passi vat.ion
tanks will be equipped with lids that will remain closed al all times unless parts are being put into or
removed from them. Emissions from the Passivation tanks will be collected and vented through a single
roof stack. Emissions will be drawn from each tank at a rate sufficient to prevent the build up of nitric acid
inside the building. The flow through the exhausl stack will be 20,000 acfm.
Please contact Susie Barney, [phone] for questions regarding this matter.
Sincerely,
Susie Barney
En vironmental Engineer
# 1 /
A erospa ce 0 Screw Machined Corn p o ne n ts ~ c;roun d Tr a nsportation
UTAH DIVISION OF AIR QUALITY
MODIFIED SOURCE PLAN REVIEW
Susie Barney
Environmental Engineer
Metalcraft Technologies, Inc.
498 North 2774 West
Cedar City, Utah 84720
RE:
REVIEW ENGINEER:
DATE:
NOTICE OF INTENT SUBMITTED:
PLANT CONTACT:
PHONE NUMBER:
FAX NUMBER:
PLANT LOCATION:
Project fee code: N0270-006
Addition of Two (2) Passivation Tanks and Removal of Chromic
Acid Anodize Tank
Iron County, CDS B; ATT; HAPs
Jon L. Black
March 6, 2000
October 28, 1999
Susie Barney
[phone]
[phone]
498 North 2774 West, Cedar City, Utah, Iron County
UTM COORDINATES:
4,172.9 km. Northing, 314.7 km. Easting, Zone 12
F:\AQ\ENGINEER\IBLACK\ WP\R VW _00\MET AL.RVW
APPROVALS:
Peer Engineer -------,,L2....,,,]_j""--"tJ""""------P..,,__,,_1/ __ /0~0_t:7_CJ ___ _
7 J. Tim Blanchard 7
DAQ requests that a company/corporation official read the attached draft/proposed Plan Review with
Recommended Approval Order Conditions. If this person does not understand or does not agree with the
conditions, the PLAN REVIEW ENGINEER -TECHNICIAN should be contacted within five days after
receipt of the Plan Review. Special attention needs to be addressed to the Recommended AO Conditions
because they will be recommended for the final AO. If this person understands and the
company/corporation agrees with the Plan Review or Recommended AO Conditions, this person should
sign below and return (can use FAX# [phone]) within 10 days after receipt of the conditions. If the
Plan Review Engineer is not contacted within 10 days, the Plan Review Engineer shall assume that the
Company/Corporation official agrees with this Plan Review and will process the Plan Review towards final
approval. NOTE: The Approval Order will not be issued until this signed sheet is returned and the
review fees are paid.
Thank You
Applicant Contact ___________________________ _
(Signature & Date)
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 1
TYPE OF IMPACT AREA
Attainment Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes
Nonattainment Area
PM10 •••.•............................................... No
SO2 .••.••..............••..••.•••••••.............•..••. No
CO ...................................................... No
Maintenance Area
Ozone ................................................... No
NSPS ........................................................ No
NESHAP ....................................................... No
Hazardous Air Pollutants (HAPs) ................................... Yes
Chromium Compounds, Nitric Acid, Ethyl Benzene, Ethylene Glycol, Lead,
Hydrofluoric Acid, Methyl Ethyl Ketone, Nickel Oxide, Toluene, Xylene
Hazardous Air Pollutants Major Source ................................ No
[> IO tpy of any one Hazardous Air Pollutant (HAP) or > 25 tpy of any combination of HAPs]
New Major Source ................................................ No
Major Modification ............................................... No
PSD Permit ...................................................... No
PSD Increment ................................................... No
Send to EPA ..................................................... No
Operating Permit Program .......................................... No
FOR MODIFIED SOURCES
The Notice of Intent is for a modification to an existing source. The following standards are applicable to
this review:
NSPS applies to modification? ....................................... No
PSD review of entire source required? ................................. No
NESHAPS applies to modification? ................................... No
HAPs involved in modification? ..................................... No
TITLE V required for entire source? .................................. No
HAPs MAJOR for modification? ..................................... No
NONA TT MAJOR for entire source? ................................. No
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 2
Abstract
Metalcraft Technologies, Inc. (Metalcraft), has submitted a Notice of Intent (NOi), dated October 28,
1999 with additional information submitted on March 3, 2000, requesting a modification to the
Approval Order (AO) dated December 1, 1999 (DAQE-937-99), for their aircraft parts manufacturing
facility in Cedar City, Utah. The proposed modification is for the addition of two passivation tanks and
the removal of the chromic acid anodize tank. Metalcraft is located in Iron County which is an
attainment area of the National Ambient Air Quality Standards (NAAQS)for all pollutants. New
Source Performance Standards (NSPS) do not apply to this source. National Emission Standards for
Hazardous Air Pollutants (NESHAP) 40 CFR 63, Subpart N -National Emissions Standards for
Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing
Tanks will not longer apply to this source due to the removal of the chromic acid anodize tank. Title V
of the 1990 Clean Air Act will no longer apply to this source. The emissions, in tons per year, will
change as follows: HAPs + 0.13 of nitric acid. Best Available Control Technology will require the
passivation tanks to be equipped with lids that will remain closed at all times unless parts are being put
into or removed from them. It has been determined that the conditions of the Utah Administrative
Code R307-401-6 have been met and the Executive Secretary intends to issue an Approval Order after a
JO-day public comment period is complete and the comments received are evaluated ..
Newspaper Notice
Metalcraft Technologies, Inc. (Metalcraft), has submitted a Notice of Intent (NOI), dated October 28, 1999
with additional information submitted on March 3, 2000, requesting a modification to the Approval Order
(AO) dated December 1, 1999 (DAQE-937-99), for their aircraft parts manufacturing facility in Cedar
City, Utah. The proposed modification is for the addition of two passivation tanks and the removal of the
chromic acid anodize tank. Metalcraft is located in Iron County which is an attainment area of the
National Ambient Air Quality Standards (NAAQS) for all pollutants. New Source Performance Standards
(NSPS) do not apply to this source. National Emission Standards for Hazardous Air Pollutants (NESHAP)
40 CFR 63, Subpart N -National Emissions Standards for Chromium Emissions from Hard and
Decorative Chromium Electroplating and Chromium Anodizing Tanks will not longer apply to this source
due to the removal of the chromic acid anodize tank. Title V of the 1990 Clean Air Act will no longer
apply to this source. It has been determined that the conditions of the Utah Administrative Code R307-
401-6 have been met and the Executive Secretary intends to issue an Approval Order after a 10-day public
comment period is complete and the comments received are evaluated ..
I. DESCRIPTION OF PROPOSAL
Metalcraft Technologies submitted an NOI on October 28, 1999 with additional information submitted on
March 3, 2000. Metalcraft is proposing to add an additional capability for passivation of stainless steel in
their current facility located at 498 North 2774 West, Cedar City, Utah. The tanks are proposed to have
the following characteristics:
Tank 1:
Tank Dimensions: 47"x42"x27"
Nitric Acid Concentration: 61-74 oz per gallon
Annual Usage: 3,864 lbs
Evaporation Rate: 3%
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 3
Tank 2:
Tank Dimensions: 36"x28"x29"
Nitric Acid Concentration: 32-57 oz per gallon
Annual Usage: 1,392 lbs
Evaporation Rate: 3%
11. EMISSION SUMMARY
The emissions from this source (the entire plant) will be as follows:
Pollutant
Current Emissions
tons/year
Emission Increases
tons/year
Total Emissions
tons/year
PMIO . . . . . . . . . . . . . . . . . . . . . . . 0.48 .............. 0.00 . . . . . . . . . . . . . . 0.48
S02 ••••••••••••••••••••••• 1.00 ............... 0.00 .............. 1.00
NOX . . . . . . . . . . . . . . . . . . . . . . . 2.40 ............... 0.00 . . . . . . . . . . . . . . 2.40
co ....................... 0.41 ............... 0.00 .............. 0.41
voe ...................... 14.43 ............... o.oo ............. 14.43
HAPs
Chromium Compounds . . . . . . . . 0.020 .............. 0.000
Ethyl Benzene . . . . . . . . . . . . . . . 0.314 .............. 0.000
Ethylene Glycol . . . . . . . . . . . . . . 0.611 .............. 0.000
Hydrofluoric Acid ............ 0.003 .............. 0.000
Lead . . . . . . . . . . . . . . . . . . . . . . . 0.000 .............. 0.000
Methyl Ethyl Ketone .......... 0.861 .............. 0.000
Methyl Isobutyl Ketone ........ 0.774 .............. 0.000
Methyl Amul Ketone . . . . . . . . . . 0.056 .............. 0.000
Nickel Oxide . . . . . . . . . . . . . . . . 0.000 .............. 0.000
Nitric Acid . . . . . . . . . . . . . . . . . . 0.160 .............. 0.160
Potassium Ferricyanide . . . . . . . . 0.003 .............. 0.000
Toluene . . . . . . . . . . . . . . . . . . . . 0.078 .............. 0.000
Triethylamine . . . . . . . . . . . . . . . . 0.278 .............. 0.000
Xylene . . . . . . . . . . . . . . . . . . . . . 0.689 .............. 0.000
Miscellaneous HAPs .......... 0.614 .............. 0.000
0.020
0.314
0.611
0.003
0.000
0.861
0.774
0.056
0.000
0.160
0.003
0.078
0.278
0.689
0.614
Total HAPs ............ 3.85 ............... 0.16 .............. 3.85
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page4
III. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS
BACT will be required for the installation of the passivation tanks. The best control stategy for the
reduction of emission due to evaporation is the storage container of the material being used. In this case
two passivation tanks will be used which will contain nitric acid concentrations. BACT for the storage
tanks will require the tanks to be equipped with lids and that the lids remain closed at all times unless parts
are being put into or removed from them. The emissions will be vented to the atmosphere through a roof
vent which shall have a 5% opacity limitation.
IV. APPLICABILITY OF FEDERAL REGULATIONS AND UTAH ADMINISTRATIVE
CODES (UAC)
The Notice of Intent submitted is or an ex1stmg s rce. It is not a new major source or a major
modification. The following fede ions and state rules have been examined to determine their
applicability to this Notice of Intent:
1. R307-401, Utah Administrative Code (UAC) UAC -Notice of Intent required for a modified
source. Therefore, this rule applies and a Notice of Intent is required for the two new
passivation tanks.
2. Modification, State and Federal definitions.
State definition, R307-l 01-2 -"any planned change in a source which results in a potential
increase of emissions." MM"aft is increasing some HAP emissions. Therefore, by state
definition it is a modificati~
Federal definition, 40 CFR 60.14 -Any physical or operational change to an existing facility
that results in an increase in the emission rate to the atmosphere of any pollutant to which a
standard applies. The following are not by themselves considered modifications:
A. Maintenance, repair, and replacement
B. An increase in production rate of an existing facility, if that increase can be accomplished
without a capital expenditure on that facility
C. An increase in the hours of operation
D. Use of an alternate fuel or raw material if, before the date any standard under this part
becomes applicable to that source type, as provided by 60.1, the existing facility was
designed to accommodate that alternative use
E. The addition or use of any system or device whose primary function is the reduction of air
pollutants
F. Relocation or change in ownership
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 5
In section 111 of the Clean Air Act, "modification" means any physical change in, or change
in the method of operation of, a stationary source which increases the amount of any air
pollutant emitted by such source or which results in the emission of any air pollutant not
previously emitted.
In section 302 of the Clean Air Act, "air pollutant" means an air pollution agent or
combination of such agents, including any physical, chemical, biological, radioactive
(including source material, special nuclear material, and byproduct material) substance or
matter which is emitted into or otherwise enters the ambient air.
Metalcraft is increasing their air pollutants. Therefore, by federal definition this is a
modification.
3. R307-101-2, Definition of Major Modification -It means any physical change in or changes in
the method of operation of a major source that would result in a significant net emission
increase of any pollutant. A net emissions increase that is significant for VOC shall be
considered significant for ozone. A physical change or change in the method of operation
shall not include:
A. Routine maintenance, repair, or replacement
B. Use of an alternative fuel or raw material by reason of an order under Sections 2a and 2b
of the ESECA of 1974 or by reason of a natural gas curtailment plan pursuant to the
Federal Power Act
C. Use of an alternative fuel at a steam generating unit to the extent that the fuel is generated
from municipal solid waste
D. Use of an alternative fuel or raw material by a source:
1) which the source was capable of accommodating before January 6, 1975, unless such
change would be prohibited under any enforceable permit condition
2) which the source is otherwise approved to use
E. An increase in the hours of operation or the production rate unless such change would be
prohibited under any enforceable permit condition
F. Any change in ownership at a source
Metalcraft will not change their emissions significantly. Therefore, this Plan Review is not for
a major modification.
4. R307-105, UAC -Emergency episode requirements. This rule requires the executive secretary
to determine the stage and extent of an air pollution episode based on pollution levels and
meteorological conditions. Under Section 40 of the Code of Federal Regulations, Part 51,
Subpart H (51.150 to 153), it is required that sources plan emergency measures based upon the
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 6
severity of the Nonattainment area in which they operate. Metalcraft is located in Iron County
which is an attainment area and does not impact a Nonattainment area. Therefore, an
emergency episode plan is not required for this source.
5. R307-107, UAC -Unavoidable breakdown reporting requirements. R307-107-2 discusses
reporting requirements. A breakdown for any period longer than two hours must be reported
to the executive secretary within three hours of the beginning of the breakdown, if reasonable,
but in no case longer than 18 hours after the beginning of the breakdown. A written report is
required within seven calendar days. The report shall include the estimated quantity of
pollutants (total and excess). R307-107-3 discusses penalties.
This rule applies to this source at this time.
6. R307-150, UAC -Emission inventory reporting requirements. This rule requires the owner or
operator of sources of air pollution to submit an emissions inventory report:
The requirements of R307-150 replace any annual inventory reporting requirements in
approval orders issued prior to April 1, 1998.
R307-150. Emission Inventories
R307-150-1. General Applicability.
(1) The following sources shall submit an emission inventory report:
(a) any Part 70 source;
(b) any source that emits or is allowed under R307 to emit 100 ton per year or more of any
regulated air pollutant;
(c) any source located in Davis, Salt Lake, Utah or Weber County that emits or is allowed
under R307 to emit 25 tons per year or more of a combination of PM 10, sulfur oxides, or
oxides of nitrogen;
(d) any source located in Davis, Salt Lake, Utah or Weber County that emits or is allowed
under R307 to emit 10 tons per year or more of volatile organic compounds;
(e) any source that emits or is allowed under R307 to emit 5 tons per year or more of lead;
(f) any source that emits or is allowed under R307 to emit 10 tons or more per year of
ammonia;
(g) any source that is allowed under R307 to emit between 90 and I 00 tons per year of any
regulated air pollutant;
(h) any source that the executive secretary requires to submit an inventory for any full or
partial year on reasonable notice.
This source is not located in Salt Lake, Davis, or Utah County and does not emit 100 tons per
year of any regulated pollutant, 5 tons per year of lead, 10 tons per year of ammonia, is not
allowed to emit more than 90 tons per year of a regulated pollutant, and it is not a Part 70
source. Therefore, this rule does not apply to this source at this time.
7. R307-l 70, UAC -Continuous Emission Monitoring Systems Program -Reporting and
technical requirements for continuous emission monitoring systems. It covers breakdowns
and quarterly reports for continuous monitoring systems. R307-170-5 states that this
regulation applies to the following:
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 7
A. Sources required to install a CEMS as required by the following documents:
1) NSPS
2) State Implementation Plan
3) Approval Order
4) Consent Decree
5) Administrative Orders and Agreements
B. Any source that constructs after the promulgation of this rule two or more
emission points, which may interfere with VEOs, shall install an opacity monitor
on each stack.
This rule does not apply to the equipment in this review for this source at this time.
8. R307-201-1(2), UAC -20% opacity limitation at all emission points. Unless a more
stringent limitation is required by New Source Performance Standards (NSPS) or BACT
or National Emission Standards for Hazardous Air Pollutants (NESHAPS).
In this case, some points, which are subject to BACT, must meet more stringent opacity
limitations.
9. R307-201-1(9), UAC -EPA Method 9 shall be used for visible emission observations.
This rule applies.
10. R307-203-1 (1 ), UAC -Sulfur content limitations in coal, oil, or mixture thereof, burned in
any fuel burning or process not covered by NSPS for sulfur emissions.
This source, emission point, does not use oil or coal for combustion. Therefore, this rule
does not apply.
11. R307-206, UAC -Abrasive Blasting Requirements -Opacity limitations and performance
standards for abrasive blasting -This rule does not apply to this source or emission point
covered in this review.
12. R307-305-5(2), UAC -Particulate emission limitations for existing sources that are
located in a Nonattainment area. This rule has been superseded by the Section IX, Parts A
and Hof the SIP except for Weber County. The effective date is November 15, 1990.
This source is not located in Weber County, and it is not listed in the SIP. Therefore, this
rule does not apply.
13. R307-325 through R307-341, UAC -Review requirements for volatile organic compound
(VOC) sources located in an ozone Maintenance area. For sources located in ozone
Maintenance areas (Salt Lake and Davis Counties) this rule specifies the minimum
(RACT) control measures promulgated by the Utah Air Quality Board. In addition, UAC
R307-401-6 requires application of BACT for all new or modified sources in the state.
However, within an ozone Maintenance area BACT can not be less stringent than RACT.
Therefore, for ozone Maintenance areas the more stringent requirement is applicable (i.e.,
BACT as required by UAC, R307-401-6 or RACT as defined by UAC R307-325 through
R307-341, or as defined in a published Control Techniques Guidance document).
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April5,2000
Page 8
This rule applies only in Salt Lake and Davis Counties and Metalcraft is located in Iron
County. Therefore, this rule does not apply to this source.
14. R307-401-6, UAC -The executive secretary shall issue an approval order if it is
determined through plan review that the following conditions have been met:
401-6(1) The degree of pollution control for emissions, to include fugitive emissions and
fugitive dust, is at least best available control technology except as otherwise provided in
Title R307.
Application of best available control technology (BACT) required at all emission points.
This rule applies to all new and modified sources throughout the state. If a source is
located in a Nonattainment area, the BACT analysis must be as stringent as RACT. This
source is located in an attainment area. Therefore, this rule applies and the source must
meet the BACT requirements.
401-6(2) The proposed installation will be in accord with applicable requirements of:
Utah Title R307 ; National Standards of Performance for New Stationary Sources;
National Primary and Secondary Ambient Air Quality Standards; National Emission
Standards for Hazardous Air Pollutants; new source review criteria; maximum allowable
increase and maximum allowable concentration requirements for Prevention of Significant
Deterioration; the State Implementation Plan for the area, if the area is classified as a
nonattainment or maintenance area; and new source requirements for nonattainment areas
under the Federal Clean Air Act.
There is no NSPS requirements for this industrial process.
40 CFR, Part 63 -National Emission Standards for Hazardous Air Pollutants (NESHAP) -
There is a NESHAP for this industrial process. The NESHAP code and title are 40 CFR
63 .741 to 63.753, Subpart GG (National Emission Standard for Aerospace Manufacturing
and Rework Facilities) This NESHAP does not apply to Metalcraft because they are not a
major source of air pollutants.
401-6(3) The executive secretary shall issue an approval order under R307-405-6 for a
major source or major modification which consumes more than 50% of the increments in
R307-405-4 only after receiving the approval of the Board. Metalcraft will not consume
more than 50% of the increment. Therefore, this rule does not apply at this time.
Metalcraft has met the state and federal rules and regulations stated above. Therefore, it
has been determined that an approval order should be issued after the appropriate public
comment period has been held and all of the comments have been evaluated.
15 . R307-401-7, UAC -Rules for relocation of temporary sources. This source is a permanent
source. Therefore, this rule does not apply.
16. R307-401-10, UAC -Requirement for installation of low-NOx burners on all existing
sources whenever existing fuel combustion burners are replaced, unless the replacement is
not physically practical or cost effective. The effective date is November 15, 1990.
Engineering Review: Metalcraft Technologies, Inc. - Passivation Tanks
April 5, 2000
Page 9
There will be no burners replaced at this time. Therefore, this rule does not apply.
17. R307-401-11, U AC -Approval orders issued by the executive secretary in accordance
with the provisions of R307-401 shall be reviewed eighteen months after the date of
issuance to determine the status of construction, installation, modification, relocation or
establishment. If a continuous program of construction, installation, modification,
relocation or establishment is not proceeding, the executive secretary may revoke the
approval order. There will be some new installation, modification, or establishment at this
site. Therefore, this rule applies.
18. R307-403-3, UAC -Review requirements for new major sources or major modifications
that are located in a Nonattainment area or which impact a Nonattainment area. This
Notice of Intent does not represent a new major source or a major modification.
Therefore, this rule will not apply.
19. R307-403-5(1)(c), UAC -Enforceable offsets of Ll are required for new sources or
modifications that would produce an emission increase greater than or equal to 25 tons per
year but less than 50 tons per year of any combination of PM10, SO2, and NOx . This is
required in Salt Lake, Davis, and Utah Counties and in any area that impacts these three
counties as defined in the rule. The effective date is November 15, 1990.
This source is located in Iron County which is an attainment area for PM10• Therefore, an
offset will not be required.
20. R307-405-4, UAC -Prevention of Significant Deterioration (PSD) Increment
Consumption -This rule lists the allowable PSD increment consumption. Under the PSD
rules, the entire state has been triggered for Particulate (PM10), SO2, and NOx. Metalcraft
is located in an attainment area and will not consume any additional increments at this
time.
21. R307-405-6(2), UAC -Prevention of Significant Deterioration (PSD) review requirements
for new major sources or major modifications. This Notice of Intent does not represent a
new major source or a major modification under PSD rules. Therefore, this rule does not
apply.
22. R307-405-7, UAC -Increment violations. This rule requires the UAQB to promulgate a
plan and implement rules to eliminate any PSD increment violations that occur in the
state. No known violations have yet occurred. This proposed Notice of Intent will not
consume any additional increments.
23. R307-406, UAC -Visibility screening analysis requirements. This rule requires all new
major sources or major modifications to undergo a visibility screening analysis to
determine visibility impact on any mandatory Class I area. This Notice of Intent does not
represent a new major source or a major modification under UAC R307. Therefore, this
rule does not apply.
24. R307-410, UAC -Air Quality Modeling -All estimates of ambient concentrations
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page IO
required in meeting the requirements of the regulations shall be based on appropriate air
quality models, data bases, and other requirements specified in the Utah Guidelines to Air
Quality Models. Modeling analysis is not routinely performed for air pollution sources
with emissions below the following levels:
Criteria for Screen Modeling
in Attainment Areas
(~ Tons per Year)
PM10
a. fugitive & fugitive dust . 5
b. non-fugitive emissions or
non-fugitive dust ..... 15
S02 •••••••••.•••••••••• 40
N02 ••••••••••••.•••••• 40
CO ....................... as required under R307-405-6(2)
0 3 ...................... 5
HAPs
There are no de minimis limit for HAPs modeling. All HAPs have
to be evaluated individually. See the modeling section for
guidance.
Pb ...................... 0.6
Modeling was performed for the nitric acid emissions and the concentrations were within
the DAQ guidelines.
25. R307-410-5, UAC -Stack height rule. This rule limits the creditable height of stacks to
that height determined to be good engineering practice. The formulas used to determine
good engineering practice are found in 40 CFR 51.100. The maximum creditable height
of 65 meters (213.2 feet) is allowed. There are no has no stacks at this site that exceed 65
meters in height. Therefore, this source is in compliance with this rule.
26. R307-413-4(1), UAC - A Notice of Intent is not required for fuel-burning equipment in
which combustion takes place at no greater pressure than one inch of mercury above
ambient pressure with a rated capacity of less than five million BTU per hour using no
other fuel than natural gas or LPG or other mixed gas that meets the standards of gas
distributed by a utility in accordance with the rules of the Public Service Commission of
the State of Utah is exempt, unless there are emissions other than combustion products.
There will be no new natural gas burning equipment installed at the site covered in this
Plan Review. Therefore, this rule does not apply.
27. R307-413-4(5), UAC -Notice of Intent required for a new parking lot of 600 or more
spaces and adding 350 or more spaces to an existing lot. There will be no parking lot
construction at this location. Therefore, a Notice of Intent is not required based on this
rule but is required based on R307-401, UAC.
28. R307-413-4(6), UAC -Notice of Intent not required for sources with emissions less than
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 11
10 tons/yr of the following compounds: 1, 1,] -trichloroethane, methylene chloride,
trichlorofluoromethane, dichlorodifluoromethane, chlorodifluoromethane,
trifluoromethane, 1, 1,2-trichloro-1,2,2-trifluoroethane, 1,2-dichloro 1, 1,2,2-
tetrafluoroethane, methane, ethane and chloropentafluoroethane. However, if the source is
emitting more than IO tons/yr of any of these compounds, a Notice of Intent must be filed
and an annual report of emissions thereafter. This source will not emit 10 tons/year of
these regulated pollutants. Therefore, a Notice of Intent is not required based on this rule
but is required based on R307-401, UAC.
29. R307-420, UAC -Enforceable offsets are required for new sources or modifications of
sources that are deemed "major". The term major shall mean: any stationary source of air
pollutants which emits, or has the potential to emit, fifty tons per year or more of volatile
organic compounds; or any stationary source of air pollutants which emits, or has the
potential to emit, one hundred tons per year or more of nitrogen oxides; or any physical
change that would occur at a source not qualifying above as a major source, if the change
would constitute a major source by itself.
This source is located in Iron County which is an attainment area for ozone. Therefore, an
offset will not be required.
30. 40 CFR, Part 50 -National Ambient Air Quality Standards (NAAQS) -This source is
located in Iron County, which is an attainment area for all pollutants.
The Division of Air Quality guidelines do not call for this source to be modeled for any
pollutant. The Division has found through experience that a source or emission point of
this small size is very unlikely to cause a new violation of the NAAQS. This is because of
the small quantity of emissions involved and the conservative predictions made by
modeling.
Therefore, it is very unlikely that any new violation of the NAAQS for any pollutant PM10,
SO2, NO,, ozone, CO will occur.
31. 40 CFR 60.18, General Control Device Requirements. These requirements apply to NSPS
Subparts that refer to this section. It specifically covers flares. This source does not have
a flare. Therefore, this regulation does not apply to this source.
32. 40 CFR 60.15, Definition of Reconstruction -the replacement of components of an
existing facility to such an extent that:
A. The fixed capital cost of the new components exceeds 50% of the fixed capital
cost that would be required to construct a comparable entirely new facility and
B. It is technologically and economically feasible to meet the applicable standards set
forth in this part
This source is not replacing any components. Therefore, this Notice of Intent is not for a
reconstruction.
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 12
33. 40 CFR, Part 72, 73, 75, 76, 77, and 78 -Federal regulations for the Acid Rain Program
under Clean Air Act Title N -This source does not generate electricity for sale.
Therefore, the Acid Rain Program does not apply.
34. 40 CFR 80.29, Controls and Prohibitions on Diesel Fuel Quality -The effective date of
the regulation is September 20, 1990. This rule implements a new national program of
diesel fuel quality control. The rule requires that refiners reduce the sulfur content of on-
highway diesel fuel from current average levels of approximately 0.25 % to levels not
exceeding 0.05 %. This rule also requires that on-highway diesel fuel have a minimum
cetane rating of 40 (or meet a maximum aromatics level of 35%).
This source is not a refiner of diesel fuel. Therefore, this rule does not apply.
The preceding rules and regulations have been examined to determine their applicability to
Metalcraft Technologies, Inc., at the time of this review. At a later date the applicability of these
rules and regulations are subject to change.
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 13
V. RECOMMENDED APPROVAL ORDER CONDITIONS
General Conditions:
1. This Approval Order (AO) applies to the following company:
Site Office
Metalcraft Technologies, Inc.
498 North 2774 West
Cedar City, Utah 84720
Phone Number [phone]
Fax Number [phone]
The equipment listed in this AO shall be operated at the following location:
PLANT LOCATION:
498 North 2774 West, Cedar City, Utah, Iron County
Universal Transverse Mercator (UTM) Coordinate System:
4,172.9 kilometers Northing, 314.7 kilometers Easting, Zone 12
2. Definitions of terms, abbreviations, and references used in this AO conform to those used
in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of
Federal Regulations ( 40 CFR). These definitions take precedence, unless specifically
defined otherwise herein.
3. Metalcraft Technologies, Inc., shall install and operate the two passivation tanks and shall
conduct its operations of the aircraft parts manufacturing facility in accordance with the
terms and conditions of this AO, which was written pursuant to Metalcraft' s Notice of
Intent submitted to the Division of Air Quality (DAQ) on October 28, 1999 and additional
information submitted to the DAQ on March 3, 2000.
4. This AO shall replace the AO dated December 1, 1999 (DAQE-937-99).
5. The approved installations shall consist of the following equipment or equivalent*:
A. Natural Gas Curing Oven
Design Capacity: 700,000 BTU/hr
B. Natural Gas Paint Burn-Off Oven
Design Capacity: 800,000 BTU/hr
C. Natural Gas Treatment Oven #1
Design Capacity: 3,400,000 BTU/hr
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 14
D. Natural Gas Treatment Oven #2
Design Capacity: 3,200,000 BTU/hr
E. Seven Paint Booths with particulate filters
F. Two Alodine Lines
G. One Titanium Etching Line
H. One Anodizing Line (including a sulfuric acid tank, and a sulfuric boric acid tank)
I. Water Treatment System (including seven holding tanks, three purification tanks,
a clarifier, and a filter press).
J. One Sunstrand Parts Maker (with 2,200 acfm filter collection system)
K. Two Natural Gas Air Make-up Heaters
L.
Design Capacity: 5,000,000 BTU/hr each
Space Heaters
Design Capacity: 350,000 BTU/hr each
M. Passivation Tank (100 gallon) *
Tank Dimensions: 47"x42"x27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz per gallon
Evaporation Rate: 3%
N. Passivation Tank (100 gallon)*
Tank Dimensions: 36"x28"x29" (assuming 4" freeboard)
Nitric Acid Concentration: 32-57 oz per gallon
Evaporation Rate: 3%
* Equivalency shall be determined by the Executive Secretary.
Any future changes or modifications to the equipment and processes approved by this AO
that could affect the emissions covered by this AO must be approved in accordance with
R307-401-1, UAC.
6. Metalcraft shall notify the Executive Secretary in writing when the installation of the
equipment listed in Condition #5.M & 5.N has been completed and is operational, as an
initial compliance inspection is required. To insure proper credit when notifying the
Executive Secretary, send your correspondence to the Executive Secretary, attn:
Compliance Section.
If installation has not been completed within eighteen months from the date of this AO, the
Executive Secretary shall be notified in writing on the status of the installation. At that time, the
Executive Secretary shall require documentation of the continuous installation of the operation and
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 15
may revoke the AO in accordance with R307-401-1 I , UAC.
Limitations and Tests Procedures
7. Visible emissions from the following emission points shall not exceed the following
values:
A. All paint booths exhaust stacks - 5% opacity
B. Passivation tank exaust stack - 5% opacity
C. All natural gas combustion stacks -10% opacity
D. All other points -20% opacity
Opacity observations of emissions from stationary sources shall be conducted according to
40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and
intermittent sources shall use procedures similar to Method 9, but the requirement for
observations to be made at I 5 second intervals over a six minute period shall not apply.
Any time-interval with no visible emissions shall not be included.
8. The consumption limits of the following materials shall not be exceeded without prior
approval in accordance with R307-401, UAC:
A.
B.
C.
D.
E.
Alodine I 200S or equivalent* -
Sodium Chromate -
Hydrofluoric Acid -
Nova Coat 1100 or equivalent* -
Acidic Chromated Deoxidizer -
85 pounds per rolling 12-month period.
1 pounds per rolling 12-month period.
125 gallons per rolling 12-month period.
135 gallons per rolling 12-month period.
125 pounds per rolling 12-month period.
Records of consumption shall be kept for all periods when the plant is in operation. The
consumption shall be determined by sales invoices or by any other method as acceptable to
the executive secretary or representatives of the executive secretary. Records of
consumption, shall be made available to the executive secretary or representatives of the
executive secretary upon request.
9. The owner/operator shall use only natural gas as fuel. If any other fuel is to be used, an
AO shall be required in accordance with R307-401, UAC.
Volatile Organic Compound (VOC) and Hazardous Air Pollutants (HAPs) Limitations
10. The paint spray booths shall be equipped with sets of paint arrestor particulate filters, or
equivalent, to control particulate emissions. All air exiting the booth shall pass through
this control system before being vented to the atmosphere (outside building/operation).
Equivalency determinations, when requested by the owner/operator, shall be submitted to
the Executive Secretary for approval.
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 16
11. The plant-wide emissions of VOCs and HAPs from the paint booths, alodine lines,
titanium etching line, anodizing line and associated operations shall not exceed:
14.43 tons per rolling 12-month period for VOCs
40.00 pounds per rolling 12-month period for chromium compounds
627.42 pounds per rolling 12-month period for ethyl benzene
1,222.00 pounds per rolling 12-month period for ethylene glycol
6.41 pounds per rolling 12-month period for hydrofluoric acid
0.22 pounds per rolling 12-month period for lead
1,721.44 pounds per rolling 12-month period for methyl ethyl ketone
1,547.30 pounds per rolling 12-month period for methyl isobutyl ketone
112.38 pounds per rolling 12-month period for methyl amul keytone
0.12 pounds per rolling 12-month period for nickel oxide
319.92 pounds per rolling 12-month period for nitric acid
6.75 pounds per rolling 12-month period for potassium ferricyanide
155.30 pounds per rolling 12-month period for toluene
555.50 pounds per rolling 12-month period for triethylamine
1,377.00 pounds per rolling 12-month period for Xylene
3.85 tons total per rolling 12-month period for all HAPs combined
This value shall not be exceeded without prior approval, in accordance with R307-401,
UAC. Compliance with each 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 plant-wide emissions of VOCs and HAPs emitted to the atmosphere shall be
determined by maintaining a record of VOC potential and HAP potential contained in
materials used each month. The record shall include the following data for each item
used:
A. Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, isocyanates, etc.
B. The weight and use location (name of paint booth or plant facility) of the VOC
potential and HAP potential of the material(s) listed in A, in pounds per gallon.
C. Percent by weight of all VOC potential and HAP potential for each individual
material listed in A. The percent by weight of the VOC and HAP potentials can
be obtained from the manufacturers' MSDSs. The owner/operator can obtain
MSDS data from the manufacturers of the materials and retain the information on-
site.
D. Amount and location of materials containing VOCs and HAPs used on a monthly
basis and summed for every location and for the entire plant each month.
E. To calculate the above potentials contained in the material listed in D, use the
following procedure:
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 17
VOC or HAPs =%Volatile by Weight x [Density U!D] x Gal Consumed x -1...!Qn_
(100) (gal) 2000 lb
F. The amount of VOC content potential (potential air emissions) and HAP potential
(potential air emissions) in pounds contained in materials deposited as solid or
hazardous waste for the month shall be quantified and subtracted from the
quantities calculated above. This is done to allow quantification by the source of
the total VOCs and HAPs emissions. (The assumption is that all the two above-
potentials of the materials applied to a product evaporate and are therefore
considered emissions).
G. Records of consumption of VOCs and HAPs shall be kept for all periods when the
plant is in operation. Records of consumption shall be made available to the
Executive Secretary or Executive Secretary's representative upon request, and the
records shall include the two-year period prior to the date of the request.
Records & Miscellaneous
12. 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 Approval Order 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 Executive Secretary 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, and the records shall be maintained
for a period of two years. Maintenance records shall be made available to the Executive
Secretary or Executive Secretary's representative upon request, and the records shall
include the two-year period prior to the date of the request.
13. The owner/operator shall comply with R307-107, UAC. This rule addresses unavoidable
breakdown reporting requirements. The full text of UAC R307-l 07 General
Requirements, Unavoidable Breakdown, is included as Appendix A. However, to be in
compliance, this facility must operate in accordance with the most current version of the
UAC, R307-107.
All records referenced in this AO which are required to be kept by the owner/operator, shall be made
available to the Executive Secretary or Executive Secretary's representative upon request, and the records
shall include the two-year period prior to the date of the request. All records shall be kept for a period of
two years. A summary of those records that are required as part of this Approval Order is included herein.
This summary shall not be considered an additional requirement, but is included for informational
purposes only. The condition that requires that these records be kept as part of the compliance with this
AO is listed following the individual record. Examples of records to be kept at this source shall include
the following as applicable:
Consumption Condition number 8
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 18
VOC and/or HAPs emission records
Maintenance records
Upset, breakdown episodes
Condition number 11
Condition number 12
Condition number 13
The list above may not be a complete list of all records that are required to be kept by Metalcraft
Technologies, Inc. For a complete list of required records check all AO conditions, and all
applicable Federal regulations such as NSPS, NESHAPS, and MACT standards that apply to this
source.
Any future modifications to the equipment approved by this order must also be approved in accordance
with R307-401 , UAC.
The Executive Secretary shall be notified in writing if the company is sold or changes its name.
Under R307-150-1, UAC, the Executive Secretary may require a source to submit an emission inventory
for any full or partial year on reasonable notice.
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.
A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting
the Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of Intent
(NOD guide, and other air quality documents and forms may also be obtained on the Internet at the
following web site:
http://www.eq.state.ut.us/eqair/aq_home.htm
Annual emissions for this source (the entire plant) are currently calculated at the following values:
Pollutant Tons/yr
A. PMIO ................................ 0.48
B. S02 ..•............••...•..••....... 1.00
C. NOX ................................ 2.40
D. CO ................................. 0.41
E. voe .............................. 14.43
F. HAPs
HAPs consist of the following amounts in Pounds/Year.
Chromium compounds ........... 40.00
Ethyl benzene . . . . . . . . . . . . . . . . . 627.42
Ethylene glycol .............. 1,222.00
Hydrofluoric Acid ............... 6.41
Lead .......................... 0.22
Methyl ethyl ketone . . . . . . . . . . . 1,721.44
Methyl isobutyl ketone ......... 1,547.30
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 19
Methyl amul keytone . . . . . . . . . . . 112.38
Nitric Acid ................... 319.92
Nickel oxide .................... 0.12
Potassium ferricyanide ............ 6.75
Toluene . . . . . . . . . . . . . . . . . . . . . 155.30
Triethylamine ................. 555.50
Xylene ..................... 1,377.00
The annual emission estimations above are for the purpose of determining the applicability of Prevention
of Significant Deterioration, nonattainment area, Maintenance area, and Title V source requirements of the
UAC R307. They are not to be used for determining compliance.
F:\AQ\ENGINEERVBLACK\ WP\R VW _00\MET AL.RVW
Engineering Review: Metalcraft Technologies. Inc. -Passivation Tanks
Apri!S,2000
Page 20
Appendix A
Engineering Review: Metalcraft Technologies, Inc. -Passivation Tanks
April 5, 2000
Page 21
Michael 0 . Laved
Governor
Dianne R. Nielson, Ph.D.
Executive Director
Ursula Kramer
Director
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
150 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
[phone] Voice
[phone] Fax
[phone] T.D.D.
Web: www.deq.state.ut.us
December 1, 1999
Susie Barney
Environmental Engineer
Metalcraft Technologies
498 North 2774 West
Cedar City, Utah 84720
Dear Ms. Barney:
Re: Approval Order Modification for Increase in Alodine 1200S Consumption Limit
Iron County, CDS-B, NESHAP, HAPs, Title V
The attached document is an Approval Order for the above-referenced project.
FILE COPY
DAQE-937-99
Future correspondence on this Approval Order should include the engineer's name as well as the DAQE
number as shown on the upper right-hand comer of this letter. Please direct any technical questions you may
have on this project to Mr. Jon Black. He may be reached at [phone].
Sincerely,
Ursula Kramer, Executive Secretary
Utah Air Quality Board
UK:JB:aj
cc: Southwest Utah District Health Department
Mike Owens, EPA Region VIII
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
APPROVAL ORDER MODIFICATION FOR INCREASE IN
ALODINE 1200S CONSUMPTION LIMIT
Prepared By: Jon Black, Engineer
[phone]
APPROVAL NUMBER
DAQE-937-99
Date: December 1, 1999
Source Contact
Metalcraft Technologies
Susie Barney
[phone]
Ursula Kramer
Executive Secretary
Utah Air Quality Board
..
Abstract
Meta/craft Technologies, Inc. (Meta/craft) is requesting a modification to the Approval Order (AO), dated
January 21, 1998, (DAQE-033-98),for their aircraft parts manufacturingfacility in Cedar City, Utah. The
proposed modification is/or a consumption limit increase/or the a/odine 1200S used in the a/odine line.
Meta/craft has experienced an increase in the amount of production parts requiring processing through
the a/odine line and, therefore, requires the requested increase to replenish their a/odine tanks. The facility
is located in an attainment area for all pollutants. It is a minor source and the modif,cation-is minor. The
chromium anodizing tank is subject to National Emissions Standards for Hazardous Air Pollutants
(NESHAP)(40 CFR 63, Subpart N -National Emissions Standards for Chromium Emissions from Hard
and Decorative Chromium Electroplating and Chromium Anodizing Tanks). The facility is not subject to
40 CFR 63, Subpart GG -National Emission Standards for Aerospace Manufacturing and Rework
Facilities because this source is not a major Hazardous Air Pollutant (HAP) source. The controlled
emission increase per rolling 12-month period will be 13.0 pounds (lbs) of HAPs consisting of 10.0 lbs of
chromium compounds and 3.0 lbs of potassiumferricyanide. This project required a 30-day comment
period.
The above-referenced project has been evaluated and found to be consistent with the requirements of the
Utah Administrative Code Rule 307 (UAC R307) and the Utah Air Conservation Act. A 30-day public
comment period was held and all comments received were evaluated. The conditions of this AO reflect any
changes to the proposed conditions which resulted from the evaluation of the comments received. This air
quality AO authorizes the project with the following conditions and failure to comply with any of the
conditions may constitute a violation of this order:
General Conditions:
1. This AO applies to the following company:
Site Office
Metalcraft Technologies
498 North 2774 West
Cedar City, Utah 84720
Phone Number [phone]
Fax Number [phone]
The equipment listed below in this AO shall be operated at the following location:
PLANT LOCATION:
498 North 2774 West, Cedar City, Utah, Iron County
Universal Transverse Mercator (UTM) Coordinate System:
4,172.9 kilometers Northing; 314.7 kilometers Easting; Zone 12
2. Definitions oherms, abbreviations, and references used in this AO conform to those used in
the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of Federal
Regulations ( 40 CFR). These definitions take precedence, unless specifically defined
otherwise herein.
DAQE-937-99
Page 3
3. Metalcraft Technologies, Inc., shall operate the aircraft parts manufacturing facility and shall
conduct its operations of the alodine line in accordance with the tenns and conditions of this
AO, which was written pursuant to Metalcraft' s NOi submitted to the Division of Air Quality
(DAQ)onJune 10, 1999.
4. At least once per calendar year, all employees who operate equipment (operator) that
produces and/or controls emissions to the air shall receive proper training as to their
responsibilities in operating that equipment according to all relevant conditions of this AO.
The training for each operator shall be for all equipment that operator operates and the
required training shall only be for pollution control equipment and/or procedures that have
a direct effect on emissions to the ambient air. The equipment shall include all of the
equipment listed below in Condition #6.A through 6.L and any other equipment that affects
or produces air emissions that the operator operates. Within 60 days of every time this AO
is modified or reissued, those employees who operate equipment that produces and/or controls
emissions to the air that is affected by the AO changes shall receive proper training as to their
responsibilities in operating equipment according to all relevant conditions of this AO.
Within 60 days of a new operator being employed or assigned with the job responsibility to
operate any of the equipment that produces and/or controls emissions to the air, the new
operator shall receive proper training as to their responsibilities in operating the equipment
according to all relevant conditions of this AO. Records of operator training shall be made
available to the executive secretary or executive secretary's representative upon request and
the records shall include the two-year period prior to the date of the request. This AO shall
be made available to all employees who operate the equipment listed in this AO.
5. This AO shall replace the AO (s) dated January 21, 1998 (DAQE-0033-98).
6. The approved installations shall consist of the following equipment or equivalent*:
A. Natural Gas Curing Oven
Design Capacity: 700,000 BTU/hr
B. Natural Gas Paint Burn-Off Oven
Design Capacity: 800,000 BTU/hr
C. Natural Gas Treatment Oven # I
Design Capacity: 3,400,000 BTU/hr
D. Natural Gas Treatment Oven #2
Design Capacity: 3,200,000 BTU/hr
E. Seven Paint Booths
DAQE-937-99
Page4
F. Two Alodine Lines
G. One Titanium Etching Line
H. One Anodizing Line (including a chromic acid tank, a sulfuric acid tank, and a
sulfuric boric acid tank)
I. Water Treatment System (including seven holding tanks, three purification tanks, a
clarifier, and a filter press).
J. One Sunstrand Parts Maker (with 2,200 acfm filter collection system)
K. Two Natural Gas Air Make-up Heaters
Design Capacity:
L. Space Heaters
Design Capacity:
5,000,000 BTU/hr each
350,000 BTU/hr each
* Equivalency shall be determined by the executive secretary.
Any future changes or modifications to the equipment and processes approved by this AO that
could affect the emissions covered by this AO must be approved in accordance with
R307-401-l, UAC.
Limitations and Tests Procedures
7. Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 20% opacity. Opacity observations of
emissions from stationary sources shall be conducted in accordance with 40 CFR 60,
Appendix A, Method 9.
8. The consumption limits of the following materials shall not be. exceeded without prior
approval in accordance with R307-401, UAC:
A.
B.
C.
D.
E.
Alodine 1200S or equivalent* -
Sodium Chromate -
Hydrofluoric Acid -
Nova Coat 1100 or equivalent* -
Acidic Chromated Deoxidizer -
.8.i pounds per rolling 12-month period.
1 pounds per rolling 12-month period.
ill gallons per rolling 12-month period.
ill gallons per rolling 12-month period.
ill pounds per rolling 12-month period.
Records of consumption shall be kept for all periods when the plant is in operation. The
consumption shall be determined by sales invoices or by any other method as acceptable to
the executive secretary or representatives of the executive secretary. Records of consumption,
shall be made available to the executive secretary or representatives of the executive secretary
upon request.
DAQE-937-99
Page 5
9. The owner/operator shall use only natural gas as fuel. If any other fuel is to be used, an AO
shall be required in accordance with R307-401 , UAC.
Federal Limitations and Requirements
10. In addition to the requirements of this AO, all applicable provisions of 40 CFR 63, National
Emission Standards for Hazardous Air Pollutants (NESHAP)1 Subparts A, General
Provisions, and N, 40 CFR 63.340 to 63.347 (National Emission Standard for Chromium
Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing
Tanks) apply to this installation. A copy of the latest 40 CFR 63 Subparts N, dated January
25, 1995, is attached to this document as Appendix A. However, to be in compliance, this
facility must operate in accordance with the most current version of 40 CFR 63.
Volatile Organic Compound (YOC) and Hazardous Air Pollutants (HAPs) Limitations
11. The paint spray booth shall be equipped with a set of paint arrestor particulate filters, or
equivalent, to control particulate emissions. All air exiting the booth shall pass through this
control system before being vented to the atmosphere (outside building/operation).
Equivalency determinations, when requested by the owner/operator, shall be submitted to the
executive secretary for approval.
12. The plant-wide emissions of VOCs and HAPs from the paint booths, alodine lines, titanium
etching line, anodizing line and associated operations shall not exceed:
14.43 tons per rolling 12-month period for VOCs
40.00 pounds per rolling 12-month period for chromium compounds
627.42 pounds per rolling 12-month period for ethyl benzene
1,222.00 pounds per rolling 12-month period for ethylene glycol
6.41 pounds per rolling 12-month period for hydrofluoric acid
0.22 pounds per rolling 12-month period for lead
1,721.44 pounds per rolling 12-month period for methyl ethyl ketone
1,547.30 pounds per rolling 12-month period for methyl isobutyl ketone
112.38 pounds per rolling 12-month period for methyl amul keytone
0.12 pounds per rolling 12-month period for nickel oxide
6. 75 pounds per rolling 12-month period for potassium ferricyanide
155.30 pounds per rolling 12-month period for toluene
555.50 pounds per rolling 12-month period for triethylamine
1,377.00 pounds per rolling 12-month period for Xylene
3.69 tons total per rolling 12-month period for all HAPs combined
This value shall not be exceeded without prior approval, in accordance with R307-40 I, UAC.
Compliance with each limitation shall be determined on a rolling 12-month total. Based on
1 NESHAP = National Emission Standards for Hazardous Air Pollutants.
DAQE-937-99
Page 6
the twentieth day of each month, a new 12-month total shall be calculated using data from the
previous 12 months.
The plant-wide emissions of voes and HAPs emitted to the atmosphere shall be determined
by maintaining a record ofVOe potential and HAP potential contained in materials used each
month. The record shall include the following data for each item used:
A. Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, isocyanates, etc.
B. The weight and use location (name of paint booth or plant facility) of the voe
potential and HAP potential of the material(s) listed in A, in pounds per gallon.
C. Percent by weight of all voe potential and HAP potential for each individual
material listed in A. The percent by weight of the voe and HAP potentials can be
obtained from the manufacturers' MSDSs. The owner/operator can obtain MSDS
data from the manufacturers of the materials and retain the information on-site.
D. Amount and location of materials containing voes and HAPs used on a monthly
basis and summed for every location and for the entire plant each month.
E. To calculate the above potentials contained in the material listed in D, use the
following procedure:
voe=% Volatile by Wei!iht X [Density (J.h.)] X Gal Consumed X ..lJ.Qn_
(100) (gal) 2000 lb
F. The amount ofVOe content potential (potential air emissions) and HAP potential
(potential air emissions) in pounds contained in materials deposited as solid or
hazardous waste for the month shall be quantified and subtracted from the quantities
calculated above. This is done to allow quantification by the source of the total
VOCs and HAPs emissions. (The assumption is that all the two above-potentials of
the materials applied to a product evaporate and are therefore considered emissions).
G. Records of consumption ofVOes and HAPs shall be kept for all periods when the
plant is in operation. Records of consumption shall be made available to the
executive secretary or executive secretary's representative upon request, and the
records shall include the two-year period prior to the date of the request.
Records & Miscellaneous
13. All installations and facilities authorized by this AO shall be adequately and properly
maintained. All pollution control equipment approved by this approval order shall be
installed, maintained, and operated according to standard operating practices that will ensure
that the air quality limits set forth in this AO will be met. Instructions from the vendor or
established maintenance practices that maximize pollution control shall be used. All
maintenance performed on equipment authorized by this AO shall be recorded, and the
DAQE-937-99
Page 7
records shall be maintained for a period of two years. All necessary equipment control and
operating devices, such as pressure gauges, amp meters, _volt meters, flow-rate indicators,
temperature gauges, CEMS, etc., shall be installed and operated properly and easily accessible
to compliance inspectors. A copy of all the manufacturers' and company's own subsequent
operating instructions for pollution control equipment and pollution emitting equipment shall
be kept on site. These instructions shall be available to all employees who operate the
equipment and shall be made available to compliance inspectors upon their request.
Maintenance records shall be made available to the executive secretary or executive
secretary's representative upon request, and the records shall include the two-year period prior
to the date of the request.
14. The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and
Monitoring. This rule addresses regulated pollutant and hazardous air pollutant emission
inventory reporting requirements, and emission statement inventory requirements. Each
owner or operator of a stationary source subject to the emission statement inventory (R307-
l 50-l) rule shall maintain for a period of five years from the due date of each emission
statement a copy of the emission statement submitted to the DAO and records indicating how
the information submitted in the emission statement was determined, including any
calculations, data, measurements, and estimates used.
The full text of UAC R307-l 50 Series, Inventories, Testing and Monitoring is included as
Appendix B. However, to be in compliance, this facility must operate in accordance with the
most current version of the R307-l 50 series or the applicable section(s), if renumbered.
15. The owner/operator shall comply with R307-107, UAC. This rule addresses unavoidable
breakdown reporting requirements. Any breakdown lasting longer than two hours shall be
reported to the executive secretary within three hours of the breakdown ifreasonable, but in
no case longer than 18 hours after the beginning of the breakdown. During times other than
normal office hours, breakdowns for any period longer than two hours shall be initially
reported to the Environmental Health Emergency Response Coordinator. Within seven
calendar days of the beginning of any breakdown lasting longer than two hours, a written
report shall be submitted to the executive secretary. The owner/operator shall
calculate/estimate the excess emissions (amount above AO limits) whenever a breakdown
occurs. Within seven (7) calendar days of the beginning of any breakdown of longer than two
(2) hours, a written report shall be submitted to the executive secretary which shall include
the cause and nature of the event, estimated quantity of pollutant (total and excess), time of
emissions and steps taken to control the emissions and to prevent recurrence. The total of
excess emissions per calendar year shall be reported to the executive secretary as directed by
the executive secretary. The owner or operator of an installation suffering an unavoidable
breakdown shall assure that emission limitations and visible emission limitations are exceeded
for only as short a period of time as reasonable. The owner or operator shall take all
reasonable measures which may include but are not limited to the immediate curtailment of
production, of operations, or activities at all installations of the source ifnecessary to limit the
total aggregate emissions from the source to be no greater than the aggregate allowable
emissions averaged over the periods provided in the source's approval orders or R307.
·-
DAQE-937-99
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All records referenced in this AO and NESHAP, which are required to be kept by the owner/operator, shall
be made available to the executive secretary or executive secretary's representative upon request, and the
records shall include the two-year period prior to the date of the request. All records shall be kept for a period
of two years. A summary of those records that are required as part of this AO is included herein. This
summary shall not be considered an additional requirement, but is included for informational purposes only.
The condition that requires that these records be kept as part of the compliance with this AO is listed following
the individual record. Records to be kept at this source shall include the following:
Operator training
Consumption
VOC and/or HAPs emission records
Maintenance records
Emission inventory
Upset, breakdown episodes
(Condition number 4)
(Condition number 8)
(Condition number 12)
(Condition number 13)
(Condition number 14)
(Condition number 15)
The list above may not be a complete list of all records that are required to be kept by Metalcraft
Technologies, Inc. For a complete list ofrequired records check all AO conditions, and all applicable
Federal regulations such as NSPS, NESHAPS, and MACT standards that apply to this source.
Any future modifications to the equipment approved by this order must also be approved in accordance with
R307-401, UAC.
The executive secretary shall be notified in writing if the company is sold or changes its name. The
notification shall be submitted within 30 days of such action.
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.
A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting the
DAQ. The Utah Administrative Code R307 rules used by DAQ, the NOi guide, and other air quality
documents and forms may also be obtained on the Internet at the following web site:
http://www.eq.state.ut.us/eqair/aq_ home.htm
Annual emissions for this source (the entire plant) are currently calculated at the following values:
Pollutant Tons/yr
A. PM10 •••••••••••••••••••••••••••••••• 0.48
B. S02 •••••••••••••••••••••••••••••••• 1.00
C.. NOX ................................ 2.40
D. CO ................................. 0.41
E. voe .............................. 14.43
F. HAPs ............................... 3.69
HAPs consist of the following amounts in PoundsNear.
Chromium compounds . . . . . . . . . . 40.00
DAQE-937-99
Page 9
Ethyl benzene ................ 627.42
Ethylene glycol .............. 1,222.00
Hydrofluoric Acid . . . . . . . . . . . . . . . 6.41
Lead .......................... 0.22
Methyl ethyl ketone . . . . . . . . . . . 1,721.44
Methyl isobutyl ketone ........ 1,547.30
Methyl amul keytone . . . . . . . . . . . 112.38
Nickel oxide .................... 0.12
Potassium ferricyanide ........... 6.75
Toluene . . . . . . . . . . . . . . . . . . . . . 155.30
Triethylamine . . . . . . . . . . . . . . . . 555.50
Xylene ..................... 1,377.00
The annual emission estimations above are for the purpose of determining the applicability of Prevention of
Significant Deterioration, nonattainment area, maintenance area, and Title V source requirements of the UAC
R307. They are not to be used for purposes of determining compliance.
In accordance with the requirements of Title V of the 1990 Clean Air Act, actual emissions of regulated
pollutants maybe subject to operating permit fee as defined in UAC, R307-415. Emissions of the following
pollutants from all sources, including pre-November 29, 1969 sources, may be subject to the operating permit
fee. Both the fee rate and the class of pollutants are subject to change by the State of Utah, the federal
agencies, or both.
Pollutant Tons/yr
A. PM 10 ....•.•.••..•..•••••.••.... 0.48
B. SO2 ••••••••••••••••••••••••••• 1.00
C. NOX ........................... 2.40
D. voe ......................... 14.43
E. HAP ........................... 3.69
Approved By:
Ursula Kramer, Executive Secretary
Utah Air Quality Board
·• -
DAQE-937-99
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f\LE COP~
Appendix A
Subpart N-National Emission Standards for Chromium Emissions
From Hard and Decorative Chromium Electroplating and
Chromium Anodizing Tanks
Source: 60 F.R. 4948, Jan. 25, 1995, unless otherwise noted.
§ 63.340 Applicability and designation of sources.
(a) The affected source to which the provisions of this subpart apply is each chromium
electroplating or chromium anodizing
tank at facilities performing hard chromium electroplating, decorative chromium electroplating, or
chromium anodizing .
(b ) Owners or operators of affected sources subject to the provisions of this subpart must also
comply with the requirements
of subpart A of this part, according to the applicability of subpart A of this part to such
sources, as identified in Table 1 of this subpart.
(c) Process tanks associated with a chromium electroplating or chromium anodizing process, but
in which neither chromium
electroplating nor chromium anodizing is taking place, are not subject to the provisions of this
subpart . Examples of such
tanks include, but are not limited to, rinse tanks, etching tanks, and cleaning tanks. Likewise,
tanks that contain a chromium
solution, but in which no electrolytic process occurs, are not subject to this subpart . An example
of such a tank is a chrome
conversion coating tank where no electrical current is applied.
(d) Affected sources in which research and laboratory operations are performed are exempt from
the provisions of this subpart
when such operations are taking place.
(e) (1) The Administrator has determined, pursuant to the criteria under section 502(a) of the
Act, that an owner or operator of the following types of operations that are not by themselves major
sources and that are not located at major sources, as defined under 40 CFR 70.2, is permanently
exempt from title V permitting requirements for that operation:
(i) Any decorative chromium electroplating operation or chromium anodizing operation that uses
fume suppressants as an emission reduction technology; and
(ii) Any decorative chromium electroplating operation that uses a trivalent chromium bath that
incorporates a wetting agent as a bath ingredient.
(2) An owner or operator of any other affected source subject to the provisions of this subpart
is subject to title V permitting
requirements . These affected sources, if not major or located at major sources as defined under 40
CFR 70 .2, may be deferred by the applicable title V permitting authority from title V permitting
requirements for 5 years after the date on, which the EPA first approves a part 70 program (i .e. ,
until December 9,1999). All sources receiving deferrals shall submit title V permit applications
within 12 months of such date (by December 9, 2000). All sources receiving deferrals still must meet
the compliance schedule as stated in§ 63 .343 .
[Amended 61 FR 27785, June 3, 1996]
§ 63.341 Definitions and nomenclature.
(a) Definitions. Terms used in this subpart are defined in the Act, in subpart A of this part,
or in this section. For the purposes of subpart N of this part, if the same term is defined in
subpart A of this part and in this section, it shall have the meaning given in this section.
Add-on air pollution control device means equipment installed in the ventilation system of
chromium electroplating and anodizing tanks for the purposes of collecting and containing chromium
emissions from the tank(s).
DAQE-937-99
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Air pollution control technique means any method, such as an add-on air pollution control device
or a chemical fume suppressant, that is used to reduce chromium emissions from chromium
electroplating and chromium anodizing tanks.
Base metal means the metal or metal alloy that comprises the workpiece.
Bath component means the trade or brand name of each component(s) in trivalent chromium plating
baths . For trivalent chromium baths, the bath composition is proprietary in most cases. Therefore,
the trade or brand name for each component(s) can be used; however, the chemical name of the wetting
agent contained in that component must be identified.
Chemical fume suppressant means any chemical agent that reduces or suppresses fumes or mists at
the surface of an electroplating or anodizing bath; another term for fume suppressant is mist
suppressant.
Chromic acid means the common name for chromium anhydride (CrO3).
Chromium anodizing means the electrolytic process by which an oxide layer is produced on the
surface of a base metal for
functional purposes (e.g., corrosion resistance or electrical insulation) using a chromic acid
solution. In chromium anodizing,
the part to be anodized acts as the anode in the electrical circuit, and the chromic acid solution,
with a concentration
typically ranging from 50 to 100 grams per liter (g/L), serves as the electrolyte.
Chromium electroplating or chromium anodizing tank means the receptacle or container in which
hard or decorative chromium
electroplating or chromium anodizing occurs.
Composite mesh-pad system means an add-on air pollution control device typically consisting of
several mesh-pad stages. The
purpose of the first stage is to remove large particles . Smaller particles are removed in the second
stage, which consists of the composite mesh pad. A final stage may remove any reentrained particles
not collected by the composite mesh pad.
Decorative chromium electroplating means the process by which a thin layer of chromium (typically
0.003 to 2.5 microns) is
electrodeposited on a base metal, plastic, or undercoating to provide a bright surface with wear
and tarnish resistance. In
this process, the part(s) serves as the cathode in the electrolytic cell and the solution serves
as the electrolyte. Typical current
density applied during this process ranges from 540 to 2,400 Amperes per square meter (A/mf2) for
total plating times ranging
between 0.5 to 5 minutes.
Electroplating or anodizing bath means the electrolytic solution used as the conducting medium
in which the flow of current is
accompanied by movement of metal ions for the purposes of electroplating metal out of the solution
onto a workpiece or for oxidizing the base material.
Emission limitation means, for the purposes of this subpart, the concentration of total chromium
allowed to be emitted expressed in milligrams per dry standard cubic meter (mg/dscm), or the
allowable surface tension expressed in dynes per centimeter (dynes/cm).
Facility means the major or area source at which chromium electroplating or chromium anodizing
is performed.
Fiber-bed mist eliminator means an add-on air pollution control device that removes contaminants
from a gas stream through the mechanisms of inertial impaction and Brownian diffusion. These devices
are typically installed downstream of another control device, which serves to prevent plugging, and
consist of one or more fiber beds. Each bed consists of a hollow cylinder formed from two concentric
screens; the fiber between the screens may be fabricated from glass, ceramic plastic, or metal .
Foam blanket means the type of chemical fume suppressant that generates a layer of foam across
the surface of a solution
when current is applied to that solution.
Fresh water means water, such as tap water, that has not been previously used in a process
operation or, if the water has been recycled from a process operation, it has been treated and meets
the effluent guidelines for chromium wastewater.
Hard chromium electroplating or industrial chromium electroplating means a process by which a
thick layer of chromium (typically 1.3 to 760 microns) is electrodeposited on a base material to
provide a surface with functional properties such as wear resistance, a low coefficient of friction,
hardness, and corrosion resistance. In this process, the part serves as the cathode in the
electrolytic cell and the solution serves as the electrolyte. Hard chromium electroplating process
is performed at current densities typically ranging from 1,600 to 6,500 .A/mf2 for total plating times
ranging from 20 minutes to 36 hours depending upon the desired plate thickness.
DAQE-937-99
Page 12
Hexavalent chromium means the form of chromium in a valence state of +6.
Large, hard chromium electroplating facility means a facility that performs hard chromium
electroplating and has a maximum
cumulative potential rectifier capacity greater than or equal to 60 million ampere-hours per year
(amp-hr/yr}.
Maximum cumulative potenti al rectifier capacity means the summation of the total installed
rectifier capacity associated with the hard chromium electroplating tanks at a facility, expressed
in amperes , multiplied by the maximum potential operating schedule of 8 ,400 hours per year and 0 .7,
which assumes that electrodes are energized 70 percent of the total operating time. The maximum
potential operating schedule is based on operating 24 hours per day, 7 days per week, SO weeks per
year.
Operating parameter value means a minimum or maximum value established for a control device or
process parameter which,
if achieved by itself or in combination with one or more other operating parameter values,
determines that an owner or operator
is in continual compliance with t he applicable emission limitation or standard.
Packed-bed scrubber means an add-on air pollution control device consisting of a single or double
packed bed that contains
packing media on which the chromic acid droplets impinge . The packed-bed section of the scrubber
is followed by a mist eliminator to remove any water entrained from the packed-bed section.
Research or laboratory operation means an operation whose primary purpose is for research and
development of new processes
and products, that is conducted under the close supervision of technically trained personnel, and
that is not involved in the manufacture of products for commercial sale in commerce , except in a de
minimis manner.
Small, hard chromium electroplating facility means a facility that performs hard chromium
electroplating and has a maximum
cumulative potential rectifier capacity less than 60 million amp-hr/yr.
Stalagmometer means a device used to measure the surface tension of a solution.
Surface tension means the property, due to molecular forces, that exists in the surface film of
all liquids and tends to prevent l i quid from spreading.
Tank operation means the time in which current and/or voltage is being applied to a chromium
electroplating tank or a chromium anodizing tank.
Tensiometer means a device used to measure the surface tension of a solution .
Trivalent chromium means the form of chromium in a valence state of +3 .
Trivalent chromium process means the process used for electrodeposition of a thin layer of
chromium onto a base material using a trivalent chromium solution instead of a chromic acid solution.
Wetting agent means the type of chemical fume suppressant that reduces the surface tension of
a liquid.
(b) Nomenclature . The nomenclature used in this subpart has the following meaning:
(1) AMR=the allowable mass emission rate from each type of affected source subject to the same
emission limitation in milligrams per hour (mg/hr).
(2) AMRSYS=the allowable mass emission rate from affected sources controlled by an add-on air
pollution control device
controlling emissions from multiple sources in mg/hr.
(3) EL=the applicable emission limitation from§ 63 .342 in milligrams per dry standard cubic
meter (mg/dscm) .
(4) IATOTAL=the sum of all inl et duct areas from both affected and nonaffected sources in meters
squared.
(5) IDAI=the total inlet area for all ducts associated with affected sources in meters squared.
(6) IDAI,A=the total inlet duct area for all ducts conveying chromic acid from each type of
affected source performing the
same operation, or each type of affected source subject to the same emission limitation in meters
squared.
(7) VR=the total of ventilation rat es for each type of affected source subject to the same
emission limitation in dry standard
cubic meters per minute (dscm/min).
(8) VRINLET=the total ventilation rate from all i nlet ducts associated with affected sources in
dscm/min.
(9) VRINLET,A=the total ventilation rate from all inlet ducts convey ing chromic acid from each
type of affected source performing the same operation, or each type of affected source subject to
the same emission limitation in dscm/min.
DAQE-937-99
Page 13
(10) VRTOT=the average total ventilation rate for the three test runs as determined at the outlet
by means of the Method
306 in appendix A of this part testing in dscm/min.
§ 63 .342 Standards.
(a ) Each owner or operator of an affected source subject to the provisions of this subpart shall
comply with these requirements
on and after the compliance dates specified in§ 63 .343(a). All affected sources are regulated by
applying maximum achievable
control technology.
(b) Applicability of emission limits. (1) The emission limitations in this section apply only
during tank operation, and also apply during periods of startup and shutdown as these are routine
occurrences for affected sources subject to this subpart. The
emission limitations do not apply during periods of malfunction, but the work practice standards
that address operation and maintenance and that are required by paragraph (f) of this section must
be followed during malfunctions.
(2) If an owner or operator is controlling a group of tanks with a common add-on air pollution
control device, the emission
limitations of paragraphs (c), (d}, and (e) of this section apply whenever any one affected source
is operated . The emission
limitation that applies to the group of affected sources is:
(i} The emission limitation identified in paragraphs (cl, (d}, and (e) of this section if the
affected sources are performing the same type of operation (e .g., hard chromium electroplating},
are subject to the same emission limitation, and are not controlled
by an add-on air pollution control device also controlling nonaffected sources;
(ii} The emission limitation calculated according to § 63 .344 (e} (3) if affected sources are
performing the same type of operation, are subject to the same emission limitation, and are
controlled with an add-on air pollution control device that is also controlling nonaffected
sources; and
(iii} The emission limitation calculated according to§ 63.344(e} (4) if affected sources are
performing different types of operations, or affected sources are performing the same operations
but subject to different emission limitations, and are controlled with an add-on air pollution
control device that may also be controlling emissions from nonaffected sources .
(cl (1) Standards for hard chromium electroplating tanks. During tank operation, each owner or
operator of an existing,
new, or reconstructed affected source shall control chromium emissions discharged to the atmosphere
from that affected source
by not allowing the concentration of total chromium in the exhaust gas stream discharged to the
atmosphere to exceed:
(i) 0.015 milligrams of total chromium per dry standard cubic meter (mg/dscm) of ventilation air
(6 .6xl0 l-6 grains per dry
standard cubic foot [gr/dscf)}; or
(ii} 0.03 mg/dscm (l.3xl0l-5 gr/dscf) if the hard chromium electroplating tank is an existing
affected source and is located
at a small, hard chromium electroplating facility.
(2) (i} An owner or operator may demonstrate the size of a hard chromium electroplating facility
through the definitions
in § 63.34l(a}. Alternatively, an owner or operator of a facility with a maximum cumulative
potential rectifier capacity of 60
million amp-hr/yr or more may be considered small if the actual cumulative rectifier capacity is
less than 60 million amp-hr/yr
as demonstrated using the following procedures:
(Al If records show that the facility's previous annual actual rectifier capacity was less than
60 million amp-hr/yr, by using
nonresettable ampere-hr meters and keeping monthly records of actual ampere-hr usage for each
12-month rolling period following the compliance date in accordance with § 63. 346 (bl (12). The
actual cumulative rectifier capacity for the previous 12-month rolling period shall be tabulated
montr.ly by adding the capacity for the current month to the capacities for the previous 11 months ;
or
(B) By accepting a Federally-enforceabl e limit on the maximum cumulative potential rectifier
capacity of a hard chromium electroplating facility and by maintaining monthly records in accordance
with § 63 .346 (bl (12) to demonstrate that
DAQE-937-99
Page 14
the limit has not been exceeded. The actual cumulative rectifier capacity for the previous 12-month
rolling period shall be tabulated monthly by adding the capacity for the current month to the
capacities for the previous 11 months .
(ii) Once the monthly records required to be kept by§ 63.346(b) (12) and by this paragraph show
that the actual cumulative rectifier capacity over the previous 12-month rolling period corresponds
to the large designation, the owner or operator is subject to the emission limitation identified in
paragraph (c) (1) (i) of this section, in accordance with the compliance schedule of
§ 63 .343 (a) (5).
(d) Standards for decorative chromium electroplating tanks using a chromic acid bath and
chromium anodizing tanks . During
tank operation, each owner or operator of an existing, new, or reconstructed affected source shall
control chromium emissions
discharged to the atmosphere from that affected source by either:
(1) Not allowing the concentration of total chromium in the exhaust gas stream discharged to
the atmosphere to exceed 0 .01
mg/dscm (4.4xl0l-b gr/dscf); or
(2) If a chemical fume suppressant containing a wetting agent is used, by not allowing the
surface tension of the electroplating
or anodizing bath contained within the affected source to exceed 45 dynes per centimeter (dynes/cm)
(3.lxl0 l -3 pound-force per foot [lbF/ft]) at any time during operation of the tank .
(e ) Standards for decorative chromium electroplating tanks using a trivalent chromium bath. (1)
Each owner or operator
of an existing, new, or reconstructed decorative chromium electroplating tank that uses a trivalent
chromium bath that incorporates a wetting agent as a bath ingredient is subject to the recordkeeping
and reporting requirements of §§ 63 .346(b) (14) and 63.347(i), but are not subject to the work
practice requirements of paragraph
(f) of this section, or the continuous compliance monitoring requirements in§ 63.343(c). The
wetting agent must be an ingredient in the trivalent chromium bath components purchased from
vendors .
(2) Each owner or operator of an existing, new, or reconstructed decorative chromium
electroplating tank that uses a trivalent
chromium bath that does not incorporate a wetting agent as a bath ingredient is subject to the
standards of paragraph (d)
of this section.
(3) Each owner or operator of existing, new, or reconstructed decorative chromium electroplating
tank that had been using
a trivalent chromium bath that incorporates a wetting agent and ceases using this type of bath must
fulfill the reporting
requirements of § 63. 347 (i) (3) and comply with the applicable emission limitation within the
timeframe specified in § 63 .343 (a) (7).
(f ) Work practice standards . The work practice standards of this section address operation and
maintenance practices.
All owners or operators subject to the standards in paragraphs (c) and (d) of this section are
subject to these work practice
standards .
(1) (i) At all times, including periods of startup, shutdown, and malfunction, owners or operators
shall operate and maintain
any affected source, including associated air pollution control devices and monitoring equipment,
in a manner consistent with
good air pollution control practices, consistent with the operation and maintenance plan required
by paragraph (f) (3) of this section.
(ii) Malfunctions shall be corrected as soon as practicable after their occurrence in accordance
with the operation and
maintenance plan required by paragraph (f ) (3) of this section.
(iii) Operation and maintenance requirements established pursuant to section 112 of the Act are
enforceable independent
of emissions limitations or other requirements in r el evant standards.
(2) (i) Determination of whether acceptable operation and maintenance procedures are being used
will be based on information
available to the Administrator, which may include, but is not limited to, monitoring results; review
of the operation and
maintenance plan, procedures, and records; and inspection of the source.
DAQE-937-99
Page 15
(ii) Based on the results of a determination made under paragraph (f) (2) (i) of this section, the
Administrator may require that ·
an owner or operator o f an affected source make changes to the operation and maintenance plan
required by paragraph (f ) (3 )
of this section for that source . Revisions may be required i f the Administrator finds that the
plan:
(A) Does not address a malfunction that has occurred;
(B) Fails to provide for the operation of the affected source, the air pollution control
techniques, or the control sy stem
and process monitoring equipment during a malfunction in a manner consistent with good air
pollution control practices; or
{C) Does not provide adequate procedures for correcting malfunctioning process equipment, air
pollution control techniques, or monitoring equipment as quickly as practicable.
(3) Operation and maintenance plan.
(i) The owner or operator of an affected source subject to the work practices of this paragraph
{f) shall prepare an operation and maintenance plan to be implemented no later than the compliance
date. The plan shall be incorporated by reference into the source's title V permit, if and when
a title V permit is required. The plan shall include the following elements:
(A) The plan shall specify the operation and maintenance criteria for the affected source, the
add-on air pollution control
device {if such a device i s used to comply with the emission l imits), and the process and control
system monitoring equipment ,
and shall include a standardized checklist to document the operation and maintenance of this
equipment;
{B) For sources using an add-on air pollution control device or monitoring equipment to comply
with this subpart, the plan
shall incorporate the work practice standards for that device or monitoring equipment, as
identified in Table 1 of this section,
if the specific equipment used is identified in Table 1 of this section;
(C) If the specific equipment used is not identified in Table 1 of this section, the plan shall
incorporate proposed work
practice standards . These proposed work practice standards shall be submitted to the Administrator
for approval as part of the
submittal required under§ 63 .343 (d);
(D) The plan shall specify procedures to be followed to ensure that equipment or process
malfunctions due to poor maintenance or other preventable conditions do not occur; and
(E) The plan shall include a systematic procedure for identifying malfunctions of process
equipment, add-on air pollution control devices, and process and control system monitoring equipment
and for implementing correctiv e actions to address such malfunctions.
(ii) If the operation and maintenance plan fails to address or inadequately addresses an event
that meets the characteristics
of a malfunction at the time the plan is initially developed, the owner or operator shall revise
the operation and maintenance
plan within 45 days after such an event occurs . The revised plan shall include procedures for
operating and maintaining
the process equipment, add-on air pollution control device, or monitoring equipment during similar
malfunction events, and
a program for corrective action for such events.
(iii) Recordkeeping associated with the operation and maintenance plan is identified in§
63 .346 (b). Reporting associated with
the operation and maintenance plan is identified in§ 63 .347 (g) and (h) and paragraph (f) (3) (iv)
of this section .
(iv) If actions taken by the owner or operator during periods of malfunction are inconsistent
with the procedures specified
in the operation and maintenance plan required by paragraph (f) (3) (i) of this section, the owner
or operator shall record
the actions taken for that event and shall report by phone such actions within 2 working days after
commencing actions inconsistent with the plan. This report shall be followed by a letter within 7
working days after the end of the event, unless the owner or operator makes alternative reporting
arrangements, in advance, with the Administrator .
(v) The owner or operator shall keep the written operation and maintenance plan on record after
it is developed to be made
DAQE-937-99
Page 16
available for inspection, upon request, by the Administrator for the life of the affected source
or until the source is no longer subject to the provisions of this subpart . In addition, if the
operation and maintenance plan i s revised, the owner or operator shall keep previous (i.e.,
superseded) versions of the operation and maintenance plan on record to be made available for
inspection, upon request, by the Administrator for a period of 5 years after each revision to the
plan.
(vi) To satisfy the requirements of paragraph (f ) (3) of thi s section, the owner or operator may
use applicable standard operating
procedure (SOP) manuals , Occupational Safety and Health Administration (OSHA) plans, or other
existing plans, provided the alternative plans meet the requirements of this section.
(g) The standards in this section that apply to chromic acid baths shall not be met by using a
reducing agent to change the
form of chromium from hexavalent to trivalent .
[Amended 60 FR 33122, June 27, 1995; 61 FR 27785, June 3, 1996]
§ 63 .343 Compliance provisions .
(a) Compliance dates. (1) The owner or operator of an existing affected source shall comply with
the emission limitations in
§ 63 .342 as follows :
(i) No later than 1 year after January 25, 1995, if the affected source is a decorative chromium
electroplating tank; and
(ii) No later than 2 years after January 25, 1995, if the affected source is a hard chromium
electroplating tank or a chromium anodizing tank .
(2) The owner or operator of a new or reconstructed affected source that has an initial startup
after January 25, 1995, shall
comply immediately upon startup of the source. The owner or operator of a new or reconstructed
affected source that has an initial startup after December 16, 1993 but before January 25, 1995,
shall follow the compliance schedule of§ 63.6(b)
(1).
Table 1 to§ 63 .342 .-Summary of Work Practice Standards
Control technique
Frequency
· Composite mesh-pad (CMP) system ..
1. 1/quarter.
2 . 1/quarter.
3. 1/quarter.
Work practice standards
1 . Visually inspect device to ensure there is proper
drainage, no chronic acid buildup on the pads, and no
evidence of chemical attack on the structural integrity of
the device
2 . Visually i nspect back portion of the mesh pad closest to
the fan to e nsure there is no breakthrough of chromic acid
mist
j 3. Visually inspect ductwork from tank to the control device
to ensure there are no leaks
DAQE-937-99
Page 17
4 . Per manufacturer .
Packed-bed scrubber (PSB )
l . 1/quarter .
2. 1/quarter.
3 . 1
4 . Whenever makeup is added .
PBS/CMP system . . . . . . . . . . . . . . . . . . .
I 1 . 1/quarter.
2 . 1/quarter.
3 . 1/quarter.
4 . Per manufacturer.
Fiber-bed mist eliminator I 1 . 1/quarter.
2 . 1 /quarter.
3 . Per manufacturer .
{c } ....
I 4. Perform washdown of the composite mesh-pads in accordance
I with manufacturers recommendations
I
I 1 . Visually inspect device to ensure there is proper
I
drainage, no chromic acid buildup on the packed beds, and
no evidence of chemical attack on the structural integrity
of the device
2 . Visually inspect back portion of the chevron blade mist
eliminator to ensure that it is dry and there is no
breakthrough of chromic acid mist
3 . Same as number 3 above
4 . Add fresh makeup water to the top of the packed bed {a, b
1. Same as for CMP system ..................................
2. Same as for CMP system ..................................
3. Same as for CMP system ..................................
I 4 . Same as for CMP system
I 1 . Visually inspect fiber-bed unit and prefiltering device
t o ensure there is proper drainage, no chromic acid buildup
i n the units, and no evidence of chemical attack on the
structural integrity of the devices
2 . Visually inspect ductwork from tank or tanks to the
control device to ensure there are no leaks
I' 3 . Perform washdown of fiber elements in accordance with
manufacturers recommendations
Air pollution control device (APCD) I To be proposed by the source for approval by the
To be proposed by the source
no~ listed in rule.
for approval by the
Administrator.
Administrator
Monitoring Equipment
DAQE-937-99
Page 18
Pitot tube ...................... . I 1/quarter.
I
Stalagmometer
I
I Backflush with water, or remove from the duct and rinse with
fresh water. Replace in the duct and rotate 180 degrees to
ensure that the same zero reading is obtai~ed. Check pitot
tube ends for damage. Replace pitot tube if cracked or
fatigued
I Follow manufacturers recommendations ...................... .
{a} If greater than SO percent of the scrubber water is drained (e.g., for maintenance purposes),
makeup water may be added to
the scrubber basin.
{b} For horizontal-flow scrubbers, top is defined as the section of the unit directly above the
packing media such that the
makeup water would flow perpendicular to the air flow through the packing. For vertical-flow
units, the top is defined as the
area downstream of the packing material such that the makeup water would flow countercurrent to
the air flow through the unit .
(c} Work practice standards for the control device installed upstream of the fiber-bed mist
eliminator to prevent plugging do not
apply as long as the work practice standards for the fiber-bed unit are followed .
(3) The owner or operator of an existing area source that increases actual or potential emissions
of hazardous air pollutants
such that the area source becomes a major source must comply with the provisions for existing major
sources, including the
reporting provisions of§ 63.347(g), immediately upon becoming a major source.
(4) The owner or operator of a new area source (i .e ., an area source for which construction or
reconstruction was commenced
after December 16, 1993) that increases actual or potential emissions of hazardous air pollutants
such that the area source
becomes a major source must comply with the provisions for new major sources, immediately upon
becoming a major source.
(5) An owner or operator of an existing hard chromium electroplating tank or tanks located at
a small, hard chromium electroplating facility that increases its maximum cumulative potential
rectifier capacity, or its actual cumulative rectifier capacity, such that the facility becomes a
large, hard chromium electroplating facility must comply with the requirements of§ 63 .342(c) (1) (i)
for all hard chromium electroplating tanks at the facility no later than 1 year after the month in
which monthly records required by§§ 63.342(c) (2) and 63.346(b) (12) show that the large designation
is met, or by the compliance date specified in paragraph (a) (1) (ii) of this section, whichever is
later.
(6) Request for an extension of compliance . An owner or operator of an affected source or sources
that requests an extension
of compliance shall do so in accordance with this paragraph and the applicable paragraphs of§
63.6 (i). When the owner or
operator is requesting the extension for more than one affected source located at the facility, then
only one request may be
submitted for all affected sources at the facility.
(i) The owner or operator of an existing affected source who is unable to comply with a relevant
standard under this subpart may request that the Administrator (or a State, when the State has an
approved part 70 permit program and the source is required to obtain a part 70 permit under that
program, or a State, when the State has been delegated the authority to implement and enforce the
emission standard for that source) grant an extension allowing the owner or operator up to 1
additional year to comply with the standard for the affected source. The owner or operator of an
DAQE-937-99
Page 19
affected source who has requested an extension of compliance under this paragraph and is otherwise
required to obtain a title V permit for the source shall apply for such permit or apply to have the
title v permit revised to incorporate the conditions of the extension of compliance. The conditions
of an extension of compliance granted under this paragraph will be incorporated into the owner or
operator's title V permit for the affected source(s) according to the provisions of 40 CFR part 70
or 40 CFR part 71, whichever is applicable.
(ii) Any request under this paragraph for an extension of compliance with a relevant standard
shall be submitted in writing
to the appropriate authority not later than 6 months before the affected source's compliance date
as specified in this section.
(7) An owner or operator of a decorative chromium electroplating tank -that uses a trivalent
chromium bath that incorporates a
wetting agent, and that ceases using the trivalent chromium process, must comply with the emission
limitation now applicable
to the tank within 1 y ear of switching bath operation.
(b) Methods to demonstrate initial compliance. (1) Except as provided in paragraphs (b) (2) and
(b) (3) of this section, an owner or operator of an affected source subject to the requirements of
this subpart is required to conduct an initial performance
test as required under§ 63 .7, using the procedures and test methods listed in§ 63.7 and§ 63 .344 .
(2) If the owner or operator of an affected source meets all of the following criteria, an
initial performance test is
not required to be conducted under this subpart:
(i) The affected source is a decorative chromium electroplating tank or a chromium anodizing
tank; and
(ii) A wetting agent is used in the plating or anodizing bath to inhibit chromium emissions from
the affected source;
and
(iii) The owner or operator complies with the applicable surface tension limit of§ 63.342(d) (2)
as demonstrated through
the continuous compliance monitoring required by paragraph (c) (5) (ii) of this section.
(3) If the affected source is a decorative chromium electroplating tank using a trivalent
chromium bath, and the owner or operator is subject to the provisions of§ 63.342(e), an initial
performance test is not required to be conducted under this subpart .
(c) Monitoring to demonstrate continuous compliance. The owner or operator of an affected source
subject to the emission
limitations of this subpart shall conduct monitoring according to the type of air pollution control
technique that is used to comply with the emission limitation. The monitoring required to demonstrate
continuous compliance with the emission limitations is identified in this section for the air
pollution control techniques expected to be used by the owners or operators of
affected sources.
(1) Composite mesh-pad systems. (i) During the initial performance test, the owner or operator
of an affected source, or a group of affected sources under common control, complying with the
emission limitations in§ 63.342 through the use of a composite mesh-pad system shall determine the
outlet chromium concentration using the test methods and procedures in § 63. 344 (cl, and shall
establish as a site-specific operating parameter the pressure drop across the system, setting the
value that corresponds to compliance with the applicable emission limitation, using the procedures
in § 63 .. 344 (d) (5). An owner or operator may conduct multiple performance tests to establish a range
of compliant pressure drop values, or may set as the compliant value the average pressure drop
measured over the three test runs of one performance test and accept #1 inch of water column from
this
value as the compliant range.
(ii) On and after the date on which the initial performance test is required to be completed
under§ 63 .7, the owner or operator of an affected source, or group of affected sources under common
control, shall monitor and record the pressure drop across the composite mesh-pad system once each
day that .any affected source is operating. To be in compliance with the standards, the composite
mesh-pad system shall be operated within #1 inch of water column of the pressure drop value
established during the initial performance test, or shall be operated within the range of compliant
values for pressure drop established during multiple performance tests.
(2) Packed-bed scrubber systems. (i) During the initial performance test, the owner or operator
of an affected source, or group
of affected sources under common control, complying with the emission limitations in § 63 .342
through the use of a packed-
DAQE-937-99
Page 20
bed scrubber system shall determi ne the outlet chromium concentration using the procedures in§
63 .344 (c ), and shall establi s h as site-specific operating par ameters the pressure drop across the
system and the velocity pressure at the common inlet of the control device, setting the value that
corresponds to compliance with t he applicable emission limitation using the procedures in §
63 .344(d) (4) and (5). An owner or operator may conduct multi ple performance tests to establish a
range of compliant operating parameter values. Alternatively, the owner or operator may set as the
compliant value the average pressure drop and inlet velocity pressure measured over the three test
runs of one performance test, and accept #1 inch of water column from the pressure drop value.and
#10 percent from the velocity pressure value as the compliant range.
(ii) On and after the date on which the initial performance test is required to be completed
under§ 63 .7, the owner or operator of an affected source, or group of affected sources under common
control, shall monitor and record t he velocity pressure at the inlet to the packed-bed scrubber and
the pressure drop across the scrubber system once each day that any affected source is operating.
To be in compliance with the st andards, the scrubber system shall be operated within #10 percent of
the velocity pressure value establi shed during the i nitial performance test, and within #1 inch of
water column of the pressure drop value established during the initial performance test, or within
the range of compliant operating parameter values established during multiple performance tests.
(3) Packed-bed scrubber/composite mesh-pad system. The owner or operator of an affected source,
or group of affected sources under common control, that uses a packed-bed scrubber in conjunction
with a composite mesh-pad system to meet the emission limitations of§ 63 .342 shall comply with the
monitoring requirements for composite mesh-pad systems as identified in paragraph (c) (1) of this
section .
(4) Fiber-bed mist eliminator. (i) During the initial performance test, the owner or operator
of an affected source, or group
of affected sources under common control, complyi ng with the emission limitations in § 63 .342
through the use of a fiber-
bed mist eliminator shall determine the outlet chromium concentration using the procedures in§
63 .344(c), and shall establish as
a site-specific operating parameter the pressure drop across the fiber-bed mist eliminator and the
pressure drop across the control device installed upstream of the fiber bed to prevent plugging,
setting the value that corresponds to compliance with the applicable emission limitation using the
procedures in§ 63 .344(d) (5 ). An owner or operator may conduct multiple performance
tests to establish a range of compliant pressure drop values, or may set as the compliant value the
average pressure drop
measured over the three test runs of one performance test and accept# 1 inch of water column from
this value as the compliant
range .
(ii) On and after the date on which the initial performance test is required to be completed
under§ 63.7, the owner or operator of an affected source, or group of affected sources under common
control, shall monitor and record t he pressure drop across the fiber-bed mist eliminator, and the
control device installed upstream of the fiber bed to prevent plugging, once each day that any
affected source is operating . To be in compliance with the standards, the fiber-bed mist eliminator
and the upstream control device s hall be operated within# 1 inch of water column of the pressure
drop value established during the initial performance
test, or shall be operated within the range of compliant values for pressure drop established during
multiple performance tests.
(5) Wetting agent-type or combination wetting agent-type/foam blanket fume suppressants. (i)
During the initial performance
test, the owner or operator of an affected source complying with the emission limitations in§
63 .342 through the use of a wetting agent in the electroplating or anodizing bath shall determine
the outlet chromium concentration using the procedures
in§ 63 .344(c). The owner or operator shall establish as the site-specific operating parameter the
surface tension of the bath using Method 306B, appendix A of this part, setting the maximum value
that corresponds to compliance with the applicable emission
limitation. In lieu of establ ishing the maximum surface tension during t he performance test, the
owner or operator may accept 45
dynes/cm as the maximum surface t ension value that corresponds to compliance with the applicable
emission limitation. However, t he owner or operator is exempt from conducting a performance test only
if the criteria of paragraph (b ) (2) of this section are met.
(ii) On and after the date on which the initial performance test is required to be completed
under§ 63 .7, the owner or operator of an affected source shall monitor the surface tension of the
electroplating or anodizing bath. Operation of the a f fected source at a surface tension greater than
the value established during t he performance test , or greater than 45 dynes/cm if the owner or
DAQE-937-99
Page 21
operator is using this value in accordance with paragraph (c) (5) (i) of this section, shall constitute
noncompliance with the standards . The surface tension shall be monitored according to the following
schedule :
(A) The surface tension shall be measured once every 4 hours during operation of the tank with
a stalagrnometer or a tensiometer as specified in Method 306B, appendix A of this part.
(B) The time between monitoring can be increased if there have been no exceedances . The surface
tension shall be measured
once every 4 hours of tank operation for the first 40 hours of tank operation after the compliance
date . Once there are no exceedances during 40 hours of tank operation, surface tension measurement
may be conducted once every 8 hours of tank operation. Once there are no exceedances during 40 hours
of tank operation, surface tension measurement may be conducted once every 40 hours of tank operation
on an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring allowed by this
subpart is once every 40 hours of tank operation.
(C) Once an exceedance occurs as indicated through surface tension monitoring, the original
monitoring schedule of once
every 4 hours must be resumed. A subsequent decrease in frequency shall follow the schedule laid
out in paragraph (c) (5) (ii) (B)
of this section. For example, if an owner or operator had been monitoring an affected source once
every 40 hours and an exceedance occurs, subsequent monitoring would take place once every 4 hours
of tank operation. Once an exceedance does not occur for 40 hours of tank operation, monitoring can
occur once every 8 hours of tank operation. Once an exceedance does not occur for 40 hours of tank
operation on this schedule, monitoring can occur once every 40 hours of tank operation.
(iii) Once a bath solution is drained from the affected tank and a new solution added, the
original monitoring schedule of
once every 4 hours must be resumed, with a decrease in monitoring frequency allowed following the
procedures of paragraphs (cl (5) (ii) (Bl and (C) of this section.
(6) Foam blanket-type fume suppressants . (i) During the initial performance test, the owner or
operator of an affected source
complying with the emission limitations in§ 63.342 through the use of a foam blanket in the
electroplating or anodizing
bath shall determine the outlet chromium concentration using the procedures in§ 63.344(c), and
shall establish as the site-
specific operating parameter the thickness of the foam blanket, setting the minimum thickness that
corresponds to compliance
with the applicable emission limitation. In lieu of establishing the minimum foam blanket thickness
during the performance test,
the owner or operator may accept 2 .54 centimeters (1 inch) as the minimum foam blanket thickness
that corresponds to compliance with the applicable emission limitation. All foam blanket measurements
must be taken in close proximity to the workpiece or cathode area in the plating tank(s).
(ii) On and after the date on which the initial performance test is required to be completed
under§ 63.7, the owner or
operator of an affected source shall monitor the foam blanket thickness of the electroplating or
anodizing bath. Operation
of the affected source at a foam blanket thickness less than the value established during the
performance test, or less than
2.54 cm (1 inch) if the owner or operator i s using this value in accordance with paragraph (c) (6) (i)
of this section, shall
constitute noncompliance with the standards. The foam blanket thickness shall be measured according
to the following schedule :
(A) The foam blanket thickness shall be measured once every 1 hour of tank operation.
(B) The time between monitoring can be increased if there have been no exceedances. The foam
blanket thickness shall be
measured once every hour of tank operation for ·the first 40 hours of tank operation after the
compliance date. Once there are no exceedances for 40 hours of tank operation, foam blanket
thickness measurement may be conducted once every 4 hours of tank operation. Once there are no
exceedances during 40 hours of tank operation, foam blanket thickness measurement may be
conducted once every 8 hours of tank operation on an ongoing basis, until an exceedance occurs. The
minimum frequency of
monitoring allowed by this subpart is once per 8 hours of tank operation .
(C) Once an exceedance occurs as indicated through foam blanket thickness monitoring, the
original monitoring schedule of once every hour must be resumed. A subsequent decrease in frequency
shall follow the schedule laid out in paragraph (cl (6) (ii) (B) of this section. For example, if an
owner or operator had been monitoring an affected source once every 8 hours and an exceedance
DAQE-937-99
Page 22
occurs, subsequent monitoring would take place once every hour of tank operation. Once an exceedance
does not occur for 40 hours of tank operation, monitoring can occur once every 4 hours of tank
operation. Once an exceedance does not occur for 4 O hours of tank operation on this schedule,
monitoring can occur once every 8 hours of tank operation.
(iii) Once a bath solution is drained from the affected tank and a new solution added, the
original monitoring schedule of
once every hour must be resumed, with a decrease in monitoring frequency allowed following the
procedures of paragraphs (c) (6) (ii) (B) and (Cl of this section.
(7) Fume suppressant/add-on control device . (i) If the owner or operator of an affected source
uses both a fume suppressant
and add-on control device and both are needed to comply with the applicable emission limit,
monitoring requirements as identified in paragraphs (c) (1) through (6) of this section, and the work
practice standards of Table 1 of§ 63 .342, apply for each of the control techniques used.
(ii) If the owner or operator of an affected source uses both a fume suppressant and add-on
control device, but only one of these techniques is needed to comply with the applicable emission
limit, monitoring ·requirements as identified in paragraphs
(c) (1) through (6) of this section, and work practice standards of Table 1 of§ 63.342, apply only
for the control technique
used to achieve compliance.
(8) Use of an alternative monitoring method. (i ) Requests and approvals of alternative monitoring
methods shall be considered
in accordance with§ 63 .8(f) (1), (f) (3 ), (f) (4), and_ (f) (5).
(ii) After receipt and consideration of an application for an alternative monitoring method, the
Administrator may approve
alternatives to any monitoring methods or procedures of this subpart including, but not limited to,
the following:
(A) Alternative monitoring requirements when installation or use of monitoring devices specified
in this subpart would
not provide accurate measurements due to interferences caused by substances within the effluent
gases; or
(B) Alternative locations for installing monitoring devices when the owner or operator can
demonstrate that installation
at alternate locations will enable accurate and representative measurements .
(d) An owner or operator who uses an air pollution control device not listed in this section
shall submit a description
of the device, test results collected in accordance with§ 63.344(c) verifying the performance of
the device for reducing chromium emissions to the atmosphere to the level required by this subpart,
a copy of the operation and .maintenance plan referenced in § 63.342(f) including proposed work
practice standards, and appropriate operating parameters that will be monitored to establish
continuous compliance with the standards. The monitoring plan submitted identifying the continuous
compliance monitoring is subject to the Administrator's approval .
[Amended 60 FR 33122, June 27, 1995)
§ 63.344 Performance test requirements and test methods.
(a ) Performance test requirements . Performance tests shall be conducted using the test methods
and procedures in this section
and§ 63.7 . Performance test results shall be documented in complete test reports that contain the
information required by paragraphs (a) (1) through (a) (9) of this section. The test plan to be
followed shall be made available to the Administrator prior to the testing, if requested.
(1) A brief process description;
(2) Sampling location description(s);
(3) A description of sampling and analytical procedures and any modifications to standard
procedures;
(4) Test results;
(5) Quality assurance procedures and results;
(6) Records of operating conditions during the test, preparation of standards, and calibration
procedures;
(7) Raw data sheets for field sampling and field and laboratory analyses;
(8) Documentation of calculations; and
(9) Any other information required by the test method.
DAQE-937-99
Page 23
(b) (1) If the owner or operator of an affected source conducts performance testing at startup
to obtain an operating permit
in the State in which the affected source is located, the results of such testing may be used to
demonstrate compliance with this
subpart if:
(i) The test methods and procedures identified in paragraph (c) of this section were used during
the performance test;
(ii) The performance test was conducted under representative operating conditions for the
source;
(iii) The performance test report contains the elements require~ by paragraph (a) of this
section; and
(iv) The owner or operator of the affected source for which the performance test was conducted
has sufficient data to establish
the operating parameter value(s) that correspond to compliance with the standards, as required for
continuous compliance monitoring under§ 63.343(c).
(2) The results of tests conducted prior to December 1991 in which Method 306A, appendix A of
this part, was used to demonstrate the performance of a control technique are not acceptable.
(c) Test methods. Each owner or operator subject to the provisions of this subpart and required
by§ 63.343(b) to conduct an initial performance test shall use the test methods identified in this
section to demonstrate compliance with the standards in§ 63.342.
(1) Method 306 or Method 306A, ''Determination of Chromium Emissions From Decorative and Hard
Chromium Electroplating and Anodizing Operations, • ' appendix A of this part shall be used to
determine the chromium concentration from hard or decorative chromium electroplating tanks or
chromium anodizing tanks. The sampling time and sample volume for each run of Methods 306 and 306A,
appendix A of this part shall be at least 120 minutes and 1.70 dscm (60 dscf), respectively. Methods
306 and 306A, appendix A of this part allow the measurement of either total chromium or hexavalent
chromium emissions. For the purposes of this standard, sources using chromic acid baths can
demonstrate compliance with the emission limits of§ 63.342 by measuring either total chromium or
hexavalent chromium. Hence, the hexavalent chromium concentration measured by these methods is equal
to the total chromium concentration for the affected operations .
(2) The California Air Resources Board (CARB) Method 425 (which is available by contacting the
California Air Resources
Board, 1102 Q Street, Sacramento, California 95814) may be used to determine the chromium
concentration from hard and decorative chromium electroplating tanks and chromium anodizing tanks
if the following conditions are met:
(i) If a colorimetric analysis method is used, the sampling time and volume shall be sufficient
to result in 33 to 66 micrograms
of catch in the sampling train.
(ii) If Atomic Absorption Graphite Furnace (AAGF) or Ion Chromatography with a Post-column
Reactor (ICPCR) analyses were used, the sampling time and volume should be sufficient to result in
a sample catch that is 5 to 10 times the minimum detection limit of the analytical method (i.e., 1.0
microgram per liter of sample for AAGF and 0 .5 microgram per liter of sample for ICPCR).
(iii) In the case of either paragraph (c) (2) (i) or (ii) of this section, a minimum of 3 separate
runs must be conducted.
The other requirements of§ 63.7 that apply to affected sources, as indicated in Table 1 of this
subpart, must also be met .
(3) Method 306B, ··surface Tension Measurement and Recordkeeping for Tanks Used at Decorative
Chromium Electroplating and Anodizing Facilities,'' appendix A of this part shall be used to measure
the surface tension of electroplating and anodizing baths .
(4) Alternate test methods may also be used if the method has been validated using Method 301,
appendix A of this part
and if approved by the Administrator. Procedures for requesting and obtaining approval are contained
in § 6 3 . 7 ( f) .
(d) Establishing site-specific operating parameter values.
(1) Each owner or operator required to establish site-specific operating parameters shall follow
the procedures in this section.
(2) All monitoring equipment shall be installed such that representative measurements of
emissions or process parameters
from the affected source are obtained. For monitoring equipment purchased from a vendor,
verification of the operational status
of the monitoring equipment shall include execution of the manufacturer's written specifications
or recommendations for installation, operation, and calibration of the system.
DAQE-937-99
Page 24
(i) Specifications for differential pressure measurement devices used to measure velocity
pressure shall be in accordance
with section 2.2 of Method 2 (40 CFR part 60, appendix A).
(ii) Specification for differential pressure measurement devices used to measure pressure drop
across a control system
shall be in accordance with manufacturer's accuracy specifications.
(3) The surface tension of electroplating and anodizing baths shall be measured using Method
306B, -'Surface Tension Measurement and Recordkeeping for Tanks used at Decorative Chromium
Electroplating and Anodizing Facilities,'' appendix A of this part. This method should also be
followed when wetting agent type or combination wetting agent/foam blanket type fume suppressants
are used to control chromium emissions from a hard chromium electroplating tank and surface tension
measurement is conducted to demonstrate continuous compliance .
(4) The owner or operator of a source required to measure the velocity pressure at the inlet to
an add-on air pollution
control device in accordance with § 63 .343 (c) (2 ), shall establish the site-specific velocity
pressure as follows:
(i) Locate a velocity traverse port in a section of straight duct that connects the hooding on
the plating tank or tanks with the control device. The port shall be located as close to the control
system as possible, and shall be placed a minimum of 2 duct diameters downstream and 0.5 diameter
upstream of any flow disturbance such as a bend, expansion, or contraction (see Method 1, 40 CFR
part 60, appendix A). If 2 .5 diameters of straight duct work does not exist, locate the port 0.8 of
the duct diameter downstream and 0 .2 of the duct diameter upstream from any flow disturbance.
(ii) A 12-point velocity traverse of the duct to the control device shall be conducted along
a single axis according to Method
2 (40 CFR part 60, appendix A) using an S-type pitot tube; measurement of the barometric pressure
and duct temperature at each traverse point is not required, but is suggested. Mark the S-type pitot
tube as specified in Method 1 (40 CFR part 60, appendix A) with 12 points. Measure the velocity
pressure (•p) values for the velocity points and record. Determine the square root of the individual
velocity point •p values and average . The point with the square root value that comes closest to the
average square root value is the point of average velocity. The •p value measured for this point
during the performance test will be used as the reference for future monitoring.
(5) The owner or operator of a source required to measure the pressure drop across the add-on
air pollution control device
in accordance with§ 63 .343 (c ) (1) through (4) may establish the pressure drop in accordance with
the following guidelines:
(i) Pressure taps shall be installed at any of the following locations:
(A) At the inlet and outlet of the control system. The inlet tap should be installed in the
ductwork just prior to the control
device and the corresponding outlet pressure tap should be installed on the outlet side of the
control device prior to the bl ower
or on the downstream side of the blower;
(B) On each side of the packed bed within the control system or on each side of each mesh pad
within the control system;
or
(C) On the front side of the first mesh pad and back side of the last mesh pad within the control
system .
(ii) Pressure taps shall be sited at locations that are:
(A) Free from pluggage as possible and away from any flow disturbances such as cyclonic
demisters.
(B) Situated such that no air infiltration at measurement site will occur that could bias the
measurement.
(iii) Pressure taps shall be constructed of either polyethylene, polybutylene, or other
nonreactive materials.
(iv) Nonreactive plastic tubing shall be used to connect the pressure taps to the device used
to measure pressure drop .
(v) Any of the following pressure gauges can be used to monitor pressure drop: a magnehelic
gauge, an inclined manometer, or
a ··u•' tube manometer.
(vi) Prior to connecting any pressure lines to the pressure gauge (s ), each gauge should be
zeroed. No calibration of the
pressure gauges is required.
(e) Special compliance provisions for multiple sources controlled by a common add-on air
pollution control device .
DAQE-937-99
Page 25
(1) This section identifies procedures for measuring the outlet chromium concentration from an
add-on air pollution control
device that is used to control multiple sources that may or may not include sources not affected
by this subpart.
(2) When multiple affected sources performing the same type of operation (e .g., all are
performing hard chromium electroplating), and subject to the same emission limitation, are controlled
with an add-on air pollution control device that is not controlling emissions from any other type
of affected operation or from any nonaffected sources, the applicable emission limitation identified
in§ 63 .342 must be met at the outlet of the add-on air pollution control device .
(3 ) When multiple affected sources performing the same type of operation and subject to the same
emission limitation are
controlled with a common add-on air pollution control device that is also controlling emissions from
sources not affected
by these standards, the following procedures should be followed to determine compliance with the
applicable emission limitation in§ 63.342 :
(i) Calculat-e the cross-sectional area of each inlet duct (i.e., uptakes from each hood)
including those not affected
by the standard.
(ii) Determine the total sample time per test run by dividing the total inlet area from all tanks
connected to the control
system by the total inlet area for all ducts associated with affected sources, and then multiply
this number by 2 hours.
The calculated time is the minimum sample time required per test run.
(iii) Perform Method 306 testing and calculate an outlet mass emission rate.
(iv) Determine the total ventilation rate from the affected sources by using equation 1:
IDAj
VRtot X VRinlet (1)
E IAtotal
where VRtot is the average total ventilation rate in dscm/min for the three test runs as determined
at t he outlet by means of the Method 306 testing; IDAI is the total inlet area for all ducts
associated with affected sources; IAtotal is the sum of all inlet duct areas from both affected and
nonaffected sources; and VRinlet is the total ventilation rate from all inlet ducts associated with
affected sources.
(v) Establish the allowable mass emission rate of the system (AMRSYS) in milligrams of total
chromium per hour (mg/hr) using equation 2:
r VRinlet x EL x 60 minutes/hours AMRsys (2)
where i:: VRinlet is the total ventilation rate in dscm/min from the affected sources, and EL is the
applicable emission limitation
from§ 63.342 in mg/dscm. The allowable mass emission rate (AMRsys) calculated from equation 2
should be equal to or more than the outlet three-run average mass emission rate determined from
Method 306 testing in order for the source to be in compliance with the standard.
(4) When multiple affected sources performing different types of operations (e .g ., hard chromium
electroplating, decorative
chromium electroplating, or chromium anodizing) are controlled by a common add-on air pollution
control device that may or may not also be controlling emissions from sources not affected by these
standards, or if the affected sources controlled by
the common add-on air pollution control device perform the same operation but are subject to
different emission limitations
(e.g., because one is a new hard chromium plating t ank and one is an existing small, hard chromium
plating tank), the following
DAQE-937-99
Page 26
procedures should be followed to determine compliance with the applicable emission limitation in
§ 63 .342:
(i) Follow the steps outlined in paragraphs (e) (3) (i) through (el (3) (iii) of this section.
(ii) Determine the total ventilation rate for each type of affected source using equation 3:
IDAj
VRtot X VRinlet,a (3)
E IAtotal
where VRtot is the average total ventilation rate in dscm/min for the three test runs as determined
at the outlet by means of the Method 306 testing; IDAi,a is the total inlet duct area for all ducts
conveying chromic acid from each type of affected source performing the same operation, or each type
of affected source·subject to the same emission limitation; IAtotal is the sum of all duct areas from
both affected and nonaffected sources; and VRinlet ,a is the total ventilation rate from all inlet
ducts conveying chromic acid from each type of affected source performing the same operation, or each
type of affected source subject to the same emission limitation.
(iii) Establish the allowable mass emission rate in mg/hr for each type of affected source that
is controlled by the add-on air pollution control device using equation 4, 5, 6, or 7 as
appropriate :
VRhcl x ELhcl x 60 minutes/hour= AMRhcl (4)
VRhc2 x ELhc2 x 60 minutes/hour= AMRhc2 (5)
VRdc x ELdc x 60 minutes/hour AMRdc (6)
·VRca x ELca x 60 minutes/hour= AMRca (7)
where ''he'' applies to the total of ventilation rates for all hard chromium electroplating tanks
subject to the same emission
limitation, ''de'' applies to the total of ventilation rates for the decorative chromium
electroplating tanks, ''ca'' applies to the total of ventilation rates for the chromium anodizing
tanks , and EL is the applicable emission limitation from§ 63.342 in mg/dscm. There are two equations
for hard chromium electroplating tanks because different emission limitations may apply (e.g., a new
tank versus an existing, small tank).
(iv) Establish the allowable mass emission rate (AMR) in mg/hr for the system using equation 8,
including each type of affected source as appropriate:
AMRhcl + AMRhc2 + AMRcd + AMRca = AMRsys (8)
The allowable mass emission rate calculated from equation 8 should be equal to or more than the
outlet three-run average mass emission rate determined from Method 306 testing in order for the
source to be in compliance with the standards.
(5) Each owner or operator that uses the special compliance provisions of this paragraph to
demonstrate compliance with
the emission limitations of§ 63 .342 shall submit the measurements and calculations to support these
compliance methods with the notification of compliance status required by§ 63 .347(e).
(6) Each owner or operator that uses the special compliance provisions of this section to
demonstrate compliance with the emission limitations of§ 63.342 shall repeat these procedures if
a tank is added or removed from the control system regardless
of whether that tank is a nonaffected source. If the new nonaffected tank replaces an existing
nonaffected tank of the same size
and is connected to the control system through the same size inlet duct then this procedure does
not have to be repeated.
[Amended 61 FR 27785, June 3, 1996]
§ 63 .345 Provisions for new and reconstructed sources.
DAQE-937-99
Page 27
(a) This section identifies the preconstruction review requirements for new and reconstructed
affected sources that are subject
to, or become subject to, this subpart.
(b) New or reconstructed affected sources. The owner or operator of a new or reconstructed
affected source is subject to§ 63 .5 (a), (b)(l), (b)(5), (b)(6), and (f)(l), as well as the
provisions of this paragraph.
(1) After January 25 , 1995, whether or not an approved permit program is effective in the State
in which an affected source
is (or would be) located, no person may construct a new affected source or reconstruct an affected
source subject to this subpart,
or reconstruct a source such that it becomes an affected source subject to this subpart, without
submitting a notification of
construction or reconstruction to the Administrator. The notification shall contain the information
identified in paragraphs (b) (2) and (3) of this section, as appropriate.
(2) The notification of construction or reconstruction required under paragraph (b) (1) of this
section shall include:
(i) The owner or operator's name, title, and address;
(ii) The address (i .e . , physical location) or proposed address of the affected source if
different from the owner 's or operator's;
(iii) A notification of intention to construct a new affected source or make any physical or
operational changes to an affected
source that may meet or has been determined to meet the criteria for a reconstruction as defined
in§ 63.2;
(iv) An identification of subpart N of this part as the basis for the notification;
(v) The expected commencement and completion dates of the construction or reconstruction;
(vi) The anticipated date of (initial) startup of the affected source;
(vii) The type of process operation to be performed (hard or decorative chromium electroplating,
or chromium anodizing);
(viii) A description of the air pollution control technique to be used to control emissions from
the affected source, such
as preliminary design drawings and design capacity if an add-on air pollution control device is
used; and
(ix) An estimate of emissions from the source based on engineering calculations and vendor
information on control device efficiency, expressed in units consistent with the emission limits of
this subpart. Calculations of emission estimates should be in sufficient detail to permit assessment
of the validity of the calculations .
(3) If a reconstruction is to occur, the notification required under paragraph (b) (1) of this
section shall include the following
in addition to the information required in paragraph (b) (2) of this section:
(i) A brief description of the affected source and the components to be replaced;
(ii) A brief description of the present and proposed emission control technique, including the
information required by paragraphs (b) (2) (viii) and (ix) of this section;
(iii) An estimate of the fixed capital cost of the replacements and of constructing a comparable
entirely new source;
(iv) The estimated life of the affected source after the replacements; and
(v) A discussion of any economic or technical limitations the source may have in complying with
relevant standards or other
requirements after the proposed replacements. The discussion shall be sufficiently detailed to
demonstrate to the Administrator's
satisfaction that the technical or economic limitations affect the source's ability to comply with
the relevant standard and how they do so.
(vi) If in the notification of reconstruction, the owner or operator designates the affected
source as a reconstructed
source and declares that there are no economic or technical limitations to prevent the source from
complying with all relevant
standards or requirements, the owner or operator need not submit the information required in
paragraphs (b) (3) (iii) through
(v) of this section.
(4) The owner or operator of a new or reconstructed affected source that submits a notification
in accordance with paragraphs
(b) (1) through (3) of this section is not subject to approval by the-Administrator. Construction
or reconstruction is subject
only to notification and can begin upon submission of a complete notification.
DAQE-937-99
Page 28
(5) Submittal timeframes. After January 25, 1995, whether or not an•approved permit program is
effective in the State
in which an affected source is (or would be) located, an owner or operator of a new or reconstructed
affected source shall
submit the notification of construction or reconstruction required by paragraph (b) (1) of this
section according to the following
schedule:
(i) If construction or reconstruction commences after January 25, 1995, the notification shall
be submitted as soon as practicable before the construction or reconstruction is planned to
commence.
(ii) If the construction or reconstruction had commenced and initial startup had not occurred
before January 25, 1995,
the notification shall be submitted as soon as practicable before startup but no later than 60 days
after January 25, 1995 .
§ 63.346 RecordKeeping requirements .
(a) The owner or operator of each affected source subject to these standards shall fulfill all
recordkeeping requirements
outlined in this section and in the General Provisions to 40 CFR part 63, according to the
applicability of subpart A of
this part as identified in Table 1 of this subpart.
(b) The owner or operator of an affected source subject to the provisions of this subpart shall
maintain the following
records for such source:
(1) Inspection records for the add-on air pollution control device, if such a device is used,
and monitoring equipment,
to document that the inspection and maintenance required by the work practice standards of §
63.342(f) and Table 1 of§
63.342 have taken place. The record can take the form of a checklist and should identify the device
inspected, the date of inspection, a brief description of the working condition of the device during
the inspection, and any actions taken to correct deficiencies found during the inspection.
(2) Records of all maintenance performed on the affected source, the add-on air pollution control
device, and monitoring
equipment;
(3) Records of the occurrence, duration, and cause (if known) of each malfunction of process,
add-on air pollution control,
and monitoring equipment;
(4) Records of actions taken during periods of malfunction when such actions are inconsistent
with the operation and maintenance plan;
(5) Other records, which may take the form of checklists, necessary to demonstrate consistency
with the provisions of
the operation and maintenance plan required by§ 63.342(f) (3);
(6) Test reports documenting results of all performance tests;
(7) All measurements as may be necessary to determine the conditions of performance tests,
including measurements necessary
to determine compliance with the special compliance procedures of§ 63.344(e);
(8) Records of monitoring data required by§ 63 .343(c) that are used to demonstrate compliance
with the standard including
the date and time the data are collected;
(9) The specific identification (i.e., the date and time of commencement and completion) of each
period of excess emissions,
as indicated by monitoring data, that occurs during malfunction of the process, add-on air pollution
control, or monitoring
equipment;
(10) The specific identification (i.e., the date and time of commencement and completion) of each
period of excess emissions,
as indicated by monitoring data, that occurs during periods other than malfunction of the process,
add-on air pollution control, or monitoring equipment;
(11) The total process operating time of the affected source during the reporting period;
(12) Records of the actual cumulative rectifier capacity of hard chromium electroplating tanks
at a facility expended during each month of the reporting period, and the total capacity expended
DAQE-937-99
Page 29
to date for a reporting period, if the owner or operator is using the actual cumulative rectifier
capacity to determine facility size in accordance with § 63 .342 (c) (2);
(13) For sources using fume suppressants to comply with the standards, records of the date and
time that fume suppressants
are added to the electroplating or anodizing bath;
(14) For sources complying with§ 63.342(e), records of the bath components purchased, with the
wetting agent clearly identified as a bath constituent contained in one of the components;
(15) Any information demonstrating whether a source is meeting the requirements for a waiver of
recordkeeping or reporting
requirements, if the source has been granted a waiver under§ 63.l0(f); and
(16) All documentation supporting the notifications and reports required by§ 63.9, § 63.10, and
§ 63 .347 .
(c) All records shall be maintained for a period of 5 years in accordance with§ 63 .l0(b) (l").
§ 63 .347 Reporting requirements .
(a) The owner or operator of each affected source subject to these standards shall fulfill all
reporting requirements outlined in this section and in the General Provisions to 40 CFR part 63,
according to the applicability of subpart A as identified in Table 1 of this subpart. These reports
shall be made to the Administrator at the appropriate address as identified in§ 63.13 or to the
delegated State authority.
(1) Reports required by subpart A of this part and this section may be sent by U.S. mail, fax,
or by another courier.
(i) Submittals sent by U.S. mail shall be postmarked on or before the specified date.
(ii) Submittals sent by other methods shall be received by the Administrator on or before the
specified date.
(2) If acceptable to both the Administrator and the owner or operator of an affected source,
reports may be submitted
on electronic media.
(b) The reporting requirements of this section apply to the owner or operator of an affected
source when such source becomes
subject to the provisions of this subpart.
(c ) Initial notifications . (1) The owner or operator of an affected source that has an initial
startup before January 25, 1995, shall notify the Administrator in writing that the source is subject
to this subpart. The notification shall be submitted no later than 180 calendar days after January
25, 1995, and shall contain the following information:
(i) The name, title, and address of the owner or operator;
(ii) The address (i .e ., physical location) of each affected source;
(iii) A statement that subpart N of this part is the basis for this notification;
(iv) Identification of the applicable emission limitation and compliance date for each affected
source;
(v) A brief description of each affected source, including the type of process operation
performed;
(vi) For sources performing hard chromium electroplating, the maximum potential cumulative
potential rectifier capacity;
(vii) For sources performing hard chromium electroplating, a statement of whether the affected
source (s) is located at a small or a large, hard chromium electroplating facility and whether this
will be demonstrated through actual or maximum potential cumulative rectifier capacity;
(viii) For sources performing hard chromium electroplating tanks, a statement of whether the
owner or operator of an affected
source (s) will limit the maximum potential cumulative rectifier capacity in accordance with §
63.342 (c) (2) such that the hard
chromium electroplating facility is considered small; and
(ix) A statement of whether the affected source is located at a major source or an area source
as defined in§ 63.2.
(2) The owner or operator of a new or reconstructed affected source that has an initial startup
after January 25, 1995 shall
submit an initial notification (in addition to the notification of construction or reconstruction
required by§ 63.345(b) as
follows:
(i) A notification of the date when construction or reconstruction was commenced, shall be
submitted simultaneously with the notification of construction or reconstruction, if construction
or reconstruction was commenced before January 25, 1995;
DAQE-937-99
Page 30
(ii) A notification of the date when construction or reconstruction was commenced, shall be
submitted no later than 30 calendar days after such date, if construction or reconstruction was
commenced after January 25, 1995; and
(iii) A notification of the actual date of startup of the source shall be submitted within 30
calendar days after such date.
(d) Notification of performance test . (l ) The owner or operator of an affected source shall
notify the Administrator in writing
of his or her intention to conduct a performance test at least 60 calendar days before the test is
scheduled to begin to allow the Administrator to have an observer present during the test .
Observation of the performance test by the Administrator is
optional.
(2) In the event the owner or operator is unable to conduct the performance test as scheduled,
the provisions of § 63 . 7 (b) (2)
apply.
(e) Notification of compliance status. (l) A notification of compliance status is required each
time that an affected source becomes subject to the requirements of this subpart .
(2) If the State in which the source is located has not been delegated the authority to
i mplement the rule, each time a notification of compliance status is required under this part , the
owner or operator of an affected source shall submit to the Administrator a notification of
compliance status, signed by the responsible official (as defined in§ 63.2) who shall certify its
accuracy, attesting to whether the affected source has complied with this subpart. If the State has
been delegated the authority, the notification of compliance status shall be submitted to the
appropriate authority. The notification shall list for each affected source:
(i) The applicable emission limitation and the methods that were used to determine compliance
with this limitation;
(ii) If a performance test is required by this subpart, the test report documenting the results
of the performance test, which contains the elements required by§ 63.344(a), including measurements
and calculations to support the special compliance
provisions of§ 63 .344(e} if these are being followed;
(iii} The type and quantity of hazardous air pollutants emitted by the source reported in mg/dscm
or mg/hr if the source is
using the special provisions of§ 63 .344(e} to comply with the standards . (If the owner or operator
is subject to the construction
and reconstructi on provisions of§ 63 .345 and had previously submitted emission estimates, the owner
or operator shall state
that this report corrects or verifies the previous estimate.} For sources not required to conduct
a performance test in accordance
with§ 63 .343(b), the surface tension measurement may fulfill this requirement;
(iv} For each monitored parameter for which a compliant value is to be established under§
63 .343(c), the specific operating
parameter value, or range of values, that corresponds to compliance with the applicable emission
limit;
(v) The methods that will be used to determine conti nuous compliance, including a description
of monitoring and reporting
requirements, if methods differ from those identifi ed in this subpart ;
(vi} A description of the air pollution control technique for each emission point;
(vii} A stateme~t that the owner or operator has completed and has on file the operation and
maintenance plan as required
by the work practice standards in§ 63 .342 (f };
(viii} If the owner or operator is determining facility size based on actual cumulative rectifier
capacity in accordance
with§ 63 .342 (c ) (2), records to support that the facili ty is small. For existing sources, records
from any 12-month period
preceding the compliance date shall be used or a description of how operations will change to meet
a small designation shall
be provided. For new sources, records of projected rectifier capacity for the first 12-month period
of tank operation shall
be used;
(ix} A statement by the owner or operator of the a f fected source as to whether the source has
complied with t he prov isions
of this subpart .
(3) For sources required to conduct a performance test by§ 63.343(b), the notification of
compliance status shall be
DAQE-937-99
Page 31
submitted. to the Administrator no later t han 90 calendar day s following completion of the compliance
demonstration required
by§ 63 .7 and§ 63 .343 (b).
(4) For sources that are not requi red to complete a performance test in accordance with§
63 .343 (b), the notification of compliance status s hall be submitted to the Administrator no later
than 30 days after the compliance date specified in §63 .343 (a ).
(f ) Reports of performance test results.
(1) If the State in which the source i s located has not been delegated the authority to implement
the rule, the owner or operator of an affected source shall report to the Administrator the results
of any performance test conducted as required by § 63 .7 or§ 63 .343(b). If the State has been
delegated the authority, t he owner or operator of an affected source should report performance test
results to the appropriate authority .
(2) Reports of performance test resul ts shall be submitted no later than 90 days following the
completion of the performance
test, and shall be submitted as part of the notification of compliance status required by paragraph
(e) of this section.
(g) Ongoing compliance status reports for major sources.
(1) The owner or operator of an affected source that is located at a major source site shall submit
a summary report to the
Admi nistrator to documenc Che ongoing compliance status of the affected source . The report shall
contain the information identifi ed in paragraph (g) (3) of this section, and shall be submitted
semiannually except when :
(i) The Administrator determines o n a case-by-case basis that more frequent reporting is
necessary to accurately assess
the compliance status of the source ; or
(ii) The monitoring data collected by the owner or operator of the affected source in accordance
with§ 63.343(c) show that
the emission limit has been exceeded, in which case quarterly reports shall be submitted . Once an
owner or operator of an
affected source reports an exceedance, ongoing compliance status reports shall be submitted
quarterly until a request to reduce
reporting frequency under paragraph (g) (2) of this section is approved .
(2) Request to reduce frequency of ongoing compliance status reports . (i) An owner or operator
who is required to submit
ongoing compliance status reports on a quarterly (or more frequent basis) may reduce the frequency
of reporting to semiannual if
all of the following conditions are met :
(A) For 1 full year (e .g ., 4 quarterly or 12 monthly reporting periods), the ongoing compliance
status reports demonstrace
that the affected source i s in compliance with the relevant emission limit;
(B) The owner or operator continues to comply with all applicable recordkeeping and monitoring
requirements of subpart A of this part a n d this subpart; and
(C) The Administrator does not object to a reduced reporting frequency for the affected source,
as provided in paragraphs
(g) (2) (ii) and (iii) of this section.
(ii) The frequency of submitting ongoi ng compliance status r eports may be reduced only after the
owner or operator notifies
the Administrator in writing of his or her intenti on to make such a change, and the Administrator
does not objecc to the
intended change. In decidi ng whether to approv e a reduced reporting frequency, the Administrator
may review information concerning the source's entire previous performance history during the 5-year
recordkeeping period prior to the intended change, or the recordkeeping period since the source's
compliance date, whichever is shorter. Records subject to review may include
performance test results , monitoring data, and eval uations of an owner or operator's conformance
with emission limitations
and work practice standards . Such information may be used by the Administrator to make a judgment
about the source 's potenti a l for noncompliance in the future . I f the Administrator disapproves the
owner or operator's request t o reduce reporting frequency , the Administrator will notify the owner
or operator in writing wi t hin 45 days after receiv ing notice of the owner or operator's intention .
The notification from the Administrator to the owner or operator will specify the grounds on which
the di sapproval is based. In the absence of a notice of disapproval within 45 days, approval is
automatically granted .
DAQE-937-99
Page 32
(iii) As soon as the monitoring data required by§ 63.343(c) show that the source is not in
compliance with the relevant
emission limit, the frequency of reporting shall revert to quarterly, and the owner shall state this
exceedance in the ongoing compliance status report for the next reporting period. After demonstrating
ongoing compliance with the relevant emission limit for another full year, the owner or operator may
again request approval from the Administrator to reduce the reporting frequency as allowed by
paragraph (g) (2) of this section.
(3) Contents of ongoing compliance status reports. The owner or operator of an affected source
for which compliance monitoring is required in accordance with§ 63 .343(c) shall prepare a summary
report to document the ongoing compliance status of the source.
The report must contain the following information:
(i) The company name and address of the affec~ed source;
(ii) An identification of the operating parameter that is monitored for compliance determination,
as required by§ 63 .343(c);
(iii) The relevant emission limitation for the affected source, and the operating parameter
value, or range of·values, that
correspond to compliance with this emission limitation as specified in the notification of
compliance status required by paragraph (e) of this section;
(iv) The beginning and ending dates of the reporting period;
(v) A description of the type of process performed in the affected source;
(vi) The total operating time of the affected source during the reporting period;
(vii) If the affected source is a hard chromium electroplating tank and the owner or operator
is limiting the maximum cumulative rectifier capacity in accordance with§ 63.342(c) (2), the actual
cumulative rectifier capacity expended during the reporting period, on a month-by-month basis;
(viii) A summary of operating parameter values, including the total duration of excess emissions
during the reporting
period as indicated by those values, the total duration of excess emissions expressed as a percent
of the total source operating
time during that reporting period, and a breakdown of the total duration of excess emissions during
the reporting period into
those that are due to process upsets, control equipment malfunctions, other known causes, and
unknown causes;
(ix) A certification by a responsible official, as defined in§ 63.2, that the work practice
standards in§ 63.342(f) were
followed in accordance with the operation and maintenance plan for the source;
(x) If the operation and maintenance plan required by § 63.342(f) (3) was not followed, an
explanation of the reasons for not following the provisions, an assessment of whether any excess
emission and/or parameter monitoring exceedances are believed to have occurred, and a copy of the
report(s) required by§ 63 .342 (f ) (3) (iv) documenting that the operation and maintenance plan was not
followed;
(xi) A description of any changes in monitoring, processes, or controls since the last reporting
period;
(xii) The name, title, and signature of the responsible official who is certifying the accuracy
of the report; and
(xiii) The date of the report.
(4) When more than one monitoring device is used to comply with the continuous compliance
monitoring required by§ 63.343 (c), the owner or operator shall report the results as required for
each monitoring device. However, when one monitoring device is used as a backup for the primary
monitoring device, the owner or operator shall only report the results from the monitoring device
used to meet the monitoring requirements of this subpart. If both devices are used to meet these
requirements, then the owner or operator shall report the results from each monitoring device for
the relevant compliance period.
(h) Ongoing compliance status reports for area sources. The requirements of this paragraph do
not alleviate affected area
sources from complying with the requirements of State or Federal operating permit programs under
40 CFR part 71.
(1) The owner or operator of an affected source that is located at an area source site shall
prepare a summary report to document the ongoing compliance status of the affected source. The report
shall contain the information identified in paragraph (g) (3) of this section, shall be completed
annually and retained on site, and made available to the Administrator upon request.
The report shall be completed annually except as provided in paragraph (h) (2) of this section.
(2) Reports of exceedances. (i ) If both of the following conditions are met, semiannual reports
shall be prepared and submitted to the Administrator:
DAQE-937-99
Page 33
(A) The total duration of excess emi ssions (as indicated by the monitoring data collected by
the owner or operator of the affected source i n accordance with§ 63 .343 (c)) is 1 percent or greater
of the total operating time for the reporting period;
and
(Bl The total duration of malfunctions of the add-on air pollution control device and monitoring
equipment is 5 percent
or greater of the total operating time.
(ii) Once an owner or operator of an af fected source reports an exceedance as defined in paragraph ·
(h) (2) (i ) of this section,
ongoing compliance status reports shall be submitted semiannually until a request to reduce
reporting frequency under paragraph
(h) (3) of this section is approved.
(iii) The Administrator may determine on a case-by-case basis that the summary report shall be
completed more frequently and
submitted, or that the annual report shall be submitted instead of being retained on site, if these
measures are nece~sary to
accurately assess the compliance status of t he source .
(3) Request to reduce frequency of ongoing compliance status reports . (i) An owner or operator
who is required to submit
ongoing compliance status reports on a semiannual (or more frequent) basis, or is required to
submit i ts annual report instead of
retaining it on site, may reduce the frequency of reporting to annual and/or be allowed to maintain
the annual report onsite
if all of the following conditions are met:
(A) For 1 full year (e.g., 2 semiannual or 4 quarterly reporting periods), the ongoing compliance
status reports demonstrate
that the affected source is in compliance wi th the relevant emission limit ;
(Bl The owner or operator continues to comply with all applicable recordkeeping and monitoring
requirements of subpart A of this part and this subpart ; and
(Cl The Administrator does not object to a reduced reporti ng frequency for t he affected source,
as provided in paragraphs
(h) (3 ) (ii) and (iii) of this section.
(ii) The frequency of submitting ongoing compliance status reports may be reduced only after the
owner or operator notifies
the Administrator in writing of his or her i ntention to make such a change, and the Administrator
does not object to the intended change. In deci ding whether to approve a reduced reporting
frequency, the Administrator may rev iew information concerning
the source's previous performance hist ory during the 5-year recordkeeping period prior to the
intended change, or the recordkeeping per i od since the source's compliance date, whichever is
shorter. Records subject to review may incl ude performance test results, monitoring data, and
evaluations of an owner or operator's conformance with emission limitations and work practice
standards . such information may be used by t he Administrator to make a judgement about the source 's
potential for noncompliance in the future . If the Administrator disapproves the owner or operator's
request to reduce reporting frequency, the Administrator will notify the owner or operator in writing
within 45 days after receiving notice of the owner or operator's intention. The notification from
the Administrator to the owner or operator will specify the grounds on which the disapproval is
based. In the absence of a notice of disapproval within 45 days, approv al is automatically granted.
(iii) As soon as the monitoring data required by§ 63.343(c) show that t he source is not in
compliance with the relevant
emission limit, the frequency of reporting shall revert to semiannual, and the owner shall state
this exceedance in the ongoing compliance status report for the next reporting period. After
demonstrating ongoing compliance wi th the relevant emission limit for another f u ll year, the owner
or operator may again request approv al f r om t he Administrator to reduce the reporting frequency as
allowed by paragraph (h) (3) of this section .
(i ) Reports associated with trivalent chromium baths. The requirements of this paragraph do not
alleviate affected sources
from complying with the requirements of State or Federal operating permit programs under title V.
Owners or operators complying with the provisions of§ 63.342(e) are not subject to paragraphs (a)
through (h) of this section, but must instead submit the following reports:
(1) Within 180 days after January 25, 1995, submit an initial notification that includes:
(i ) The same information as is required by paragraphs (c ) (1) (i) through (v) of this section;
and
DAQE-937-99
Page 34
(ii) A statement that a trivalent chromium process that incorporates a wetting agent will be used
to comply with§ 63 .342 (e ); and
(iii) The list of bath components that comprise the trivalent chromium bath, with the wetcing
agent clearly identified; and
(2) Within 30 days of the compliance date specifi ed in§ 63.343(a), a notification of compliance
status that contains
an update of the information submitted in accordance with paragraph (i) (1) of this section or a
statement t hat the information is
still accurate; and
(3) Within 30 days of a change to the trivalent chromium electroplating process, a report that
includes :
( i) A description of the manner in which the process has been changed and the emission
limitation, if any, now applicable
to the affected source;
(ii) If a different emission limitation applies, the applicable information required by paragraph
(c) (1 ) of this section; and
(iii) The notification and reporting requirements of paragraphs (d), (e), (f), (g), and (h) of
this section, which shall be
submitted in accordance with the schedules identifi ed in those paragraphs.
[Amended 61 FR 27785, June 3, 1996)
+
+Table 1 to Subpart N of Part 63 .-General Provisions Applicabi lity
+ to Subpart N
+
+
+
General provisions reference
+63 .l (a) (1 )
+
+
+
+63 .l (a) (2 )
+63.l (a) (3)
+63 .l (a) (4 )
+
+
+
+63 .l (a) (6)
+63 .l (a ) (7)
+63 .l (a ) (8)
+63 .l (a) (10) ..................... .
+63 .1 (a ) (11) ..................... .
+
+
+63.l (a )(l2)-(14) ................ .
+63.l (b) (1) ...................... .
+
+63 .l (b) (2)
+63.l (b) (3)
+
+
+
+
+63 .l (c ) (1)
+
+
+
+63 .l (c ) (2 )
+
+63.l (c ) (4 )
+63 .l (c ) (5 )
Applies to
subpart N
Yes ............ .
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No ............. .
Yes
No ............. .
Yes ............ .
Yes
Yes
No ............. .
Comment
Additional terms defined in§
63 .341; when overlap between
subparts A and N occurs, subpart
N takes precedence.
Subpart N clarifies the
applicability of each paragraph
in subpart A to sources subject
to subpart N.
§ 63 .347(a) of subpart N also
allows report submissions via fax
and on electronic media.
§ 63 .340 of subpart N specifies
applicability.
This provision in subpart A is
being deleted. Also, all affected
area and major sources are
subject to subpart N; there are
no exemptions.
Subpart N clarifies the
applicability of each paragraph
in subpart A to sources subject
to subpart N.
Subpart N specifies permit
requirements for area sources .
Subpart N clarifies that an area
DAQE-937-99
Page 35
+
+
+
+63 .l (e )
+63.2
+
+
+
+63 .3
+
+63. 4 ............................ .
+63.5(a) ......................... .
+
+
+
+63.5(b) (1)
+63 .5 (b)(3)
+
+63.5 (b)(4)
+
+
+
+
+63.5 (b) (5) ...................... .
+63.5(b)(6) ...................... .
+63. 5 (d) (1) (il ................... .
+
+
+63 .5(dl (1) (ii)
+
+63. 5 (d) (1) (iii)
+
+
+
+63. 5 (d} (2)
+
+
+
+
+
+
+
+
+63.5(d) (3)-(4)
+
+63.5 (e) ......................... .
+
+63. 5 (fl (ll
+
+
+63.5 (f)(2)
+
+
+
+
+
+
+63.6 (a) ......................... .
+63.6(b) (1)-(2) .................. .
+
+
+63.6(b) (3)-(4) .................. .
+63.6(b} (5) ...................... .
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No ............. .
Yes
Yes
No ............. .
Yes
Yes
Yes ............ .
Yes
Yes
Yes
No ............. .
Yes
Yes
Yes
Yes
source that becomes a major
source is subject to the
requirements for major sources.
Additional terms defined in§
63.341; when overlap between
subparts A and N occurs, subpart
N takes precedence.
Other units used in subpart N are
defined in that subpart.
Except replace the term ''source''
and ''stationary source'' in§
63.S(a) (ll and (2) of subpart A
with ''affected sources.''
Applies only to major affected
sources .
Subpart N (§ 63 .345) specifies
requirements for the notification
of construction or reconstruction
for affected sources that are not
major.
§ 63.345 (c} (5) of subpart N
specifies when the application or
notification shall be submitted.
Applies to major affected sources
that are new or reconstructed .
Except information should be
submitted with the Notification
of Compliance Status required by
§ 63.347(e} of subpart N.
Applies to major affected sources
that are new or reconstructed
except: (1) replace ''source'' in
§ 63.5 (d) (2) of subpart A with --
affected source''; and (2) actual
control efficiencies are
submitted with the Notification
of Compliance Status required by
§ 63.347(e}.
Applies to major affected sources
that are new or reconstructed.
Applies to major affected sources
that are new or reconstructed.
Except replace ''source'' in§
63.5(f) (1) of subpart A with
affected source.''
New or reconstructed affected
sources shall submit the request
for approval of construction or
reconstruction under§ 63.5(f} of
subpart A by the deadline
specified in§ 63.345 (c ) (5) of
subpart N.
Except replace ''source'' in§
63 .6(b) (1 )-(2) of part A with
affected source.''
Except replace ''source'' in§
DAQE-937-99
Page 36
+
+
+63 .6(b)(7)
+
+
+
+63 .6 (c) (1)-(2)
+
+
+63 .6 (c) (5)
+
+
+
+63.6(e)
+
+
+
+
+63.6(f) (1)
+
+63. 6 (f) (2) (i) -(ii) .............. .
+61.6(f) (2) (iii) ................. .
+
+
+
+63 . 6 (fl (2) (iv)
+63.6(f}(2)(v) ................... .
+63.6(f)(3) ·······················
+63.6(g)
+63. 6 (h )
+
+
+63 .6(i) (1)
+63.6(i) (2)
+
+
+63 .6(i) (3)
+63.6(i) (4) (i)
+
+
+
+
+63.6(i) (4) (ii) .................. .
+63 .6(i) (5)
+63. 6 (i} (6) (i)
+
+
+
+
+
+
+63. 6 (i) (6) (ii)
+63.6(i) (7) ...................... .
+63.6(i} (8) ...................... .
+
+
+
+
+
+
+63 .6(i)(9)
+
+
No ............. .
Yes ............ .
No ............. .
No ............. .
No ............. .
Yes
No ............. .
Yes
Yes
Yes
Yes
No ............. .
Yes
Yes
Yes
No ...........•••
Yes
Yes
Yes
Yes
Yes
Yes
Yes ............ .
63. 6 (b) (5) of subpart A with "
affected source.''
Provisions for new area sources
that become major sources are
contained in § 63 .343 (a) (4) of
subpart N.
Except replace ··source'' in§
63. 6 (c) (1) -(2) of subpart A with
''affected source.''
Compliance provisions for existing
area sources that become major
sources are contained in§ 63 .343
(a) (3) of subpart N.
§ 63.342(f) of subpart N contains
work practice standards
(operation and maintenance
requirements) that override these
provisions.
§ 63.342(b) of subpart N specifies
when the standards apply.
§ 63.344(b) of subpart N specifies
instances in which previous
performance test results for
existing sources are acceptable .
Subpart N does not contain any
opacity or visible emission
standards .
Except replace ··source'' in§
63.6(i) (2) (i) and (ii) of subpart
A with ''affected source .''
§ 63 .343 (a) (6) of subpart N
specifies the procedures for
obtaining an extension of
compliance and the date by which
such requests must be submitted.
This paragraph only references --
paragraph (i) (4) of this section'
' for compli ance extension
provisions. But,§ 63 .343(a)(6)
of subpart N also contains
provisions for requesting a
compliance extension.
This paragraph only references --
paragraphs (i) (4) through (i) (6)
of this section'' for compliance
extension provisions . But, §
63.343(a) (6) of subpart N also
contains provisions for
requesting a compliance extension.
This paragraph only references--·
paragraphs ( i) ( 4) through ( i) ( 6)
of this section'' and --
DAQE-937-99
Page 37
+
+
+
+
+
+
+63 .6 (i) (10) (i) -(iv) ............. .
+63 . 6 (i ) (10) (v) (A) ............... .
+
+
+
+
+
+63 .6 (i) (10) (v) (B)
+63 .6 (i) (11) ..................... .
+63.6 (i) (12) (i)
+
+
+
+
+
+
+63 .6 (i) (12) (ii) -(iii)
+63.6 (i) (13)
+63 .6 (i) (14) ..................... .
+63 .6 (i) (16) ..................... .
+63.6 (j ) ......................... .
+63 .7(a) (1) ...................... .
+63. 7 (a) (2) (i) -(vi) .............. .
+63 . 7 (a) (2) (ix) .................. .
+63. 7 (a) (3)
+63 . 7 (b) (1)
+
+
+
+
+
+63. 7 (bl (2)
+63.7 (c)
+
+
+
+
+63.7(d)
+
+
+
+63 .7 (e)
+
+
+63.7 (f)
+
+
+
+63 . 7 (g) (1)
+
+
+
+
+63 .7 (g)(3 ) ·······················
+63 .7 (h)(l)-(2) .................. .
+63 .7 (h) (3) (i) ................... .
+
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No ............•.
Yes
No ............. .
Yes ............ .
Yes ............ .
Yes ............ .
No ....•.........
Yes
Yes
Yes
paragraphs (i) (4) and (i) (5) of
this section'' for compliance
extension provisions. But, §
63 .343 (a) (6) of subpart N also
contains provisions for
requesting a compliance extension.
This paragraph only references-,
paragraph (i) (4) '' for compliance
extension provisions. But, §
63.343(a) (6) of subpart N also
contains provisions for
requesting a compliance extension.
This paragraph only references
paragraph (i) (4) (i) or (i) (5) of
this section'' for compliance
extension provisions. But, §
63 .343(a) (6) of subpart N also
contains provisions for
requesting a compliance extension.
§ 63.347(d) of subpart N requires
notification prior to the
performance test. § 63.344(a) of
subpart N requires submission of
a site-specific test plan upon
request.
§ 63.344(a) of subpart N specifies
what the test plan should contain,
but does not require test plan
approval or performance audit
samples.
Except replace ''source'' in the
first sentence of§ 63.7(d) of
subpart A with ''affected source.
Subpart N also contains test
methods specific to affected
sources covered by that subpart.
§ 63 .344 (cl (2) of subpart N
identifies CARB Method 425 as
acceptable under certain
conditions.
Subpart N identifies the items to
be reported in the compliance
test [§ 63 .344(a)J and the
timeframe for submitting the
results [§ 63 .347 (f )].
This paragraph only references''§
63 .6(i) '' for compliance
DAQE-937-99
Page 38
+
+
+
+
+63 . 7 (h ) (3) (ii) -(iii) ............ .
+63 .7 (h )(4)-(5) .................. .
+63 .B(a ) (1 )
+63 .B(a ) (2)
+
+
+63 .B(a ) (4)
+63 .B(b ) (1 )
+63 .B(b ) (2)
+
+
+63 . B (b ) (3)
+
+
+63 .B(c ) (1 ) (i )
+
+
+
+63 .B(c) (1 ) (ii)
+
+
+63 .B(c) (1) (iii) ................. .
+
+
+63 . B (c) (2) -(3)
+
+
+63 . B (c ) (4) -(7)
+63 .B(d)
+
+
+63 .B(e )
+
+
+
+63 .B(f)(l )
+63 .B(f )(2)
+
+
+
+
+
+63 .B(f ) (3)
+63 . 8 (f ) (4)
+63 . 8 (f ) (5)
+63 . 8 (f) (6)
+
+63.B (g )
+
+
+
+63.9 (a)
+63 . 9 (b ) (1) (i ) -(ii)
+
+
+
+
+
+63 .9 (b) (1) (iii )
Yes
Yes
Yes
No ............. .
No
Yes
No ............. .
No ............. .
No ............. .
No ............. .
No ............. .
No ............. .
No
No
No ............. .
Yes
No ............. .
Yes
Yes
Yes
No
No
Yes
No ............. .
No ............. .
extension provisions. But, §
63 .343(a) (6 ) of subpart N also
contains provisions for
requesting a compliance extension.
Work practice standards are
contained in§ 63 .342(f) of
subpart N.
§ 63.344(d) of subpart N specifies
the monitoring location when
there are multiple sources.
§ 63 .347(g) (4) of subpart N
identifies reporting requirements
when multiple monitors are used.
Subpart N requires proper
maintenance of monitoring devices
expected to be used by sources
subject to subpart N.
§ 63 .342 (f) (3 ) (iv) of subpart N
specifies reporting when the O&M
plan is not followed.
§ 63. 343 (f) (2) identifies the
criteria for whether O&M
procedures are acceptable.
§ 63 .344 (d) (2) requires
appropriate use of monitoring
devices.
Maintenance of monitoring devices
is required by§§ 6~.342(f) and
63 .344(d) (2 ) of subpart N.
There are no performance
evaluation procedures for the
monitoring devices expected to be
used to comply with subpart N.
Instances in which the
Administrator may approve
alternatives to the monitoring
methods and procedures of subpart
N are contained in § 63 .343 (c) (8)
of subpart N.
Subpart N does not require the use
of CEM 's .
Monitoring data does not need to
be reduced for reporting purposes
because subpart N requires
measurement once/day.
§ 63 . 343 (a) (3 ) of subpart N
requires area sources to comply
with major source provisions if
an increase in HAP emissions
causes them to become major
sources.
§ 63 .347(c) (2) of subpart N
DAQE-937-99
Page 39
+
+
+
+63. 9 (bl (2 )
+
+
+
+63 .9 (b)(3 )
+63 . 9 (b ) (4)
+63 . 9 (b ) (5 )
+63 .9(c )
+
+
+
+
+
+
+
+
+
+63 .9 (d )
+
+
+
+
+
+63.9 (e )
+
+
+63 .9(f}
+63 .9 (g}
+
+
+
+63 .9 (h ) (1)-(3)
+
+
+
+
+63. 9 (h ) (5)
+
+
+63 . 9 (h ) (6)
+63 .9 (i) ··························
+63 .9 (j) ··························
+63 .l 0(a ) ........................ .
+63 .10 (b ) (1) ..................... .
+63 .10 (b ) (2)
+
+
+63 .l 0(b )(3}
+
+63 .l 0(c )
+
+
+63 .l 0(d )(l )
+63.10(d}(2)
+
+
+63 .l 0(d } (3)
+
+63.l 0(d ) (4)
+63 .10 (d ) (5 )
No ............. .
No
No
No
Yes
Yes ............ .
No ............. .
No
No
No ............. .
No ............. .
Yes
Yes
Yes
Yes
Yes
No ............. .
No
No
Yes
No ............. .
No ............. .
Yes
No ............. .
specifies ini tial notification
requirements for new or
reconstructed affected sources.
§ 63 .347 (c} (1) of subpart N
specifies the information to be
contai ned in the initial
notification.
§ 63
Thi s ·paragraph only references --§
63 :6(i} (4 ) through§ 63.6(i) (6) 11
for compliance extension
provisions. But,§ 63.343(a)(6)
of subpart N also contains
provisions for requesting a
compliance extension. Subpart N
provides a different timeframe
for submitting the request than§
63 .6(i)(4 ).
This paragraph only references --
the notification dates
est ablished in paragraph (g} of
thi s secti on.'' But, § 63 .347 of
subpart N a l so contains
not ification dates.
Noti fication of performance test
is required by§ 63 .347(d) of
subpart N.
Subpart N does not require a
performance evaluation or
relative accuracy.test for
monitoring devices .
§ 63 .347 (e) of subpart N specifies
inf ormati on to be contained in
t he noti fication of compli ance
status and the timeframe for
submitting this information.
Simi lar l anguage has been
i ncorporated into§ 63 .347 (e} (2)
(i i i} of subpart N.
§ 63.346 (b ) of subpart N specifies
the records that must be
mai ntained .
Subpart N applies to major and
area sources .
Applicable requirements of§ 63 .10
(c ) have been incorporated into§
63 .346 (b) of subpart N.
§ 63.34 7(f ) of subpart N specifies
the timeframe for reporting
performance test results.
Subpart N does not contain opacity
or visi ble emissions standards.
§ 63.342(f ) (3 ) (iv) and§ 63 .347(g)
DAQE-937-99
Page 40
+
+
+
+63 .l O(e )
+
+
+
+
+
+
+63.l O(f )
+63 .11 ........................... .
+
+63.12-63 .15
No ............. .
Yes
No .............. .
Yes
(3) of subpart N specify
reporting associated with
malfunctions .
§ 63.347(g) and (h) of subpart N
specify the frequency of periodic
reports of monitoring data used
to establish compliance.
Applicable requirements of§
63.lO (e) have been incorporated
into§ 63 .347 (g) and (h).
Flares will not be used to comply
wi th the emmission limits.
+--------------------1.------------'---------------------
+
+[Amended 61 FR 27785 , June 3, 1 996]
DAQE-937-99
Page 41
Appendix A
UAC R307-155 and UAC R307-107
R307. Environmental Quality, Air Quality.
R307-155. Emission Inventories.
R307-155-1. Criteria Pollutant Inventory.
(1) The requirements of R307-155 replace any annual inventory
reporting requirements in approval orders issued prior to April 1,
1998.
(a) Report Every Third Year. The owner or operator of each of
the following sources is required to submit a report of actual
emissions every third year. The first report shall be due in 2000 for
calendar year 1999 for:
(i) any Part 70 source located in Davis, Salt Lake, Utah or
Weber Counties;
(ii) any Part 70 temporary source;
(iii) any Part 70 source located outside Davis, Salt Lake, Utah
or Weber Counties with 25 tons per year or more of combined allowable
emissions of PMl0, sulfur dioxide, oxides of nitrogen, volatile
organic compounds or carbon monoxide; or
(iv) any stationary source:
(I) located in Davis, Salt Lake, Utah or Weber County with
allowable emissions of PMl0, sulfur oxides, or oxides of nitrogen of
25 tons per year or more;
(II) located in Davis or Salt Lake County with allowable
emissions of volatile organic compounds of 10 tons per year or more;
(III) located in Davis, Salt Lake, or Utah County with allowable
emissions of carbon monoxide of 100 tons per year or more;
(IV) that actually emits 100 tons per year or more of PMl0,
sulfur oxides, volatile organic compounds, carbon monoxide or oxides
of nitrogen; or
(V) that actually emits 5 tons per year or more of lead.
(b) Report Every Sixth Year. Any Part 70 source not included in
(a) above shall submit an emissions inventory every sixth year. The
inventory for calendar year 1996 suffices as the first inventory.
(c) Additional Reports of Actual Emissions Required Under
Specified Circumstances. This subsection is applicable to sources
identified in (a) (i) through (iv) above.
(i) A source that initially achieves compliance at any time with
any requirement of an applicable state implementation plan shall
submit an inventory for the calendar year in which compliance is
achieved.
(ii) A source specified in (a) (iv) (I), (II), (III), or (V) above
and whose actual emissions of any of the individual pollutants
specified in(a) (iv) (I), (II), (III), or (V) above increase or decrease
DAQE-937-99
Page 42
by five percent or more from the most recently submitted inventory
information shall submit an inventory for the calendar year in which
the increase or decrease occurred.
(iii) A source with actual or allowable emissions of 100 or more
tons per year of carbon monoxide, PMl0, sulfur oxides, volatile
organic compounds, or oxides of nitrogen, and whose actual emissions
of any of these pollutants increase or decrease by five percent or
more from the most recently submitted inventory shall submit an
inventory for the calendar year in which the increase or decrease
occurred.
(iv) A source operating temporarily in Davis, Salt Lake, Utah or
Weber County -shall submit an inventory for the calendar year in which
the source operated in those counties.
(v) A source that ceases operations shall submit a report of
actual emissions for the partial year and a report for the previous
calendar year.
(vi) A new or modified source that receives approval to
construct or begins operating shall submit a report for the initial
partial year of operation and a report for the subsequent calendar
year.
(d) In addition to the required inventories, any source may
choose to submit an inventory for any calendar year. The executive
secretary may require at any time a full or partial year inventory on
reasonable notice to affected sources.
(e) Due Date. Emission inventories shall be submitted on or
before April 15 of each calendar year following any calendar year in
which an inventory is required under R307-155-1 or 3.
(f) Reports. Emission inventory reports shall include the rate
and period of emission, excess or breakdown emissions, specific plant
source of air pollution, composition of air contaminant, type and
efficiency of air pollution control equipment and other information
necessary to quantify operation and pollution emission, and to
evaluate pollution control.
R307-155-2. Hazardous Air Pollutant Inventory.
The owner or operator of a stationary source, either "major
source" or "area source" as defined in the Federal Clean Air Act
(Title I, Part A, Section 112), which emits one or more hazardous air
pollutant shall submit, at the request of the Executive Secretary, but
not more than once per year, a Hazardous Air Pollutant Inventory. The
inventory shall be submitted no later than July 1 of each year
following any calendar year for which the hazardous air pollutant
inventory is required. The required submittal shall be limited to
hazardous air pollutants and shall include a report of the rate and
period of emission, excess or breakdown emissions, the specific plant
source of the emissions, the composition of the emission, the type and
DAQE-937-99
Page 43
efficiency of air pollution control equipment, and any other
information determined necessary by the Executive Secretary for the
issuance of permits, the verification of compliance, and the
determination of the effectiveness of control technology relative to
the source's maximum achievable control technology (MACT).
R307-155-3. Emission Statement Inventory.
(1) Applicability. The owner or operator of a stationary source
of either volatile organic compounds or oxides of nitrogen that is
located in Salt Lake or Davis Counties or a nonattainment area for
ozone and which emits or has the potential to emit 25 tons or more per
year of either volatile organic compounds or oxides of nitrogen is
required to submit an emission statement for the emissions released
directly or indirectly into the outdoor atmosphere in the calendar
years specified in (2) below. Such emission statement shall include
information concerning both volatile organic compounds and oxides of
nitrogen even if the source's emissions or its potential to emit
equaled or exceeded 25 tons per year for only volatile organic
compounds or oxides of nitrogen. Compliance with the emission
statement requirements does not relieve any owner or operator of a
source from the responsibility to comply with any other applicable
reporting requirements set forth in any federal or state law or in the
conditions of approval of any order or certificate in effect.
(2) Timing of Submittals.
(a) An emission statement shall be submitted for calendar year
1999 and every third year thereafter.
(b) A report for the calendar year in which any of the following
conditions occurs must be submitted by any source:
(i) whose actual emissions of volatile organic compounds or
oxides of nitrogen increase or decrease by five percent or more from
the most recently submitted inventory information;
(ii) that initially achieves compliance at any time with any
requirement of an applicable state implementation plan; or
(iii) for which the executive secretary requests submittal.
(c) A source that ceases operations shall submit a report for
the partial year and a report for the previous calendar year.
(d) A new or modified source that receives approval to construct
or begins operating during the reporting period shall submit a report
for the initial partial year of operation and the subsequent calendar
year.
(3) Procedure for submitting an emission statement. Emission
statements shall be submitted in accordance with the following
provisions:
(a) Emission statements shall be submitted on or before April 15
of each calendar year followi ng any calendar year in which the source
is subject to this rule.
DAQE-937-99
Page 44
(b) Emission statements shall be submitted to the Division of
Air Quality on a form obtainable from the Division of Air Quality.
(4) Required contents of an emission statement. Any person who
submits an emission statement shall include, as an integral part of
the report:
(a) Certification, signed by the highest ranking individual with
direct knowledge and overall responsibility for the information
contained in the certified documents, that the information provided is
true, accurate and complete. Such certification should be submitted
with the understanding that submittal of false, inaccurate or
incomplete information is subject to civil and criminal penalties.
(b) The date of the signature of certification and the telephone
number of the certifying indiv idual shall be included.
(c) The following source identification information shall be
included:
(i) full name of the source;
(ii) parent company name, if applicable;
(iii) physical location of the source (i.e., the street
address);
and
(iv)
(v)
(vi)
mailing address of the source;
SIC code(s) of the source;
UTM coordinates or latitude and longitude of the source;
(vii) the calendar year of the emissions.
(d) The following operating data for each source operation which
has the potential to emit volatile organic compounds or oxides of
nitrogen shall be included:
(i) annual and peak ozone season throughput;
(ii) average days of operation per week;
(iii) average hours of operation per day; and
(iv) total hours of operation for the year.
(e) The following information at the process level for oxides of
nitrogen (expressed as molecular weight of nitrogen dioxide) and
volatile organic compounds shall be included:
(i) Emissions information, including:
(A) the actual emissions of volatile organic compounds and
oxides of nitrogen in tons per year;
(B) the average actual emissions of volatile organic compounds
and oxides of nitrogen in pounds per day of operation during the peak
ozone season;
(C) the code for the method used to quantify the actual
emissions (from Table 1 included with the filing form in (2) (b}
above); and
(D) any emission factor used to determine actual emissions.
(ii) Control apparatus information, including current primary
and secondary control apparatus identification codes (from Table 2
DAQE-937-99
Page 45
included with the filing form in (2) (b)); and the actual control
efficiency achieved by the control apparatus. If the actual control
efficiency is unavailable, the control apparatus design efficiency
shall be used.
(iii) Process rate data, including the annual process rate and
the average process rate per day of operation during the peak ozone
season.
(f) In place of the information required in (4) (d) and (e)
above, any source which has the potential to emit less than one ton
per year of either volatile organic compounds or nitrogen oxides but
which is subject to this rule shall include:
(i) a description of each source operation and actual emissions
of each air contaminant emitted from each source operation shall be
estimated at one ton per year, or
(ii) a description of each source operation; estimated actual
emission in tons per year; the code for the method used to quantify
the actual emissions (from Table 1 included with the filing form in
(2) (b); and any emission factor used to determine actual emissions.
(g) Emission statements shall include cumulative total fugitive
emissions for the stationary source for all fugitive emissions that
cannot be reported in the information pursuant to (4) (d) through (f)
above. Such fugitive emissions shall be expressed in tons per year
and in average pounds per day of operation during the peak ozone
season.
(h) The method used for quantifying actual emissions for a
source operation for use in preparing emission information required in
(4) (e) (i) or (4) (f) (ii) above above shall be the method which is
reasonably available and which best estimates the actual emissions
from the source operation, unless an operating permit pursuant to
Title V of the federal Clean Air Act has been issued for the
stationary source. In such case, the method used shall be the method
specified in the operating permit.
(5) Recordkeeping requirements.
(a) Each owner or operator of a stationary source subject to
this rule shall maintain for a period -of four years from the due date
of each emission statement a copy of the emission statement submitted
to the Division of Air Quality and records indicating how the
information submitted in the emission statement was determined,
including any calculations, data, measurements, and estimates used.
(b) Upon the request of the Executive Secretary, the owner or
operator of the stationary source shall make these records available
at the stationary source for inspection by any representative of the
Division of Air Quality during normal business hours.
KEY: inventory, air pollution
1998 19-2-104
DAQE-937-99
Page 46
R307-107
R307. Environmental Quality, Air Quality.
40 CFR 51 Subpart Q
R307-107. General Requirements: Unavoidable Breakdown.
R307-107-1. Application.
R307-107 applies to all regulated pollutants including those for
which there are National Ambient Air Quality Standards. Except as
otherwise provided in R307-107, emissions resulting from an
unavoidable breakdown will not be deemed a violation of these
regulations. If excess emissions are predictable, they must be
authorized under the variance procedure in R307-102-4. Breakdowns
that are caused entirely or in part by poor maintenance, careless
operation, or any other preventable upset condition or preventable
equipment breakdown shall not be considered unavoidable breakdown.
R307-107-2. Reporting.
A breakdown for any period longer than 2 hours must be reported
to the executive secretary within 3 hours of the beginning of the
breakdown if reasonable, but in no case longer than 18 hours after the
beginning of the breakdown. During times other than normal office
hours, breakdowns for any period longer than 2 hours shall be
initially reported to the Environmental Health Emergency Response
Coordinator, Telephone [phone] . Within 7 calendar days of the
beginning of ·any breakdown of longer than 2 hours, a written report
shall be submitted to the executive secretary which shall include the
cause and nature of the event, estimated quantity of pollutant (total
and excess), time of emissions and steps taken to control the
emissions and to prevent recurrence. The submittal of such
informati on shall be used by t he executive secretary in determining
whether a violation has occurr ed and/or the need of further
enforcement action.
R307-107-3. Penalties.
Failure to comply with the reporting procedures of R307-107-2
will constitute a violation of these regulations.
•
DAQE-937-99
Page 47
R307-107-4. Procedures.
The owner or operator of an installation suffering an unavoidable
breakdown shall assure that emission limitations and visible emission
limitations are exceeded for only as short a period of time as
reasonable. The owner or operator shall take all reasonable measures
which may include but are not limited to the immediate curtailment of
production, operations, or activities at all installations of the
source if necessary to limit the total aggregate emissions from the
source to no greater than the aggregate allowable emissions averaged
over the periods provided in the source's approval orders or R307. In
the event that production, operations or activities cannot be
curtailed so as to so limit the total aggregate emissions without
jeopardizing equipment or safety or measures taken would result in
even greater excess emissions, the owner or operator of the source
shall use the most rapid, reasonable procedure to reduce emissions.
The owner or operator of any installation subject to a SIP emission
limitation pursuant to these rules shall be deemed to have complied
with the provisions of R307-107 if the emission limitation has not
been exceeded.
R307-107-5. Violation.
Failure to comply with curtailment actions required by R307-107-4
will constitute a violation of R307-107.
R307-107-6. Emissions Standards.
Other provisions of R307 may require more stringent controls than
listed herein, in which case those requirements must be met.
KEY: air pollution, breakdown*, excess emissions*
1998 19-2-104
4 -1 9 -00;12:59PM; ;435 586 944 2 # 1 / 4
. .. lletalcnlft
-~ TECHNOLOGIES, INC
498 North 277 4 West Cedar City, Utah 84720
[phone] FAX (435) Sffi.0289
TO= , :an B FAXCOVERSHEET
[a c L FROM:--'S~c ...... Js~c~e_. -'!..•B...-<JC:<""'--'-r~n'----e=-· __,'--~/ 1 ArrN: _________ _
DATE: __ l-f~/4-+-(---+-9-+-t~o ........ c) ____ FAXNo: I -'80 J -s 3f, -ct099
RECEIVED
APR 1 9 2000
Air Qualitv
NUMBER OF PAGES INCLUDING COVER SHEET
;435 586 9442 # 2 / 4
4 -19-00;12:59P M;
AeR-12-2000 WED 04: PM DIVISIOH AIR QUALITY FAX [phone] P. 01
Ml,,hnd 0. l.cn\'ill Oov.:rnor
·Ui~hl\<l R. 'Nid,otl. Ph.D. F.itcc:utl v~ l)frcctur
ll111ul.i K. Tr11,lt11an
blrL'tlOI
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVfSlON OF ATR QUALITY
150 North 1950 West r.o. Doll 144820
So.JI L.~kc City, llwh 84114-4820
(~<ll) 536-400(> Vc>icc
(801) 536•4099 fax
(801) 51(,-4414 't.D,f),
TELECOPIER REQUEST
150 No~th 1950 West Mo~th ~Q!Ple
Salt ~ake City, Utah 84114-48l0
Cannon 630 FAX# (B01) 536-4099
Confirmation# [phone]
Fram: Jon L. Black
Phone: [phone]
Date: April 12, 2000
To:~~ie B~r.ney Phone:~) 585-38,1
)>.GENCY /FIR.1'1: Mct~l crafe T~chnologies, Inc.
NUMBER OF PAGES TO FOt,WW: including the covGr
SUBJECT: SusiQ, Here arc the proposed ~O conditions for the modification to
add two passivation tanks and rQmoval of chromic acid
anodize t;:tnk, Please review this documnne and let me know of any
questions or conc~rn~ which you muy have. If everything looks
good, ~leaso sign page 2 of this f~x under 'Applicant Concact' und
fax it back to me and we can begin the /\0 process.
If you have any questions: or concerns, fGel free to call me at
[801) 536-40117 (SLC) o.r (801) 3n~ll06 {Provo Office).
Thi:tnk You
Dale Logged ____ _
Date Faxed ____ _
Time
Initials
4 -19-00; 12 :59P M; ;435 586 9442 # 3 / 4
PRR-12-2000 WED 04: M DIVISION AIR QUALITY 15364099 P. 02/02
UTAH DlVISION OF AIR QUALITY
l\!IODIFIED SOURCE PLAN REVIEW
Susie lfarney
Environmental Engineer
Mt:talcraft Technologies, Inc.
498 North 2774 Wcsl
Cedar City, Utah 84 720
RE:
REVIEW ENGINEER:
DATE:
NOTICE OF INTENT SUBfl.HTTED:
PLANT CONTACT:
PHONE NUMBER:
FAX NUMBER:
PLANT LOCATION:
Project fee code: N0270-006
Addition of Two (2) Passivation Tanks and Removal ofChromk:
Acid Anodize Tank
Iron County, CDS B; ATT; HAPS
Jon L. Black
March 6, 2000
October 28, 1999
Susie Barney
[phone]
[phone]
498 Norlh 2774 West, Cedar City, Utah, Iron County
UTM COORl)]NATES:
4,172.9 km. Northing, 314.7 km . Easting.Zone 12
f :\AQ\J,NGINEE:.R\J11LACK\WP\R.VW_OO\MITTAL.RVW
APPROVALS:
Peer Engineer __________________________ _
J. Tim Blanchar<l
DAQ request-; that a comprmy/corpora1ion official read Lhc atlached drafVproposcJ Plan Review with
Rccommendc<l Approval Order Conditions. If th i!\ person does not understand or does not agree with lhe
conditions, the £J-A N REVffiW ENGINEER -TECHNICIAN should bo contacted within five duys after
receipt of the Plan Review. Special nllention need~ to be. addre~scd to the Recommended AO Conditions
because they will be recommended for the final AO. If this pcrson undcr~Wnds and the
company/corporntion <2grccs with the Plan Review or Recommended AO Conditions, thi:-person should
sign bdow and remrn (can use FAX# [phone]) within l O days after receipt of the conditiom. If the
Plan Review Engineer is not contactc<l within 10 days, the Plan Review Engineer shall assume that the
Company/Corporation oflicial agn:r.:s with lhis Plan Review and v.•ill process the Pinn Re view toward:; final
approval. NOTE: The Approval Order will not be issued until this J,igncd sheet is returned imd the
review fees are paid.
Th::i.ok You
Applicnnt Comact -fil .
Engina~1i1)J; R.cvi~w: ~1t.~1:.Ucr:i.fl T!!chn<'>k>f.i'"'~• 11\C. -Pa:;..-.;ivilrion Tat1k.'i
April 12, 2000
Por;~ f
. • •• , .. --• -• • ......... .,o••,,•-•Jt nl'"'-• i .._,.'\1 "•IIIVtl 1¥11A."'
April I l, 2000
l'ot:~ I
;435 586 9442 # 4 / 4
4 -19-00;12:59PM; ,,
,/R-12-2000 WED 04: PM DIVISION AIR QUALITY FAX ,~ 8015364099 P. 03
D. Natural Gas Tr1!11tmcnt Oven #2
Design Capacity: 3,200.000 BTU/hr
E. Se::ven Paint Booths wilh particulnte filters
F. Two Alodinc l ,ines
G. One Titanium Etching Line
H. One Anodi7jng Line (includh1g n sulfuric acid umk, and a sulfuric boric acid rank)
I. Water Treatment System (including seven holding tanks. thn~e purification timks,
a clarifier, nnd a filter prnss).
J. One Sunstrand Parts Maker (with 2,200 ucfm filter coUcclion system)
K. Two Natural Gas Air Make-up Heaters
Desih>n Capacity: 5.000,000 BTU/hr each
L. Space HeateN
Design Cap.icity: 350.000 BTU/hr each
M. Passivation Tank (122 g II .. ~ •( 2 ZS ~ c,J(_J2..e-,-,..)
Tank Dimensions: 4rx42"x2r (n.,;suming 4" freeboard)
Nitric Add Concentration: 61-74 oz per gallon
Evaporation Rate: 3%
N. Passivation Tank (100 gnllon) *
Tank Dimensions: 36".x.28"x29" (assuming 4" freeboard)
Nitric Acid Concerilration: 32-57 oz per gallon
Evaporation Rate: 3%
+ Equivalency shall be determined by the Executive Secretnry.
Any future changes or modifications IO the cquipll'lcnt and processes approved by lhis AO
that could nffect the emissions covered by this AO must be approved in accor<lance with
R307-401-l, UAC.
6. lvfclalcraft shall notify lhe Executive Secretary in writing when the installation of tho
equipment listed in Condition #5.M & 5.N has been completed and is operation::il, ns :in
initial compliance inspection is required. To in~ure proper credit whel\ notifying the
Executive Secretary, send your correspondence to the Executive Secretary, au.n:
Compliance Section.
If installation hac; not been completed within eighteen months from lhe date of this AO, the
Executive Secretary shuJI be notified in writing on the status of the installuliort. At that time, the
Executive Secretary shall require documcntntion of the continuous i11s1allation of the <)peration au<l
Eni;i,11.,,,inr. R~,i~w; Metakror, Tc•c.bnr,toi;it.-s. )nc. -Pa.s.,iv~liOll "'r:1nk,
April 12, 2000
f'ltJ,,'l: 15
From:
To:
Date:
Subject:
"Susie Barney" <[e-mail]>
<[e-mail]. ut. us>
3/1/00 7:41PM
Modification to Permit #937-99
I know it would save a lot of money if I could plan all of my changes to happen at once, but I can't seem to
get to that point. Debra McMurtrie in the Emissions Inventory side of the house strongly recommended
that I go ahead with the change to have the reference to the chromic acid anodize tank taken out of our
permit (#937-99). Before I present this action to my management I would like to know approximately how
much such a change would cost. I know that is a hard number to pull out of the air and it really isn't fair to
ask you to quote one, but do you think it would be a major change, would it require a peer review and
public comment period? Any information would help. Thanks.
From:
To:
Date:
Subject:
"Susie Barney" <[e-mail]>
<[e-mail]>
3/3/00 2:29PM
Permit Change for DAQE-937-99
My management has decided to go ahead with the change to our permit to remove the reference to the
chromic acid anodize tank. Hope this email gets to you in time to add this to the passivation review. I will
also call and leave a message on your voice mail. Thanks.
1
DAQC-436-24
Site ID 10270 (B1)
MEMORANDUM
TO: FILE – ALIGN PRECISION (Building 1) – Formerly Known as METALCRAFT
TECHNOLOGIES
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Jared James, Environmental Scientist
DATE: April 24, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Iron County
INSPECTION DATE: March 27, 2024
SOURCE LOCATION: 526 Aviation Way, Cedar City, Utah 84721
SOURCE CONTACT(S): Eric Lewis, Environmental Engineer: 435-586-3871
[e-mail]
OPERATING STATUS: Operating
PROCESS DESCRIPTION: This is an aircraft parts fabrication plant. Metals of different
types and sizes are brought in by truck. The parts are first sent
through a series of cutters, formers, welders, and grinders. Most
of these machines do not produce emissions with the exception
of the welders which vent directly to the air. The parts are then
heat treated in one of three ovens according to size and
temperatures needed. The ovens are natural gas or electric fired.
The electric ovens have small vents on the top which vent
directly to the inside air. The natural gas ovens have discharge
vents which go to the roof and vent to the outside air. The ovens
are used to treat the metal and no coatings are applied prior to
the use of the ovens. The parts once treated are shipped to
another building for further processing.
APPLICABLE REGULATIONS: Approval Order DAQE-412-00, dated July 6, 2000.
SOURCE EVALUATION:
General Conditions:
Condition 1. This Approval Order (AO) applies to the following company:
Site Office
Metalcraft Technologies, Inc.
498 North 2774 West
Cedar City, Utah 84720
Phone Number [phone]
Fax Number [phone]
00
2
The equipment listed in this AO shall be operated at the following location:
PLANT LOCATION
498 North 2774 West, Cedar City, Utah, Iron County
Universal Transverse Mercator (UTM) Coordinate System:
4,172.9 kilometers Northing, 314.7 kilometers Easting, Zone 12
Status: In compliance. The telephone number and fax number are current but the source is
now located at 526 Aviation Way, Cedar City, UT 84721. The source was also
purchased by and is now named Align Precision.
Condition 2. Definitions of terms, abbreviations, and references used in this AO conform to those used
in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of
Federal Regulations (40 CFR). These definitions take precedence, unless specifically
defined otherwise herein.
Status: In compliance.
Condition 3. Metalcraft Technologies, Inc., shall install and operate the two passivation tanks and shall
conduct its operations of the aircraft parts manufacturing facility in accordance with the
terms and conditions of this AO, which was written pursuant to Metalcraft’s Notice of
Intent submitted to the Division of Air Quality (DAQ) on October 28, 1999 and
additional information submitted to the DAQ on March 3, 2000.
Status: In compliance. The two passivation tanks have been removed from the source. See
status of condition 5 for additional information.
Condition 4. This AO shall replace the AO dated December 1, 1999 (DAQE-937-99).
Status: In compliance. Only the current AO was used to determine compliance.
Condition 5. The approved installations shall consist of the following equipment or equivalent*:
A. Natural Gas Curing Oven
Design Capacity: 700,000 BTU/hr
B. Natural Gas Paint Burn-Off Oven
Design Capacity: 800,000 BTU/hr
C. Natural Gas Treatment Oven #1
Design Capacity: 3,400,000 BTU/hr
D. Natural Gas Treatment Oven #2
Design Capacity: 3,200,000 BTU/hr
E. Seven Paint Booths with particulate filters
F. Two Alodine Lines
G. One Titanium Etching Line
3
H. One Anodizing Line (including a sulfuric acid tank, and a sulfuric boric acid tank)
I. Water Treatment System (including seven holding tanks, three purification tanks,
a clarifier, and a filter press).
J. One Sunstrand Parts Maker (with 2,200 acfm filter collection system)
K. Two Natural Gas Air Make-up Heaters
Design Capacity: 5,000,000 BTU/hr each
L. Space Heaters
Design Capacity: 350,000 BTU/hr each
M. Passivation Tank (225 gallon) *
Tank Dimensions: 47"x42"x27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz per gallon
Evaporation Rate: 3%
N. Passivation Tank (100 gallon) *
Tank Dimensions: 36"x28"x29" (assuming 4" freeboard)
Nitric Acid Concentration: 32-57 oz per gallon
Evaporation Rate: 3%
Equivalency shall be determined by the Executive Secretary.
Any future changes or modifications to the equipment and processes approved by this
AO that could affect emissions covered by this AO must be approved in accordance with
R307-401-1, UAC.
Status: In compliance. Most of the equipment listed in this condition has been removed or is
currently not in use. Items A, C, D, E (one small paint hood only), and L are still in
use. All remaining equipment has been relocated to the company’s new building
Building 2). This site (Building 1) now serves as the fabrication source. All
manufacturing and finishing work is completed in Building 2.
Condition 6. Metalcraft shall notify the Executive Secretary in writing when the installation of the
equipment listed in Condition #5.M & 5.N has been completed and is operational, as an
initial compliance inspection is required. To insure proper credit when notifying the
Executive Secretary, send your correspondence to the Executive Secretary, Attn:
Compliance Section.
If installation has not been completed within eighteen months from the date of this AO,
the Executive Secretary shall be notified in writing on the status of the installation. At
that time, the Executive Secretary shall require documentation of the continuous
installation of the operation and may revoke the AO in accordance with R307-401-11,
UAC.
Status: In compliance. Notifications were sent and are in the main source file. This
condition could be considered not applicable for further inspections since items M
and N have been permanently removed from the source.
4
Condition 7. Visible emissions from the following emission points shall not exceed the following
values:
A. All paint booths exhaust stacks - 5% opacity
B. Passivation tank exhaust stack - 5% opacity
C. All natural gas combustion stacks - 10% opacity
D. All other points - 20% opacity
Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and
intermittent sources shall use procedures similar to Method 9, but the requirement for
observations to be made at 15-second intervals over a six-minute period shall not apply.
Any time-interval with no visible emissions shall not be included.
Status: In compliance. No visible emissions were observed from any point during the
inspection.
Condition 8. The consumption limits of the following materials shall not be exceeded without prior
approval in accordance with R307-401, UAC:
A. Alodine 1200S or equivalent* - 85 pounds per rolling 12-month period.
B. Sodium Chromate - 4 pounds per rolling 12-month period.
C. Hydrofluoric Acid - 125 gallons per rolling 12-month period.
D. Nova Coat 1100 or equivalent* - 135 gallons per rolling 12-month period.
E. Acidic Chromated Deoxidizer - 125 pounds per rolling 12-month period.
Records of consumption shall be kept for all periods when the plant is in operation. The
consumption shall be determined by sales invoices or by any other method as acceptable
to the Executive Secretary or representatives of the Executive Secretary. Records of
consumption, shall be made available to the Executive Secretary or representatives of the
Executive Secretary upon request.
Status: Not applicable. None of these materials are consumed any longer at this location. All
material consuming processes have been moved to Building 2. This site is used only
as a fabrication source.
Condition 9. The owner/operator shall use only natural gas as fuel. If any other fuel is to be used, an
AO shall be required in accordance with R307-401, UAC.
Status: In compliance. Natural gas lines to remaining equipment in use at the site were
verified during the inspection.
Condition 10. The paint spray booths shall be equipped with sets of paint arrestor particulate filters, or
equivalent, to control particulate emissions. All air exiting the booth shall pass through
this control system before being vented to the atmosphere (outside building/operation).
Equivalency determinations, when requested by the owner/operator, shall be submitted to
the Executive Secretary for approval.
Status: In compliance. One small paint hood remains in use at the facility. Very little
painting is conducted, most of which is touch up painting with a spray can. Filters
were in place and in good condition. Lid was present on paint cans, and a HPLV
nozzle is utilized. Rags appear to be properly stored in closed lid containers.
5
Condition 11. The plant-wide emissions of VOCs and HAPs from the paint booths, Alodine lines,
titanium etching line, anodizing line and associated operations shall not exceed:
14.43 tons per rolling 12-month period for VOCs
40.00 pounds per rolling 12-month period for chromium compounds
627.42 pounds per rolling 12-month period for ethyl benzene
1,222.00 pounds per rolling 12-month period for ethylene glycol
6.41 pounds per rolling 12-month period for hydrofluoric acid
0.22 pounds per rolling 12-month period for lead
1,721.44 pounds per rolling 12-month period for methyl ethyl ketone
1,547.30 pounds per rolling 12-month period for methyl isobutyl ketone
112.38 pounds per rolling 12-month period for methyl amul keytone
0.12 pounds per rolling 12-month period for nickel oxide
319.92 pounds per rolling 12-month period for nitric acid
6.75 pounds per rolling 12-month period for potassium ferricyanide
155.30 pounds per rolling 12-month period for toluene
555.50 pounds per rolling 12-month period for triethylamine
1,377.00 pounds per rolling 12-month period for Xylene
3.85 tons total per rolling 12-month period for all HAPs combined
This value shall not be exceeded without prior approval, in accordance with R307-401,
UAC. Compliance with each 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 plant-wide emissions of VOCs and HAPs emitted to the atmosphere shall be
determined by maintaining a record of VOC potential and HAP potential contained in
materials used each month. The record shall include the following data for each item
used:
A. Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, isocyanates, etc.
B. The weight and use location (name of paint booth or plant facility) of the VOC
potential and HAP potential of the material(s) listed in A, in pounds per gallon.
C. Percent by weight of all VOC potential and HAP potential for each individual
material listed in A. The percent by weight of the VOC and HAP potentials can
be obtained from the manufacturers' MSDSs. The owner/operator can obtain
MSDS data from the manufacturers of the materials and retain the information
on-site.
D. Amount and location of materials containing VOCs and HAPs used on a monthly
basis and summed for every location and for the entire plant each month.
E. To calculate the above potentials contained in the material listed in D, use the
following procedure:
VOC or HAPs = % Volatile by Weight x [Density ( lb )] x Gal Consumed x 1 ton
100) (gal) 2000 lb
6
F. The amount of VOC content potential (potential air emissions) and HAP
potential (potential air emissions) in pounds contained in materials deposited as
solid or hazardous waste for the month shall be quantified and subtracted from
the quantities calculated above. This is done to allow quantification by the source
of the total VOCs and HAPs emissions. (The assumption is that all the two
above-potentials of the materials applied to a product evaporate and are therefore
considered emissions).
G. Records of consumption of VOCs and HAPs shall be kept for all periods when
the plant is in operation. Records of consumption shall be made available to the
Executive Secretary or Executive Secretary’s representative upon request, and
the records shall include the two-year period prior to the date of the request.
Status: In compliance. All VOC and HAP-containing materials have been moved from this
source to Building 2. Records were reviewed at the time of inspection and contained
all required information. VOCs were recorded as 0.35 tons/year, toluene was
recorded with 0.02 tons/year, and 0.12 tons/year of HAPs for the 12 month period.
Condition 12. 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 Approval Order 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 Executive Secretary 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, and the records shall
be maintained for a period of two years. Maintenance records shall be made available to
the Executive Secretary or Executive Secretary’s representative upon request, and the
records shall include the two-year period prior to the date of the request.
Status: In compliance. All equipment appeared to be maintained and no emissions were
observed from any point during the inspection. All records were furnished upon
request.
Condition 13. The owner/operator shall comply with R307-107, UAC. This rule addresses unavoidable
breakdown reporting requirements. The full text of UAC R307-107 General
Requirements, Unavoidable Breakdown, is included as Appendix A. However, to be in
compliance, this facility must operate in accordance with the most current version of the
UAC, R307-107.
Status: In compliance. No reportable breakdowns have occurred since last inspection.
7
AREA SOURCE RULES EVALUATION:
No area source rules were determined to be applicable to the facility during this inspection except for
R307-205 which was addressed by condition 7.
EMISSION INVENTORY: Potential to emit for this source from the AO is as follows:
Pollutant Tons/yr
PM10 ................................. 0.48
SO2 ................................. 1.00
NOx ................................. 2.40
CO ................................. 0.41
VOC ............................... 14.43
HAPs consist of the following amounts in Pounds/Year.
Chromium compounds…….40.00
Ethyl benzene…………….627.42
Ethylene glycol……….. ..1,222.00
Hydrofluoric Acid…………...6.41
Lead…. ……………………...0.22
Methyl ethyl ketone…… .1,721.44
Methyl isobutyl ketone….1,547.30
Methyl amul keytone……...112.38
Nitric Acid…………………319.92
Nickel oxide…………………..0.12
Potassium ferricyanide………..6.75
Toluene……………………..155.30
Triethylamine……………….555.50
Xylene……………………..1,377.00
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: Align Precision should be considered in compliance with the
conditions of the AO DAQE-412-00, dated July 6, 2000, at the
time of inspection. The facility appears to be well maintained
and operated properly. All records were provided for review at
the time of inspection.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal. Inspect the source with Align Precision
Metalcraft Technologies) Building #2 (Site ID 12202) with the
AO dated October 4, 2001 (DAQE-817-01).
ATTACHMENTS: VEO Form.
Dale: 12/2912021
This form must be type written or computer Agegi 'Number: 9253352
State of Utah Amount Paid: 66.001
Department of Commerce
Division of Corporations & Commercial Code
Amendment to Certificate of Organization
Non-Refundable Processing Fee: $37.00
Pursuant to UCA § 48-3a-202, the individual named below causes this Amendment to the Certificate of
Organization to be delivered to the Utah Division of Corporations for filing, and states as follows:
Entity Number: 8628618-0160
The name of the limited liability company is: METALCRAFT TECHNOLOGIES INV., LLC
The Certificate of Organization shall be amended as set forth herein (complete all that apply):
There is a change in the name of the limited liability company to:
Align Precision - Cedar City, LLC
RECEIVED
DEC 29 2021
Utah Div. of Corp. & Comm. Code
The Certificate of Organization is amended as follows:
The name of the limited liability company is: Align Precision - Cedar City, LLC.
Filing date of initial certificate 03/31/2013
Future effective date (if not to be effective upon filing) 1/1/2022 at 12:01 AM (not to exceed 90 days)
Under penalties of perjury, I declare that this Amendment of Certificate of Orpn4ation has been
examined by me and is, to the best of my knowledge and belief, true, correc omplete.
Name:
Title: A-4
,717//i7 Signed:
Dated:
Under GRAMA (63-2-201), all registration information maintained by the Division is classified as public record. For confidentiality purposes, you may
use the business entity physical address rather than the residential or private address of any individual affiliated with the entity.
01/14
State of Utah
Department of Commerce
Division of Corporations and Commercial Code
I hereby certified that the foregoing has been filed
and appr ved as of this Jayed effe • ate:
day of 20
In this office of this Division and hereby issued
This Certificate thereof.
Examiner c-9 Date 1211106(
Watc_
Leigh Veillete
Division Director
DEC 29 '21 P157
UTO9 I • 3/19/2015 Wolters Kluwer Online
Lucia Mason <[e-mail]>
DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
17 messages
Lucia Mason <[e-mail]>Mon, Dec 2, 2024 at 11:40 AM
To: "Eric Lewis (CCY)" <[e-mail]>
Hi Eric,
The DAQ has completed Align Precision- Cedar City LLC's updated Approval Order for site 10270. Before it's issued you have ten days to review the document.
Please get back to me with any questions or concerns by 12/12. If you approve of the document, please return a signed copy. The updated permit is attached.
Additionally, please confirm the correct SIC code for this site. Currently, the SIC code is listed as 3728 (Aircraft Parts & Auxiliary Equipment, NEC).
Lastly, the latest compliance report for the facility notes that many of the approved pieces of equipment have been moved to a different site. Given the reduction in
the equipment and emissions at site 10270 you may want to explore the possibility of a Small Source Exemption (SSE) and permit revocation. You can find more
information about SSEs here: https://deq.utah.gov/air-quality/new-source-review-exemptions-from-permitting-air-quality.
The SSE application form can be accessed here: https://utahgov.co1.qualtrics.com/jfe/form/SV_3t4JtgzRudum7l3.
Please reach out with any questions. Hope you're having a good start to your week.
Lucia
#4 SOURCE 10YR RN102700011.rtf
1544K
Eric Lewis (CCY) <[e-mail]>Thu, Dec 12, 2024 at 9:36 AM
To: Lucia Mason <[e-mail]>
Hi Lucia,

One question I have is that the updated approval order references DAQE-412-00, my records indicate that DAQE-817-01 would be this site’s most recent AO. Can
you help me understand what appears to be a discrepancy here?

As for the SIC code for this site, 3728 (Aircraft Parts & Auxiliary Equipment, NEC) is correct.
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…1/22

Also, thank you for the information on the potential for exemption but my records show that we don’t quite meet the requirements to make such an application at
this time but may be something we can look at trying to accomplish with future improvement projects.

Look forward to hearing back from you,

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Monday, December 2, 2024 11:41 AM
To: Eric Lewis (CCY) <[e-mail]>
Subject: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the
content is safe.
[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Dec 12, 2024 at 12:03 PM
To: "Eric Lewis (CCY)" <[e-mail]>
HI Eric,
Thanks for the SIC code confirmation.
To answer your question, the DAQ has been working on two AOs for Align Precision simultaneously. This AO is a 10-year review associated with site 10270.
According to our records, site 10270 is currently permitted by AO DAQE-412-00. The DAQ has also been working on an administrative amendment for site 12202
which is currently permitted by AO DAQE-817-01.
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…2/22
I've listed two Align Precision projects that are in progress below and attached their respective AOs. If this information doesn't match your records let me know and
we'll work to get to the bottom of the confusion.
Site 10270, Building 1 (10-Year Review)
Current AO: DAQE-412-00
Source Address: 526 Aviation Way, Cedar City, UT 84721
Mailing Address: 526 Aviation Way, Cedar City, UT 84721
UTM Coordinates: 314,596 m E, 4173107 m N
Site 12202, Building 2 (Administrative Amendment)
Current AO: DAQE-817-01
Source Address: 597 North 1500 West, Cedar City, UT 84721
Mailing Address: 526 Aviation Way, Cedar City, UT 84721
UTM Coordinates: 316,354 m Easting, 4,173,035 m Northing
Please reach out with any additional questions.
Best,
Lucia
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3 attachments
Opensense_ALIGN_Signature_Main.png
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AO DAQE-412-00.pdf
20919K
AO DAQE-817-01.pdf
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Eric Lewis (CCY) <[e-mail]>Thu, Dec 12, 2024 at 2:26 PM
To: Lucia Mason <[e-mail]>
That makes much more sense, thank you! The equipment listed below is no longer at site 10270 but now resides at site 12202 from when we initially submitted the
NOI for site 12202. However, with this clarification in mind, site 10270 should meet the requirements for an exemption so I have submitted that application as well.

II.A.6 NEW Seven (7) Paint Booths*
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…3/22
Control: Particulate filters

*We do still have (1) paint booth that remains at site 10270 controlled by particulate filters

II.A.7 NEW Two (2) Alodine Lines

II.A.8 NEW One (1) Titanium Etching Line

II.A.9 NEW One (1) Anodizing Line
Includes:
One (1) sulfuric acid tank
One (1) sulfuric boric acid tank

II.A.10 NEW Water Treatment System
Includes:
Seven (7) holding tanks
Three (3) purification tanks
One (1) clarifier
One (1) filter press

II.A.11 NEW One (1) Parts Maker*
Control: Filter collection system
Rating: 2,200 acfm

*This equipment is no longer at either site.

1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…4/22
II.A.12 NEW Two (2) Natural Gas Air Make-up Heaters
Rating: 5 MMBtu/hr each

II.A.14 NEW Passivation Tank
Capacity: 225 gallons
Tank Dimensions: 47"x42"x27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz per gallon
Evaporation Rate: 3%

II.A.15 NEW Passivation Tank
Capacity: 100 gallons
Tank Dimensions: 36"x28"x29" (assuming 4" freeboard)
Nitric Acid Concentration: 32-57 oz per gallon
Evaporation Rate: 3%

Let me know if this brings up any further questions on your end,
[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Dec 12, 2024 at 2:43 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Thanks for the updates Eric! I'm going to pause the 10-year review for site 10270 until the small source exemption (SSE) application is processed given that the
exemption will supersede the 10-year review if everything goes smoothly.
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Opensense_ALIGN_Signature_Main.png
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1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…5/22
Eric Lewis (CCY) <[e-mail]>Thu, Dec 12, 2024 at 2:44 PM
To: Lucia Mason <[e-mail]>
Sounds good, thank you so much for your patience with me on this project!
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ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Monday, December 2, 2024 11:41 AM
To: Eric Lewis (CCY) <[e-mail]>
Subject: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
[Quoted text hidden]

1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…6/22
Lucia Mason <[e-mail]>Thu, Dec 12, 2024 at 3:20 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Yeah for sure! It's honestly pretty confusing having both projects going at once- sorry for any lack of clarity on our end.
I think we're getting pretty close on the administrative amendment for site 12202 (replacement of the anodize/alodine chemical process lines). Earlier today I sent
an email about some equipment that compliance flagged as possibly removed from site 12202 (the zinc/phosphate descale process line, equipment ID 8.M, and the
sludge dryer associated with the wastewater treatment plant, equipment ID 8.P.vii). If this equipment has been permanently removed from site 12202 and you
would like it removed from your AO as part of this amendment let me know. The DAQ will need emission estimates for the zinc/phosphate descale process line and
sludge dryer if you would like them removed so that your overall site emissions remain accurate.
Let me know about the removed equipment and feel free to reach out with any questions. Thanks for your help,
Lucia
[Quoted text hidden]
Opensense_ALIGN_Signature_Main.png
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Eric Lewis (CCY) <[e-mail]>Thu, Dec 12, 2024 at 3:47 PM
To: Lucia Mason <[e-mail]>
Both pieces of equipment can be removed from the AO. I am at site 10270 for the rest of today and will need to reference the physical copies of our initial NOI
information for site 12202 when I am over there tomorrow and get back to you on emission estimates.
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ERIC LEWIS
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…7/22
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
[Quoted text hidden]
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Lucia Mason <[e-mail]>Thu, Dec 12, 2024 at 3:56 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Perfect. Thanks!
[Quoted text hidden]
Opensense_ALIGN_Signature_Main.png
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Eric Lewis (CCY) <[e-mail]>Mon, Dec 16, 2024 at 12:55 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

Attached is what I was able to find regarding the sludge drier & zinc/phosphate descale process line.

Let me know if you have any questions,
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…8/22
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ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
[Quoted text hidden]
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2 attachments
sludge drier & scrubber info.pdf
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DAQE-098-00.pdf
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Lucia Mason <[e-mail]>Mon, Dec 16, 2024 at 1:55 PM
To: "Eric Lewis (CCY)" <[e-mail]>
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&sim…9/22
Thank you.
[Quoted text hidden]
Opensense_ALIGN_Signature_Main.png
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Lucia Mason <[e-mail]>Tue, Dec 17, 2024 at 7:11 AM
To: "Eric Lewis (CCY)" <[e-mail]>
Hi Eric,
A few questions about the SSE application for site 10270 and a clarification about the operations at site 12202:
SSE Application for Site 10270:
1. As far as I can tell, the only emissions from Building 1 come from the use of T-50 Formkote in the one (1) on-site paint booth. Can you confirm this is
correct?
2. Typically two years of data are used to support SSE applications. It would be ideal if you could send data from 2023. If for some reason you can't, we can
probably work with what you already sent.
3. I've added some notes and emission sums to the attached spreadsheet. Take a look at them and let me know if the emission sums are accurate.
4. Could you provide the SDS for T-50 Formkote to confirm the percentages of Xylene, Toluene and VOCs listed in the spreadsheet?
Administrative Amendment for Site 12202:
1. Condition 15 of AO DAQE-817-01 lists the VOC and HAPs emission limits from paint booths. In practice these also seem to include emissions from the
chemical process lines. Would it impact your operations if I change the condition to include emissions from chemical process lines in addition to paint
booths?
Let me know and thanks for all your time,
Lucia
[Quoted text hidden]
10270 DAQ Calculations.xlsx
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Lucia Mason <[e-mail]>Thu, Dec 26, 2024 at 10:40 AM
To: "Eric Lewis (CCY)" <[e-mail]>
Hi Eric,
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…10/22
I'm checkin on on the follow up email I sent on the 17th. Let me know if you have any updates.
Happy holidays,
Lucia
[Quoted text hidden]
Eric Lewis (CCY) <[e-mail]>Fri, Jan 3, 2025 at 11:28 AM
To: Lucia Mason <[e-mail]>
Hi Lucia,

SSE Application for Site 10270:
1. As far as I can tell, the only emissions from Building 1 come from the use of T-50 Formkote in the one (1) on-site paint booth. Can you confirm this is
correct? -yes, this is correct.
2. Typically two years of data are used to support SSE applications. It would be ideal if you could send data from 2023. If for some reason you can't, we can
probably work with what you already sent. -we just keep a rolling report saved so I would have to go back and re-generate a 2023 report if that is required,
let me know if you would like me to re-generate a 2023 report or if the current data is sufficient.
3. I've added some notes and emission sums to the attached spreadsheet. Take a look at them and let me know if the emission sums are accurate. -yes, the
sums that you have added appear to be accurate.
4. Could you provide the SDS for T-50 Formkote to confirm the percentages of Xylene, Toluene and VOCs listed in the spreadsheet? -see attached
Administrative Amendment for Site 12202:
1. Condition 15 of AO DAQE-817-01 lists the VOC and HAPs emission limits from paint booths. In practice these also seem to include emissions from the
chemical process lines. Would it impact your operations if I change the condition to include emissions from chemical process lines in addition to paint
booths? – You are correct, in practice these include emissions from the chemical process lines so it should not impact our operations for you to change the
condition to include emissions from chemical process lines in addition to paint booths.

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…11/22
From: Lucia Mason <[e-mail]>
Sent: Tuesday, December 17, 2024 7:12 AM
To: Eric Lewis (CCY) <[e-mail]>
Subject: Re: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the
content is safe.

Hi Eric,

A few questions about the SSE application for site 10270 and a clarification about the operations at site 12202:

SSE Application for Site 10270:
1. As far as I can tell, the only emissions from Building 1 come from the use of T-50 Formkote in the one (1) on-site paint booth. Can you confirm this is
correct?
2. Typically two years of data are used to support SSE applications. It would be ideal if you could send data from 2023. If for some reason you can't, we can
probably work with what you already sent.
3. I've added some notes and emission sums to the attached spreadsheet. Take a look at them and let me know if the emission sums are accurate.
4. Could you provide the SDS for T-50 Formkote to confirm the percentages of Xylene, Toluene and VOCs listed in the spreadsheet?
Administrative Amendment for Site 12202:
1. Condition 15 of AO DAQE-817-01 lists the VOC and HAPs emission limits from paint booths. In practice these also seem to include emissions from the
chemical process lines. Would it impact your operations if I change the condition to include emissions from chemical process lines in addition to paint
booths?
Let me know and thanks for all your time,

Lucia

On Mon, Dec 16, 2024 at 1:55 PM Lucia Mason <[e-mail]> wrote:
Thank you.
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…12/22

On Mon, Dec 16, 2024 at 12:55 PM Eric Lewis (CCY) <[e-mail]> wrote:
Hi Lucia,

Attached is what I was able to find regarding the sludge drier & zinc/phosphate descale process line.

Let me know if you have any questions,

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Thursday, December 12, 2024 3:21 PM
To: Eric Lewis (CCY) <[e-mail]>
Subject: Re: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the
content is safe.

1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…13/22
Yeah for sure! It's honestly pretty confusing having both projects going at once- sorry for any lack of clarity on our end.

I think we're getting pretty close on the administrative amendment for site 12202 (replacement of the anodize/alodine chemical process lines). Earlier today I
sent an email about some equipment that compliance flagged as possibly removed from site 12202 (the zinc/phosphate descale process line, equipment ID
8.M, and the sludge dryer associated with the wastewater treatment plant, equipment ID 8.P.vii). If this equipment has been permanently removed from site
12202 and you would like it removed from your AO as part of this amendment let me know. The DAQ will need emission estimates for the zinc/phosphate
descale process line and sludge dryer if you would like them removed so that your overall site emissions remain accurate.

Let me know about the removed equipment and feel free to reach out with any questions. Thanks for your help,

Lucia

On Thu, Dec 12, 2024 at 2:45 PM Eric Lewis (CCY) <[e-mail]> wrote:
Sounds good, thank you so much for your patience with me on this project!

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Thursday, December 12, 2024 2:43 PM
To: Eric Lewis (CCY) <[e-mail]>
Subject: Re: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…14/22

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.

Thanks for the updates Eric! I'm going to pause the 10-year review for site 10270 until the small source exemption (SSE) application is processed given
that the exemption will supersede the 10-year review if everything goes smoothly.

On Thu, Dec 12, 2024 at 2:27 PM Eric Lewis (CCY) <[e-mail]> wrote:
That makes much more sense, thank you! The equipment listed below is no longer at site 10270 but now resides at site 12202 from when we initially
submitted the NOI for site 12202. However, with this clarification in mind, site 10270 should meet the requirements for an exemption so I have submitted
that application as well.

II.A.6 NEW Seven (7) Paint Booths*
Control: Particulate filters

*We do still have (1) paint booth that remains at site 10270 controlled by particulate filters

II.A.7 NEW Two (2) Alodine Lines

II.A.8 NEW One (1) Titanium Etching Line

II.A.9 NEW One (1) Anodizing Line
Includes:
One (1) sulfuric acid tank
One (1) sulfuric boric acid tank

II.A.10 NEW Water Treatment System
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…15/22
Includes:
Seven (7) holding tanks
Three (3) purification tanks
One (1) clarifier
One (1) filter press

II.A.11 NEW One (1) Parts Maker*
Control: Filter collection system
Rating: 2,200 acfm

*This equipment is no longer at either site.

II.A.12 NEW Two (2) Natural Gas Air Make-up Heaters
Rating: 5 MMBtu/hr each

II.A.14 NEW Passivation Tank
Capacity: 225 gallons
Tank Dimensions: 47"x42"x27" (assuming 4" freeboard)
Nitric Acid Concentration: 61-74 oz per gallon
Evaporation Rate: 3%

II.A.15 NEW Passivation Tank
Capacity: 100 gallons
Tank Dimensions: 36"x28"x29" (assuming 4" freeboard)
Nitric Acid Concentration: 32-57 oz per gallon
Evaporation Rate: 3%
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…16/22

Let me know if this brings up any further questions on your end,

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Thursday, December 12, 2024 12:03 PM
To: Eric Lewis (CCY) <[e-mail]>
Subject: Re: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know
the content is safe.

HI Eric,

Thanks for the SIC code confirmation.

1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…17/22
To answer your question, the DAQ has been working on two AOs for Align Precision simultaneously. This AO is a 10-year review associated with site
10270. According to our records, site 10270 is currently permitted by AO DAQE-412-00. The DAQ has also been working on an administrative
amendment for site 12202 which is currently permitted by AO DAQE-817-01.

I've listed two Align Precision projects that are in progress below and attached their respective AOs. If this information doesn't match your records let me
know and we'll work to get to the bottom of the confusion.

Site 10270, Building 1 (10-Year Review)
Current AO: DAQE-412-00
Source Address: 526 Aviation Way, Cedar City, UT 84721
Mailing Address: 526 Aviation Way, Cedar City, UT 84721
UTM Coordinates: 314,596 m E, 4173107 m N

Site 12202, Building 2 (Administrative Amendment)
Current AO: DAQE-817-01
Source Address: 597 North 1500 West, Cedar City, UT 84721
Mailing Address: 526 Aviation Way, Cedar City, UT 84721
UTM Coordinates: 316,354 m Easting, 4,173,035 m Northing

Please reach out with any additional questions.

Best,

Lucia

On Thu, Dec 12, 2024 at 9:37 AM Eric Lewis (CCY) <[e-mail]> wrote:
Hi Lucia,

1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…18/22
One question I have is that the updated approval order references DAQE-412-00, my records indicate that DAQE-817-01 would be this site’s most
recent AO. Can you help me understand what appears to be a discrepancy here?

As for the SIC code for this site, 3728 (Aircraft Parts & Auxiliary Equipment, NEC) is correct.

Also, thank you for the information on the potential for exemption but my records show that we don’t quite meet the requirements to make such an
application at this time but may be something we can look at trying to accomplish with future improvement projects.

Look forward to hearing back from you,

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Monday, December 2, 2024 11:41 AM
To: Eric Lewis (CCY) <[e-mail]>
Subject: DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and
know the content is safe.
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…19/22

Hi Eric,

The DAQ has completed Align Precision- Cedar City LLC's updated Approval Order for site 10270. Before it's issued you have ten days to review the
document. Please get back to me with any questions or concerns by 12/12. If you approve of the document, please return a signed copy. The updated
permit is attached.

Additionally, please confirm the correct SIC code for this site. Currently, the SIC code is listed as 3728 (Aircraft Parts & Auxiliary Equipment, NEC).

Lastly, the latest compliance report for the facility notes that many of the approved pieces of equipment have been moved to a different site. Given the
reduction in the equipment and emissions at site 10270 you may want to explore the possibility of a Small Source Exemption (SSE) and permit
revocation. You can find more information about SSEs here: https://deq.utah.gov/air-quality/new-source-review-exemptions-from-permitting-air-quality.

The SSE application form can be accessed here: https://utahgov.co1.qualtrics.com/jfe/form/SV_3t4JtgzRudum7l3.

Please reach out with any questions. Hope you're having a good start to your week.

Lucia

Formkote T-50.pdf
244K
Lucia Mason <[e-mail]>Fri, Jan 3, 2025 at 3:56 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Hi Eric,
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…20/22
Thanks for the additional information. In regards to the SSE application, the HAP weight percentages listed in the Formkote T-50 SDS are greater than those in the
emission calculation spreadsheet. I recalculated the site's PTE using the weight percentages listed in the Fornkote-T50 SDS you provided and, assuming the same
consumption (66 gallons of Formkote T-50 over the past year), the site still qualifies as an SSE. However, if more than 83 gallons of Formkote T-50 are consumed
in a rolling 12-month period the facility will emit greater than 0.25 tons of toluene, and therefore exceed the individual HAP limit. Let me know if 83 gallons of
Formkote T-50 consumed per rolling 12 months is a reasonable consumption limit.
See the "DAQ Calculations" tab of the attached spreadsheet to reference my calculations. Let me know how you'd like to proceed.
Best,
Lucia
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Thank you.

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Hi Eric,
[Quoted text hidden]
Lucia

1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…21/22

10270 DAQ Calculations.xlsx
25K
Eric Lewis (CCY) <[e-mail]>Mon, Jan 6, 2025 at 3:37 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

66 gallons of Formkote T-50 should be our peak usage for a rolling 12-month period so 83 gallons seems like a reasonable consumption limit to me.

Thanks,
[Quoted text hidden]
Lucia Mason <[e-mail]>Mon, Jan 6, 2025 at 3:44 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Sounds good. Thank you.
[Quoted text hidden]
1/6/25, 4:09 PM State of Utah Mail - DAQ Approval Order Review, 10270: Metalcraft Technologies- Aircraft Parts Manufacturing Facility
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2892196424361751856&simpl=msg-a:r-5902809499246044853&simpl=msg-f:1818253252663445779&si…22/22
Lucia Mason <[e-mail]>
Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270
and 12202: Align Precision
8 messages
Lucia Mason <[e-mail]>Tue, Aug 20, 2024 at 9:55 AM
To: [e-mail]
Hi Eric,
The DAQ is making customary permit updates to your Approval Orders for sites 10270 and 12202. Please respond in the next week (by 8/27) with the following
information for both sites.
1. Site: physical address, phone number, and email (if applicable)
2. Company: physical address, billing address, mailing address, phone number, fax number (if applicable) and email
3. Environmental contact: physical address, mailing address, phone number, fax number (if applicable) and email
4. Billing contact: (if different from environmental contact): physical address, phone number, fax number (if applicable) and email
5. Name on Approval Order: (if different from environmental contact): physical address, mailing address, phone number, fax number (if applicable) and
email
Additionally, DAQ records show that both sites underwent an undocumented ownership change from Metalcraft Technologies to Align Precision. Please provide
proof of the ownership change. This could be in the form of the signature from the former owner (see attached Name and Ownership Change Notification Form) or
a document that includes evidence of the ownership change.
Please reach out with any questions.
Best,
Lucia
Ownership Change or Company Name Change Notification Form.pdf
34K
Eric Lewis (CCY) <[e-mail]>Tue, Aug 20, 2024 at 11:03 AM
To: Lucia Mason <[e-mail]>
Hi Lucia,

1/6/25, 4:08 PM State of Utah Mail - Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270 and 12202: Align Precision
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2672728583026922721&simpl=msg-a:r5662481634748737555&simpl=msg-f:1807926857018823062&simpl=…1/5
I am so sorry, I am not trying to dodge you or anything, I just have quite a bit I am juggling right now. I did have it on my list of tasks this week to make sure and
gather all of this information for you so I just wanted to reach out real quick and let you know I actually am here and will get this for you by next week.

Thank you for your patience!

ERIC LEWIS
EHS Coordinator
O:435.586.3871
[e-mail]
ALIGN PRECISION – Cedar City | 526 Aviation Way | Cedar City, UT 84721
From: Lucia Mason <[e-mail]>
Sent: Tuesday, August 20, 2024 9:56 AM
To: Eric Lewis (CCY) <[e-mail]>
Subject: Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270 and 12202: Align Precision

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the
content is safe.

Hi Eric,

The DAQ is making customary permit updates to your Approval Orders for sites 10270 and 12202. Please respond in the next week (by 8/27) with the following
information for both sites.
1. Site: physical address, phone number, and email (if applicable)
2. Company: physical address, billing address, mailing address, phone number, fax number (if applicable) and email
3. Environmental contact: physical address, mailing address, phone number, fax number (if applicable) and email
4. Billing contact: (if different from environmental contact): physical address, phone number, fax number (if applicable) and email
5. Name on Approval Order: (if different from environmental contact): physical address, mailing address, phone number, fax number (if applicable)
and email
1/6/25, 4:08 PM State of Utah Mail - Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270 and 12202: Align Precision
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2672728583026922721&simpl=msg-a:r5662481634748737555&simpl=msg-f:1807926857018823062&simpl=…2/5
Additionally, DAQ records show that both sites underwent an undocumented ownership change from Metalcraft Technologies to Align Precision. Please provide
proof of the ownership change. This could be in the form of the signature from the former owner (see attached Name and Ownership Change Notification Form) or
a document that includes evidence of the ownership change.
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Aug 20, 2024 at 11:35 AM
To: "Eric Lewis (CCY)" <[e-mail]>
Sounds good. Thanks for the update.
[Quoted text hidden]
Eric Lewis (CCY) <[e-mail]>Mon, Aug 26, 2024 at 3:23 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

10270:
1. Site: 526 Aviation Way, Cedar City UT 84721 - [phone]
2. Company: 526 Aviation Way, Cedar City UT 84721 - [phone]
3. Environmental contact: Eric Lewis, EHS Coordinator - 526 Aviation Way, Cedar City UT 84721 - [phone] - [e-mail]
4. Billing contact: (if different from environmental contact): 526 Aviation Way, Cedar City UT 84721 - [phone] - ap.align-ccy@alignprecision.
com
5. Name on Approval Order: (if different from environmental contact): N/A

12202:
1. Site: 597 N 1500 W, Cedar City UT 84721
2. Company: 526 Aviation Way, Cedar City UT 84721 - [phone]
3. Environmental contact: Eric Lewis, EHS Coordinator - 526 Aviation Way, Cedar City UT 84721 - [phone] - [e-mail]
4. Billing contact: (if different from environmental contact): 526 Aviation Way, Cedar City UT 84721 - [phone] - ap.align-ccy@alignprecision.
com
5. Name on Approval Order: (if different from environmental contact): N/A
1/6/25, 4:08 PM State of Utah Mail - Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270 and 12202: Align Precision
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2672728583026922721&simpl=msg-a:r5662481634748737555&simpl=msg-f:1807926857018823062&simpl=…3/5

I have attached the proof of ownership change we have on-hand, let me know if you need anything else.
[Quoted text hidden]
I.14 Align Precision - Cedar City, LLC.pdf
413K
Lucia Mason <[e-mail]>Mon, Aug 26, 2024 at 3:49 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Thank you! I'll reach out if I need more information.
[Quoted text hidden]
Lucia Mason <[e-mail]>Wed, Nov 13, 2024 at 2:54 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Hi Eric,
Is there a person you would like listed as your billing contact? If so, could you provide their name? If not, I'll list you as the billing contact.
Thanks,
Lucia
[Quoted text hidden]
Eric Lewis (CCY) <[e-mail]>Tue, Nov 19, 2024 at 1:37 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

You can keep me as the billing contact name, but the best email for billing is [e-mail]
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Nov 19, 2024 at 3:12 PM
To: "Eric Lewis (CCY)" <[e-mail]>
Thanks.
1/6/25, 4:08 PM State of Utah Mail - Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270 and 12202: Align Precision
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2672728583026922721&simpl=msg-a:r5662481634748737555&simpl=msg-f:1807926857018823062&simpl=…4/5
[Quoted text hidden]
1/6/25, 4:08 PM State of Utah Mail - Updated Contact Information and Proof of Ownership Change (Respond by 8/27, Division of Air Quality), 10270 and 12202: Align Precision
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2672728583026922721&simpl=msg-a:r5662481634748737555&simpl=msg-f:1807926857018823062&simpl=…5/5
Response Summary:
The form below will collect the information to start the revocation process. Please fill out the information and a NSR
Engineer will be contacting you with any follow up requirements.

Q2. Company/Owner Information:
Owner Name:ALIGN PRECISION - Cedar City, LLC.
Address 526 aviation way
City cedar city
State UT
Zip 84721

Q4. Contact Information:
Contact Name:Eric Lewis
Contact email:[e-mail]
Contact phone [phone]

Q3. Permit Information:
Site Name:ALIGN PRECISION - Cedar City, Plant 1
Site ID:10270
Permit ID: Ex DAQE-
111110001-21 DAQE-412-00

Q9. Is the AO revocation subject to the Oil and Gas PBR Registration? PBR Requirements
No

Q5. Please provide an explanation for the request to revoke your permit
Reduction in equipment and emissions.

Q6. The undersigned acknowledges they are the responsible party to provide DAQ with this information and
authorize DAQ to bill the fee for revoking an AO. As authorized by Utah Legislature, the fee is the time spent
by the Permitting staff.
[Click here]

Embedded Data:
N/A