The URL can be used to link to this page

Home My WebLink AboutDAQ-2025-001460 DAQE-AN128530003-25 {{$d1 }} Chas Dallas De La Rue North America Holdings 6401 Commerce Drive Irving, TX 75063 chas.dallasiii@delarue.com Dear Mr. Dallas: Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN0128530001-09 for a 10-Year Review and Permit Updates Project Number: N128530003 The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year administrative review of this source and its respective AO. De La Rue North America Holdings must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Katie Andersen, who can be contacted at (385) 515-1748 or kandersen@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. Sincerely, {{$s }} Bryce C. Bird Director BCB:KA:jg cc: Bear River Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director March 6, 2025 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN128530003-25 Administrative Amendment to Approval Order DAQE-AN0128530001-09 for a 10-Year Review and Permit Updates Prepared By Katie Andersen, Engineer (385) 515-1748 kandersen@utah.gov Issued to De La Rue America Holdings - Hologram Manufacturing Facility Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality March 6, 2025 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 3 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 5 PERMIT HISTORY ..................................................................................................................... 6 ACRONYMS ................................................................................................................................. 7 DAQE-AN128530003-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name De La Rue North America Holdings De La Rue North America Holdings - Hologram Manufacturing Facility Mailing Address Physical Address 6401 Commerce Drive 1750 North 800 West Irving, TX 75063 Logan, UT 84321 Source Contact UTM Coordinates Name: Chas Dallas 429,071 m Easting Phone: (435) 265-8695 4,623,970 m Northing Email: chas.dallasiii@delarue.com Datum NAD83 UTM Zone 12 SIC code 3993 (Signs & Advertising Specialties) SOURCE INFORMATION General Description De La Rue North America Holdings manufactures holographic images for gas fireplaces, identifications, security, and other applications. Isopropyl alcohol (IPA) is used to develop various holographic images. NSR Classification 10-Year Review Source Classification Located in Attainment Area Cache County Airs Source Size: B Applicable Federal Standards None Project Description The purpose of this 10-Year Review is to update the language, format, and layout to match current DAQ permitting standards. DAQE-AN128530003-25 Page 4 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) Volatile Organic Compounds 0 14.06 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Xylenes (Isomers And Mixture) (CAS #1330207) 0 20 Change (TPY) Total (TPY) Total HAPs 0 0.01 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] DAQE-AN128530003-25 Page 5 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Hologram Manufacturing Facility II.A.2 Five (5) IPA Baths with Cooling Lids Maximum Capacity: 20 gallons each II.A.3 One (1) IPA Drum Capacity: 55 gallons II.A.4 One (1) Diaphragm Pump II.A.5 Two (2) Spray Booths II.A.6 Two (2) Stacks SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Requirements: II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All spray booths - 10% opacity B. All stacks - 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] II.B.1.b The owner/operator shall store all VOC/HAP-containing materials and VOC/HAP-laden rags in covered containers except when in use. [R307-325, R307-401-8] II.B.1.c The owner/operator shall not emit more than 14.06 tons of VOCs per rolling 12-month period from evaporative sources (paint booths, degreasers, contact cement applicators, etc., and associated operations) on site. [R307-401-8] II.B.1.c.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] DAQE-AN128530003-25 Page 6 II.B.1.c.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs. [R307-401-8] II.B.1.c.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC-emitting material, such as paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. The maximum percent by weight of VOCs in each material used C. The density of each material used D. The volume of each VOC-emitting material used E. The amount of VOCs emitted from each material F. The amount of VOCs reclaimed and/or controlled from each material G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8] II.B.1.d The owner/operator shall comply with all applicable requirements of R307-304 Solvent Cleaning. [R307-304] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN0128530001-09 dated December 3, 2009 Incorporates Additional Information dated January 2, 2025 DAQE-AN128530003-25 Page 7 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE- RN128530003 February 19, 2025 Chas Dallas De La Rue North America Holdings 6401 Commerce Dr Irving, TX 75063 chas.dallasiii@delarue.com Dear Chas Dallas, Re: Engineer Review: Administrative Amendment to Update AO DAQE-AN0128530001-09 for a 10-Year Review and Permit Updates Project Number: N128530003 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. De La Rue North America Holdings should complete this review within 10 business days of receipt. De La Rue North America Holdings should contact Katie Andersen at (385) 515-1748 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen at kandersen@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If De La Rue North America Holdings does not respond to this letter within 10 business days, the project will move forward without source concurrence. If De La Rue North America Holdings has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor March 3rd, 2025 Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N128530003 Owner Name De La Rue North America Holdings Mailing Address 6401 Commerce Dr Irving, TX, 75063 Source Name De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility Source Location 1750 North 800 West Logan, UT 84321 UTM Projection 429,071 m Easting, 4,623,970 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3993 (Signs & Advertising Specialties) Source Contact Chas Dallas Phone Number (435) 265-8695 Email chas.dallasiii@delarue.com Billing Contact David Peacock Phone Number (435) 753-5775 Email david.peacock@delarue.com Project Engineer Katie Andersen, Engineer Phone Number (385) 515-1748 Email kandersen@utah.gov Notice of Intent (NOI) Submitted October 9, 2024 Date of Accepted Application January 13, 2025 Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 2 SOURCE DESCRIPTION General Description De La Rue Authentication manufactures holographic images for gas fireplaces, identifications, security, and other applications. Isopropyl alcohol (IPA) is used to develop various holographic images. NSR Classification: 10 Year Review Source Classification Located in Attainment Area Cache County Airs Source Size: B Applicable Federal Standards Project Proposal Administrative Amendment to Update AO DAQE-AN0128530001-09 for a 10-Year Review and Permit Updates Project Description The purpose of this 10-Year Review is to update the language, format, and layout to match current DAQ permitting standards EMISSION IMPACT ANALYSIS This is a 10-Year Review to update the language, format, and layout of the Approval Order to match current DAQ permitting standards. There are no changes to equipment nor emissions at this time. Therefore, modeling is not required at this time. [Last updated January 2, 2025] Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 3 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) Volatile Organic Compounds 0 14.06 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Xylenes (Isomers And Mixture) (CAS #1330207) 0 20 Change (TPY) Total (TPY) Total HAPs 0 0.01 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review This is a 10-Year Review to update the language, format, and layout of the Approval Order to match current DAQ permitting standards. There are no changes to equipment nor emissions. Thus, a BACT analysis is not required at this time. [Last updated January 2, 2025] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307- 401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 5 SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Hologram Manufacturing Facility II.A.2 NEW Five (5) Isopropyl Alcohol Baths with Cooling Lids Maximum Capacity: 20 gallons each II.A.3 NEW One (1) Isopropyl Alcohol Drum Capacity: 55 gallons II.A.4 NEW One (1) Diaphragm Pump II.A.5 NEW Two (2) Spray Booths II.A.6 NEW Two (2) Stacks SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 NEW Site Wide Requirements: II.B.1.a NEW The owner/operator shall not allow visible emissions from the following emissions points to exceed the following values: A. All spray booths - 10% opacity B. All stacks - 10% opacity. [R307-401-8] II.B.1.a.1 NEW Opacity observations of emissions from stationary source shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] II.B.1.b NEW The owner/operator shall store all VOC/HAPs containing materials and VOC/HAPs laden rags in covered containers except when in use. [R307-325, R307-401-8] Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 6 II.B.1.c NEW The owner/operator shall not emit more than 14.06 tons of VOCs per rolling 12-month period from evaporative sources (paint booths, degreasers, contact cement applicators, etc. and associated operations) on site. [R307-401-8] II.B.1.c.1 NEW The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.1.c.2 NEW The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs. [R307-401-8] II.B.1.c.3 NEW The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. The maximum percent by weight of VOCs in each material used C. The density of each material used D. The volume of each VOC-emitting material used E. The amount of VOCs emitted from each material F. The amount of VOCs reclaimed and/or controlled from each material G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8] II.B.1.d NEW The owner/operator shall comply with all applicable requirements of R307-304 Solvent Cleaning. [R307-304] Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 7 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN0128530001-09 dated December 3, 2009 Incorporates Additional Information dated January 2, 2025 REVIEWER COMMENTS 1. Comment regarding 10-Year Review: This is a 10-Year Review to update the language, format, and layout of the Approval Order to match current DAQ permitting standards. When the source goes through the next modification, the emissions should be updated. [Last updated January 13, 2025] 2. Comment regarding State Rule Applicability: R307-304 Solvent Cleaning R307-304 applies to solvent cleaning operations within Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, and Weber counties. Effective on September 1, 2018, this subpart applies to facilities using 55 gallons or more a year of VOC containing solvent products, minus exempt materials, for solvent cleaning operations. De La Rue Authentication Systems uses more than 55 gallons of VOC containing solvent products a year. Thus, the source is subject to this state rule. [Last updated February 19, 2025] 3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source; 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Source; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants, 4. Any Title IV affected source. This source is not a major source nor is it a Title IV affected Source. The source is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP), nor 40 CFR 63 (MACT) requirements. There are no other reasons why this source would be required to obtain a Title V permit. Therefore, Title V does not apply to this source. [Last updated February 19, 2025] Engineer Review N128530003: De La Rue Authentication Solutions Inc.- Hologram Manufacturing Facility February 19, 2025 Page 8 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQC-I301-22 Site tD 128s3 (Bl) MEMORANDUM File -DE LA RUE AUTHENTICATION SOLUTIONS, HOLOGRAPHICS) INC. (PREVIOUSLY DUPONTTO: THROUGH: FROM: DATE: SUBJECT: Rik Ombach, Minor Source Compliance Manager @ Irene Tucker, Environmental Scientist September 26,2022 Full Compliance Evaluation, B, Cache County tr_ INSPECTION DATE: SOURCE LOCATION: SOURCE CONTACT: OPERATING STATUS: PROCESS DESCRIPTION: APPLICABLE REGIILATIONS: September 22,2022 1750 North 800 West, Logan, Cache County (800 West is not a through street. Approach from 600 West and enter the dead-end street on 1800 North) Chas Dallas III, Operations Manager : 43 5 -265 -869 5, chas. dallasiii@delarue.com Operating De La Rue Authentication is a secure facility, manufactures holographic images for gas fireplaces, identifications, security and other applications. Isopropyl alcohol (IPA) is used in the Mastering Area Developing Room, which consists of a 55-gallon drum of IPA, a diaphragm pump and 5 stainless steel baths with cooling lids. The drum and pump are located outside of the building and the baths are located in the developing room. The baths have varying temperatures and IPA/water concentrations (70oh to 100% IPA). Each bath contains about 25 gallons of solution and is used to develop the holographic master image. Baths are refilled on the average once/day due to consumption and losses. To refill the baths with IPA an operator will use the diaphragm pump to pump the IPA (ambient temperature and pressure) from the 55-gallon drum to the inside of the developing room into a S-gallon safety can designed to handle flammable liquids. The material is then transferred to the baths. The baths are used 5 days/week for a total of l6 hours/day. Two small spray booths. One is used to make models. Second spray paint booth was used to spray about 144 12 oz cans per year black paint on the back of the hologram master image, but a sticker is now used to give better reflection in the developing of the images onto photo-ready plastic material. AO DAQE AN0128530001-09, dated December 3,2009 Status: In compliance. The company is located at the above address. On February 6, 2017, DAQ issued a Notification of Company Name and Ownership Change (DAQE-GN128530002-17) to De La Rue North America Holdings (parent company). Section I: GENERAL PROVISIONS I.l All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] SOIIRCE U\SPECTION EVALUATION: Name of Permittee: Dupont Holographics, Inc. 1750 North 800 West Logan, Utah8432l Phone Number Fax Number Status: T,2 Status: I.3 Status: t.4 Status: L5 (43s) 7s3-s77s (43s) 7s3-s876 This is not a compliance issue. The limits set forth in this AO shall not be exceeded without prior approval. [R307401] In compliance. De La Rae Authenticution did not exceed any of the limits set forth in this AO. Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] In compliance. De La Rue Authentication hus not made any modifications to the equipment or processes approved by this AO. All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the 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. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401] In compliance. De Lo Rue Authentication plons to maintain records for at least two years. At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a marurer 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. [R3074014] Status: In compliance. De La Rue Authentication maintains records of maintenance activities performed on equipment oathoriaed by thk AO. See the attachment for additional information. I.6 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. [R307-1s0] Status: Not upplicuble. De La Rue Authentication is not required to submit an Emissions Inventory Report I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable Breakdowns. [R307-107] Status: In compliance. De La Rue Authenticotion did not expefience any breokdowns resulting in an emissions evenl Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.l HologramManufacturingFacility Il.A.2 Five (5) Isopropyl Alcohol Baths with Cooling Lids Maximum Capacity: 20 gallons each II.A.3 One (1) Isopropyl Alcohol Drum Capacity: 55 gallons II.A.4 One (l) Diaphragm Pump II.A.5 Two (2) Spray Booths II.4.6 Two (2) Stacks Status: In compliance. There toere no new or unapproved equipment identified onsite during this inspection. II.B Requirements and Limitations II.B.1 The Hologram Manufacturing Facility shall be subject to the following II.B.l.a Visible emissions from the following emission points shall not exceed the following values: A. All spray booths - 10% opacity B. All stacks - l}%opacity. [R307401-8] Status: In compliance. There were no visible emissions observedfrom the spray booths or stacks during this inspection. See the attachmentfor additionol information. II.B.l.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In compliance. The opacity observations were conducted according to 40 CFR 60, Appendk A, Method 9. ILB.l.b The VOC/HAPs containing materials and VOC/HAPs laden rags shall be stored in covered containers (except when in use). [R307401-8] Status: In compliance. De La Rue Authentication uses isopropyl alcohol for cleaning, and the spent liquid is collected in a drum for offsite disposal by Safe Harbor. ll.B.1.c The plant-wide emissions of VOC from the paint booths, degteasers, contact cement applicators, etc. and associated operations shall not exceed 14.06 tons per rolling l2-month period. [R307- 401-81 Status: In compliance. The plant-wide emissions of VOC from De La Rue Authentication in a tolling I2-monthfrom September 2021 to August 2022 indicated 3.72 tons. II.B.l.c.l Compliance with the limitation shall be determined on a rolling l2-month total. Based on the twentieth day of each month, a new l2-month total shall be calculated using data from the previous l2 months. [R307-401-8] Status: In compliance. De La Rue Authentication is in compliance with the limitstions on a rolling 12-month. II.B.1.c.2 The VOC emissions shall be determined by maintaining a record of VOC emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC in each material used D. Gallons of each VOC emitting material used E. The amount of VOC emitted monthly by each material used shall be calculated by the following procedure: VOC: [% VOC by Weight/lO0] x [Density (lb/gal)] x [Gal Consumed] x (1 ton/2,000 lb) F. The amount of VOC emitted monthly from all materials used. G. The amount of VOC reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307401-8] Status: In compliance. De Lo Rue Authentication determines the VOC emissions as required by this AO Condition. R307-304. Solvent Cleanins. UTAH SOURCE RULES EVALUATTON Status: In compliance. De La Rae Autltentication uses Isopropyl Alcoholfor cleaning. The YOC content of Isopropyl Alcohol k 6.55 lb/gal This indicates compliance with the YOC content in Table I oJR307-304-5. See the SDS in the attachmenl Rule 350: Miscellaneous Metal Parts and Products Coatings Status: In compliance. De La Rue Authentication operates two very small spray booths. The coatings applied arefrom spray cans. De La Rue Authentication is claiming the exemption in R307-350- s (1)(.). EMISSIONS INVENTORY: Not applicable. De La Rue Authentication is not required to submit an Emissions Inventory Report PREVIOUS ENFORCEMENTACTIONS: No enforcement actions in past five years. COMPLIANCE STATUS &RECOMMENDATIONS: De La Rue Authentication Solutions is in compliance with the conditions of the AO DAQE-AN0128530001-09, dated December 3,2009. RECOMMENDATTON FOR NEXT INSPECTION: Inspect as usual. This is a secure facility. Several process areas require a sterile field. RECOMMENDATIONFORNSR: None at this time. ATTACHMENTS:Visible Emissions Observation Form, SDS STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITYDIVISION OF AIR QUALITY Page _ of _ Source Name: Street Address: City/County: Phone: Site lD: Facilitv: Control Eq Sky Conditions: Clear ffi Precipitation' rvo tf,vtu, Wind: Direction: _ Ambient Temp: of Height Relative to Observer: Distance From Observer: PartlyCloudy [ ] Overcast Speed: _ mph RH:_ % tl Condensed WaterVaporpresent: No I J yes I JAttachedlJ Detachedll -ength of Condensed Water Vapor plume: Background: COMMENTS: iketch process unit: indicate observer position relative to;ource; indicate potential emission points and/oractualrmission points. I have received a copy of these observations: SIGNATURE: Printed Name: Emission Point: sec mln 0 15.es )so 45 1 (.^s" 2 \,\$} 3 4 " \Nl /Nrff, 5 \'!N.\d h$- 6 {r\#/ 7 \8c\\\9\\ 10 1'l 12 n rr wrnd 2 Emission point with plume c])server position x rserver's Signature:Title: SAFETY DATA SHEET I q OPROPYL ALC O HOL 99o/o 1. CHEPIICAL NAME AND COMPM DATE: 3/L9 ZAD Formulated/Manufactured By; Information Telephone Number: For Chemical Spill Emergency Call: Product Name: CAS Number: . Tower Productsr lnc. 27 03 F r eeruansburg Avenue Easton, PA 18045 1 -800-5 27-8 626 or 6t 0-253 -620 6 CHEMTREC: 1 -800-424-9300 ISOPROPYL ALCOHiOL gg% 6743-0 2. IIAZARDS TDENTIFICATION Flarnmable Liquids (Category 2) lnec_ing Target Organ Toxicity - Single Exposure (Category 3)Eye Initation (Category 2A) @o GHS Ctassificatio4 Pictograrn(s) Signal Wor-d DANGER! Hazard statement(s) H225: HIGHLY FLAMMABLE LIQUID & VAPOR.H336: MAY CAUSE DROWSTNESS on DVZINESSH3l9: CAUSES SERTOUS EyE TRRITATTON. H3l6: CAUSES MILD SKIN IRRITATTON. Precautionary statement(s) Prevention: P210: KEEP AWAY FROM HBAT/SPARKs/opEN FLAMES/HoT suRFACES AND orHER TGNITT'N souRCEs,NO SMoKING. r uvr\r.f1.\/DD f!.r. \261: AVOID BREATHING FuME/Dusr/cASA,TIST/vApoRS/spRAy. P280: wEAR PRorEcrrvE GLovES/PRoTEcrrvE cLorlrING/EyE pRorECTroN/FACE pRoTECTIoNP264: WASH SKIN TIIOR0UGHLY AFTER TIANDLING. . Response: P370+P378: IN cAsE oF FIRE: usE DRy cHEMTcAL oR cARBoN DroxrDE To ExrlNcursH.P3O4+P340: IF INFIALED: REMOVE PERSON TO FRESH eIn aNo KEEP CoMFORTABLE FoR BREATHTNG.P303+P361+P353 IF-ONSKIN (oR HAIR): TAKE oFF iMM;DIATELy ALL coNTAMTNATED cLorHINc. RIN.ElKrN WTTH WATER (OR SHOWER). P3O5+P351+P338: IF IN EYES: NNUST CAUTIOUSLY WITH WATER FOR SEVERAL MINUTES. REMOVE CONTACTLENSES, IF PRESENT AND EASY TO DO. CONTINUE RINSING.Storage: P4O3+P233+P405: STORE IN A WELLYENfiLATED PLACE. KEEP CONTAINER TIGHTLY CLOSED. STORELOCKED UP. SAFETY DATA SHEET ISOPROPYL ALCOHOL 99o/o DATE: 8. EXPOSURE CONTROLS AND PERSONAL PROTECTION Exposure Guidellnes: COMPONENT Isopropyl Alcohol OSIIA CAS No. PDL/T\ryA67-63-0 400ppm ACGIH ACGTH OTHER TLV/TWA TLV/ST4L RATING200ppm 400ppm Exposure Controls: Avoid open electrical sources near product vapor areas. Personal Protection Equipment: Eyes: Chemical splash goggles recommended. Skin and body: Impervious or chemical resistant gloves (consult safety equipment supplier). Respiratory: Ventilation in work at'ea should be sufficient to maintain atmosphere with vapor level below lowest listed TLV. If TLV's are exceede{ use a respirator with appropriate MOSH approved carhidges or supplied air equipment. 9. PHYSICAL AND CHEMTCAL PROPERTTES Appearance: Clear colorless liquid. Odor: Characteristic odor pH: N/A Metting Point N/A Boiling Point: 180o F Flnsh Point: (Tag Closed Cup Method) 53o F (12" C) Flammable Limits: LEL: 2$% UEL: 12.7% Vapor Pressure: (mmHg) 33 @68'F (20" C) VaporDensity: (Air: l) 2.1 Specilic Gravity: (Water: l) 0.787 @68" F (20'C) Solubility in water: Complete @68" F (20'C) Maojmum VOC Content: 6.55 LblGal (785 Glnll-) Maximum YAC Yo: 100% (EPA Method 24) Odor Threshold: N/A Evaporation Rater N/A RelativeDensity: NiA Partition Coefficient: N-Octano/Water: N/A Auto-ignition Tempcrature: N/A Decornposition Temperature: N/A Viscosity: N/A 10. STABILITY AND REACTIVITY Chemical Stability: Stable Incompatible Materials: Avoid strong oxidizing agents. Hazardous Decomposition Products: Carbon Monoxide and or Carbon Dioxide. Carbon Monoxide is highly toxic if inhaled, Carbon Dioxide in sufficient concentrations, can lead to asphyxiation. Hazardous Polymerization: Will not occur. Conditions to Avoid: Avoid exposure to high heat sources, electrioal and welding aros, open flame and strong oxidizing agents, Warnlng: Spontaneous combustion may occur when solvent soaked combustible materials (paper, cotton etc.) are allowed to stand in confined areas. SAFETY DATA SHEET 15. REGULATORY INT'ORMATTON ISO PROPYL ALCO HOL 99o/o DATE: 3 0L9 Product tnav contaiu components which are further regulated by state andlorlocal agencies - Consult AppropriateAgencies. Noffication status: U.S.A.: Toxic Substances Control Act [SCA) y Canada: Domestic Substances List (DSL): y 16. OTHER INFORMATION For More Information, Consult To*er froao.lffiThis I[formatlon Herein Is Given rn Good Faith, But No Warranty, Express or Implied Is Mnde. Date of Preparation: January l,Z}ls Date of Revision: Marchlg,Z0lg Katie Andersen <kandersen@utah.gov> De La Rue Authentication Solutions Air Quality Permit Update 7 messages Katie Andersen <kandersen@utah.gov>Thu, Jan 2, 2025 at 2:29 PM To: chas.dallasiii@delarue.com Hello Chas Dallas, The Utah Division of Air Quality (DAQ) has initiated a 10-Year Review for the purpose of updating the language, format, and layout of Approval Order DAQE-AN0128530001-09 for De La Rue Authentication Solutions. The DAQ typically initiates 10-Year Reviews once an approval order has been active for 10 or more years. I've been assigned as the project engineer for this permit update. I have some questions to verify contact information, location information, and equipment information. Based on the latest compliance inspection report, you are listed as the source contact. Would you be the best person to direct my questions to or is there another person over the permitting or environmental concerns I could talk with? I appreciate your assistance! Cheers, Katie Andersen -- Katie Andersen Engineering Technician I | Minor NSR Section M: (385) 515-1748 airquality.utah.gov Dallas III, Chas (Logan) <chas.dallasiii@delarue.com>Thu, Jan 2, 2025 at 2:42 PM To: Katie Andersen <kandersen@utah.gov> Hi Katie, Happy new year! Yes, please direct any queries my way, and I will provide a prompt response. 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…1/7 Thanks, Chas Dallas III | De La Rue Plant Manager, Authentication chas.dallasiii@delarue.com | Mobile: +1-435-265-8695 1750 N. 800 W. Logan, Utah 84321, USA | www.delarue.com Follow De La Rue online: CONFIDENTIAL From: Katie Andersen <kandersen@utah.gov> Sent: Thursday, January 2, 2025 2:29 PM To: Dallas III, Chas (Logan) <chas.dallasiii@delarue.com> Subject: De La Rue Authentication Solutions Air Quality Permit Update Attention: This email has originated from outside De La Rue. Please take extra care when opening links or attachments even if you have verified the sender. If in doubt, contact the IT Service Desk EXTERNAL EMAIL - This email was sent by a person from outside your organization. Exercise caution when clicking links, opening attachments or taking further action, before validating its authenticity. Secured by Check Point You don't often get email from kandersen@utah.gov. Learn why this is important Hello Chas Dallas, The Utah Division of Air Quality (DAQ) has initiated a 10-Year Review for the purpose of updating the language, format, and layout of Approval Order DAQE-AN0128530001-09 for De La Rue Authentication Solutions. The DAQ typically initiates 10-Year Reviews once an approval order has been active for 10 or more years. I've been assigned as the project engineer for this permit update. I have some questions to verify contact information, location information, and equipment information. Based on the latest compliance inspection report, you are listed as the source contact. Would you be the best person to direct my questions to or is there another person over the permitting or environmental concerns I could talk with? 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…2/7 I appreciate your assistance! Cheers, Katie Andersen -- Katie Andersen Engineering Technician I | Minor NSR Section M: (385) 515-1748 airquality.utah.gov Disclaimer: This e-mail is sent on behalf of De La Rue PLC (Company No 3834125), De La Rue International Limited (Company No 720284) or De La Rue Holdings Limited (Company No 58025) all registered in England with their registered offices at: De La Rue House, Jays Close, Basingstoke, Hampshire RG22 4BS. The e-mail and any attached files are strictly confidential and are intended solely for the addressee. If you have received this email in error, please notify the sender and then delete the e-mail and any attachments. You are advised to ensure that you have adequate virus protection as we accept no liability for any viruses. For information about how we process data, please see our privacy policy. image001.png 1K Katie Andersen <kandersen@utah.gov>Thu, Jan 2, 2025 at 3:46 PM To: "Dallas III, Chas (Logan)" <chas.dallasiii@delarue.com> Chas, Awesome! Thank you for the quick response. Will you please confirm the following information: 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…3/7 1. The source contact is currently listed as Carrie Christofferson on the current Approval Order, with a phone number of 435-753-5775. Is she the best source contact? If not, will you please provide the name, phone number, email address, and business mailing address of the best source contact. 2. The current business name is De La Rue Authentication Solutions Inc. Is this correct? 3. The business address and mailing address are: 1750 North 800 West Logan, Utah, 84321. Is that correct? 4. Please provide the billing contact information: name of contact, billing address, phone number, and email 5. The current Approval Order lists the following equipment: five (5) isopropyl alcohol baths with a capacity of 20 gallons each, one (1) isopropyl alcohol drum with a capacity of 55 gallons, one (1) diaphragm pump, two (2) spray booths, and two (2) stacks. Is this equipment still in use? Are there any other pieces of equipment that have not been added to the permit? At the moment, I believe this is all the information I need to update the current Approval Order. Cheers, Katie Andersen [Quoted text hidden] -- [Quoted text hidden] Dallas III, Chas (Logan) <chas.dallasiii@delarue.com>Thu, Jan 2, 2025 at 3:56 PM To: Katie Andersen <kandersen@utah.gov> Hi Katie, See my responses inline below highlighted in yellow. Thanks, Chas Dallas III | De La Rue Plant Manager, Authentication chas.dallasiii@delarue.com | Mobile: +1-435-265-8695 1750 N. 800 W. Logan, Utah 84321, USA | www.delarue.com Follow De La Rue online: CONFIDENTIAL 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…4/7 From: Katie Andersen <kandersen@utah.gov> Sent: Thursday, January 2, 2025 3:47 PM To: Dallas III, Chas (Logan) <chas.dallasiii@delarue.com> Subject: Re: De La Rue Authentication Solutions Air Quality Permit Update Attention: This email has originated from outside De La Rue. Please take extra care when opening links or attachments even if you have verified the sender. If in doubt, contact the IT Service Desk EXTERNAL EMAIL - This email was sent by a person from outside your organization. Exercise caution when clicking links, opening attachments or taking further action, before validating its authenticity. Secured by Check Point You don't often get email from kandersen@utah.gov. Learn why this is important Chas, Awesome! Thank you for the quick response. Will you please confirm the following information: 1. The source contact is currently listed as Carrie Christofferson on the current Approval Order, with a phone number of 435-753-5775. Is she the best source contact? If not, will you please provide the name, phone number, email address, and business mailing address of the best source contact. a. Carrie is no longer with the business Updated Contact Details: Chas Dallas 435-265-8695 Chas.dallasiii@delarue.com Mailing address below 2. The current business name is De La Rue Authentication Solutions Inc. Is this correct? a. Yes. However we are in the process of being sold with a new name TBD. We will submit a change request upon confirmation. 3. The business address and mailing address are: 1750 North 800 West Logan, Utah, 84321. Is that correct? a. Correct 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…5/7 4. Please provide the billing contact information: name of contact, billing address, phone number, and email David Peacock 1750 North 800 West Logan, Utah, 8432 435-753-5775 David.peacock@delarue.com 5. The current Approval Order lists the following equipment: five (5) isopropyl alcohol baths with a capacity of 20 gallons each, one (1) isopropyl alcohol drum with a capacity of 55 gallons, one (1) diaphragm pump, two (2) spray booths, and two (2) stacks. Is this equipment still in use? Are there any other pieces of equipment that have not been added to the permit? a. The above list is accurate. Nothing has been added. [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] image001.png 1K Katie Andersen <kandersen@utah.gov>Mon, Jan 13, 2025 at 2:24 PM To: "Dallas III, Chas (Logan)" <chas.dallasiii@delarue.com> Chas, I have a follow up question. What is De La Rue's Standard Industrial Classification (SIC) code? Cheers, Katie Andersen [Quoted text hidden] Dallas III, Chas (Logan) <chas.dallasiii@delarue.com>Mon, Jan 13, 2025 at 3:04 PM To: Katie Andersen <kandersen@utah.gov> Hi Katie, 551112 [Quoted text hidden] [Quoted text hidden] image001.png 1K Katie Andersen <kandersen@utah.gov>Tue, Jan 14, 2025 at 1:47 PM To: "Dallas III, Chas (Logan)" <chas.dallasiii@delarue.com> Chas, 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…6/7 Do you have a 4 digit SIC code? The one you provided doesn't seem to be the correct code. It is coming up as Offices of other Holding Companies in the NAICS Code Descriptions. Cheers, Katie [Quoted text hidden] 1/23/25, 9:52 AM State of Utah Mail - De La Rue Authentication Solutions Air Quality Permit Update https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-878748352471845571&simpl=msg-a:r-142262170131812…7/7