DAQ-2024-008272

DAQE-AN127390007-24

{{$d1 }}

Corbet Austin
Storm Products Incorporated
165 South 800 West
Brigham City, UT 84302
[e-mail]

Dear Mr. Austin:

Re: Approval Order: Modification to Approval Order DAQE-AN127390006-16 to Add Laser
Etching and a Baghouse
Project Number: N127390007

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
31, 2023. Storm Products Incorporated must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Tim DeJulis, who can be contacted at [phone] or
[e-mail]. 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. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TD: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 [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

June 4, 2024

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-AN127390007-24
Modification to Approval Order DAQE-AN127390006-16
to Add Laser Etching and a Baghouse

Prepared By
Mr. Tim DeJulis, Engineer
[phone]
[e-mail]

Issued to
Storm Products Incorporated - Bowling Ball Manufacturing

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

June 4, 2024
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.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN127390007-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Storm Products Incorporated Storm Products Incorporated - Bowling Ball
Manufacturing

Mailing Address Physical Address
165 South 800 West 165 South 800 West
Brigham City, UT 84302 Brigham City, UT 84302

Source Contact UTM Coordinates
Name: Corbet Austin 414,215 m Easting
Phone: [phone],595,544 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3949 (Sporting & Athletic Goods, NEC)

SOURCE INFORMATION
General Description
Storm Products Incorporated (Storm Products), located in Brigham City, Box Elder County, creates
bowling balls for shipment to national and international customers. Bowling ball manufacturing involves
six (6) stages: casting the core, casting the ball around the core, cutting the ball to the proper dimensions,
drilling finger holes, polishing, and etching. Finished bowling balls are packaged and stored for shipping.
Particulates from cutting, cleaning, sizing, finishing, and etching are sent to an outdoor baghouse, then
vented back into the building or exhausted outside for heat control. A closed room houses three (3)
styrene and two (2) isocyanate tanks. Polyol is stored in large containers.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: B
Applicable Federal Standards
None

DAQE-AN127390007-24
Page 4

Project Description
Storm Products has requested a modification to AO DAQE-AN127390006-16, dated April 21, 2016, to
replace an internally vented fabric filter with an external venting baghouse. The plant will use the
baghouse to control emissions from ball finishing and laser etching, which place various designs on each
bowling ball. The laser etching will emit 0.02 tons/yr of PM10 and 0.01 tons/yr of PM2.5 after control
during the manufacture of 960,000 bowling balls per year. The number of bowling balls manufactured
will stay at the same level as in the previous AO. The baghouse has a control efficiency of 99.9%.

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)
Particulate Matter - PM10 0.02
Particulate Matter - PM2.5 0.01
Volatile Organic Compounds 0 28.31

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Styrene (CAS #100425) 0 5540
Xylenes (Isomers And Mixture) (CAS #1330207) 0 19520
Change (TPY) Total (TPY)
Total HAPs 0 12.53

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]

DAQE-AN127390007-24
Page 5

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Brigham City Bowling Products Manufacturing Plant

II.A.2 Baghouse
One (1) baghouse
Flowrate: 27,000 scfm
Controls emissions from the laser etcher

II.A.3 Batching Systems
Two (2) two-vessel closed batching systems

II.A.4 Batching System
One (1) three-vessel closed batching system

II.A.5 Casting Machine
One (1) Peyton-Technology casting machine

II.A.6 Ball Polisher
One (1) filtered bowling ball polisher

This equipment is listed for informational purposes only.

II.A.7 Parts Washers
Various Parts Washers

DAQE-AN127390007-24
Page 6

II.A.8 Vent Stack
One (1) Vent Stack
43 feet from ground level
7,500 scfm blower

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 VOC and HAPs Emission Limitations
II.B.1.a The owner/operator shall comply with all applicable requirements of R307-304, Solvent
Cleaning, and R307-335, Degreasing, for all applicable emission units on site.
[R307-304, R307-335]

II.B.1.b The owner/operator shall not emit more than the following from the bowling ball formers,
contact cement applicators, batching and casting systems, and associated operations:

28.31 tons of VOC per rolling 12-month period.

9.76 tons of xylene per rolling 12-month period.

2.77 tons of styrene per rolling 12-month period.

[R307-401-8]

II.B.1.b.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 determine and log the monthly
consumption of the materials containing VOCs and HAPs. [R307-401-8]

II.B.1.b.2 The owner/operator shall keep records of consumption for all periods when the plant is in
operation. These records of consumption shall include the following:

A. Name of the VOC or HAP- emitting material.

B. Density of each material used (pounds per gallon).

C. Percent by weight of all VOCs and HAPs in each material used.

D. Gallons of each VOC or HAP- emitting material used.

E. The amount of VOC or HAPs emitted monthly by each material.

[R307-401-8]

DAQE-AN127390007-24
Page 7

II.B.1.b.3 The owner/operator shall calculate the amount of VOC or HAPs emitted with the following
procedure:

VOC = monthly material throughput (in 1,000 pounds) x VOC factor in (in pounds/1,000 pounds
of material).

HAPs = % styrene or xylene by weight/100 x density (lb/gal) x gallons used x 1 ton/2000 lb x
emission factor.

The owner/operator has used 83% in its xylene calculations and 0.3% in its styrene calculations.

[R307-401-8]

II.B.1.c The owner/operator shall not operate for more than 16 hours per day and five (5) days per week.
[R307-401-8]

II.B.1.c.1 The owner/operator shall determine the hours of operation by supervisor monitoring and
maintaining an operations log. [R307-401-8]

II.B.2 Baghouse Requirements
II.B.2.a The owner/operator shall use a baghouse to control particulate emissions from the laser etcher of
each bowling ball produced. [R307-401-8]

II.B.2.b The owner/operator shall not allow visible emissions from the baghouse to exceed 10% opacity.
[R307-401-8]

II.B.2.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across the baghouse. [R307-401-8]

II.B.2.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.2.c.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

II.B.2.d During operation of the baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between two (2) and seven (7) inches of water column.
[R307-401-8]

II.B.2.d.1 The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

II.B.2.d.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Daily static pressure differential readings;

C. Date of reading.

[R307-401-8]

II.B.2.e At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

DAQE-AN127390007-24
Page 8

II.B.2.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN127390006-16 dated April 21, 2016
Is Derived From NOI dated October 30, 2023
Incorporates Additional information dated March 18, 2024

DAQE-AN127390007-24
Page 9

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-IN127390007-24

April 25, 2024

Corbet Austin
Storm Products Incorporated
165 South 800 West
Brigham City, UT 84302
[e-mail]

Dear Mr. Austin:

Re: Intent to Approve: Modification to Approval Order DAQE-AN127390006-16 to Add Laser
Etching and a Baghouse
Project Number: N127390007

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. 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 upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Mr. Tim DeJulis, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Mr. Tim DeJulis, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:TD: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 [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

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN127390007-24
Modification to Approval Order DAQE-AN127390006-16
to Add Laser Etching and a Baghouse

Prepared By
Mr. Tim DeJulis, Engineer
[phone]
[e-mail]

Issued to
Storm Products Incorporated - Bowling Ball Manufacturing

Issued On
April 25, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN127390007-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Storm Products Incorporated Storm Products Incorporated - Bowling Ball
Manufacturing

Mailing Address Physical Address
165 South 800 West 165 South 800 West
Brigham City, UT 84302 Brigham City, UT 84302

Source Contact UTM Coordinates
Name: Corbet Austin 414,215 m Easting
Phone: [phone],595,544 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3949 (Sporting & Athletic Goods, NEC)

SOURCE INFORMATION
General Description
Storm Products Incorporated, located in Brigham City, Box Elder County, creates bowling balls for
shipment to national and international customers. Bowling ball manufacturing involves six (6) stages:
casting the core, casting the ball around the core, cutting the ball to the proper dimensions, drilling finger
holes, polishing, and etching. Finished bowling balls are packaged and stored for shipping. Particulates
from cutting, cleaning, sizing, finishing, and etching are sent to an outdoor baghouse, then vented back
into the building or exhausted outside for heat control. A closed room houses three (3) styrene and two
(2) isocyanate tanks. Polyol is stored in large containers.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: B

Applicable Federal Standards
None

DAQE-IN127390007-24
Page 4

Project Description
Storm Products Incorporated has requested a modification to Approval Order DAQE-AN127390006-16,
dated April 21, 2016, to replace an internally vented fabric filter with an external venting baghouse. The
plant will use the baghouse to control emissions from ball finishing, and laser etching, which place
various designs on each bowling ball. The laser etching will emit 0.02 tons/yr of PM10 and 0.01 tons/yr of
PM2.5 after control during the manufacture of 960,000 bowling balls per year. The number of bowling
balls manufactured will stay at the same level as in the previous AO. The baghouse has a control
efficiency of 99.9%.

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)
Particulate Matter - PM10 0.02
Particulate Matter - PM2.5 0.01
Volatile Organic Compounds 0 28.31

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Styrene (CAS #100425) 0 5540
Xylenes (Isomers And Mixture) (CAS #1330207) 0 19520
Change (TPY) Total (TPY)
Total HAPs 0 12.53

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Box Elder News & Journal on May 1, 2024. During the public
comment period the proposal and the evaluation of its impact on air quality will be available for the
public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

DAQE-IN127390007-24
Page 5

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.

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

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.

II.A THE APPROVED EQUIPMENT

II.A.1 Brigham City Bowling Products Manufacturing Plant

DAQE-IN127390007-24
Page 6

II.A.2 Baghouse
One (1) baghouse
Flowrate: 27,000 scfm
Controls emissions from the laser etcher and ball finishing.

II.A.3 Batching Systems
Two (2) two-vessel closed batching systems

II.A.4 Batching System
One (1) three-vessel closed batching system

II.A.5 Casting Machine
One (1) Peyton-Technology casting machine

II.A.6 Ball Polisher
One (1) filtered bowling ball polisher

This equipment is listed for informational purposes only.

II.A.7 Parts Washers
Various Parts Washers

II.A.8 Vent Stack
One (1) Vent Stack
43 feet from ground level
7,500 scfm blower

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.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 VOC and HAPs Emission Limitations
II.B.1.a The owner/operator shall comply with all applicable requirements of R307-304, Solvent
Cleaning, and R307-335, Degreasing for all applicable emission units on site.
[R307-304, R307-335]

II.B.1.b The owner/operator shall not emit more than the following from the bowling ball formers,
contact cement applicators, batching and casting systems, and associated operations:

28.31 tons of VOC per rolling 12-month period.

9.76 tons of xylene per rolling 12-month period.

2.77 tons of styrene per rolling 12-month period.

[R307-401-8]

II.B.1.b.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 determine and log the monthly
consumption of the materials containing VOCs and HAPs. [R307-401-8]

DAQE-IN127390007-24
Page 7

II.B.1.b.2 The owner/operator shall keep records of consumption for all periods when the plant is in
operation. These records of consumption shall include the following:

A. Name of the VOC or HAP- emitting material.

B. Density of each material used (pounds per gallon).

C. Percent by weight of all VOCs and HAPs in each material used.

D. Gallons of each VOC or HAP- emitting material used.

E. The amount of VOC or HAPs emitted monthly by each material.

[R307-401-8]

II.B.1.b.3 The owner/operator shall calculate the amount of VOC or HAPs emitted with the following
procedure:

VOC = monthly material throughput (in 1,000 of pounds) x VOC factor in (in pounds/1,000
pounds of material)

HAPs = % styrene or xylene by weight/100 x density (lb/gal) x gallons used x 1 ton/2000 lb x
emission factor.

The owner/operator has used 83% in its xylene calculations and 0.3% in its styrene calculations.

[R307-401-8]

II.B.1.c The owner/operator shall not operate for more than 16 hours per day and five (5) days per week.
[R307-401-8]

II.B.1.c.1 The owner/operator shall determine the hours of operation by supervisor monitoring and
maintaining of an operations log. [R307-401-8]

II.B.2 Baghouse Requirements
II.B.2.a The owner/operator shall use a baghouse to control particulate emissions from the laser etcher
and ball finishing of each produced bowling ball. [R307-401-8]

II.B.2.b The owner/operator shall not allow visible emissions from the baghouse to exceed 10% opacity.
[R307-401-8]

II.B.2.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across the baghouse. [R307-401-8]

II.B.2.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.2.c.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

II.B.2.d During operation of the baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between two (2) and seven (7) inches of water column.
[R307-401-8]

DAQE-IN127390007-24
Page 8

II.B.2.d.1 The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

II.B.2.d.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Daily static pressure differential readings;

C. Date of reading.

[R307-401-8]

II.B.2.e At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

II.B.2.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN127390006-16 dated April 21, 2016
Is Derived From NOI dated October 30, 2023
Incorporates Additional information dated March 18, 2024

DAQE-IN127390007-24
Page 9

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-NN127390007-24

April 25, 2024

Box Elder News & Journal
Legal Advertising Dept
PO BOX 370
Brigham City, UT 84302-0370

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Box Elder News &
Journal (Account Number: LOC0403) on May 1, 2024.

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. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Bear River Association of Governments
cc: Box Elder County

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

DAQE-NN127390007-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Storm Products Incorporated
Location: Storm Products Incorporated - Bowling Ball Manufacturing – 165 South 800
West, Brigham City, UT
Project Description: Storm Products Incorporated has requested a modification to Approval Order
DAQE-AN127390006-16, dated April 21, 2016, to replace an internally vented
fabric filter with an external venting baghouse. The plant will use the baghouse
to control emissions from ball finishing, and laser etching, which place various
designs on each bowling ball. The laser etching will emit 0.02 tons/yr of PM10
and 0.01 tons/yr of PM2.5 after control during the manufacture of 960,000
bowling balls per year. The number of bowling balls manufactured will stay at
the same level as in the previous AO. The baghouse has a control efficiency of
99.9%.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before May 31, 2024 will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this
notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: May 1, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN127390007
March 25, 2024

Corbet Austin
Storm Products Incorporated
165 S 800 W
Brigham City, UT 843020
[e-mail]

Dear Corbet Austin,

Re: Engineer Review:
Modification to AO DAQE-AN127390006-16 to Add Laser Etching and a Baghouse
Project Number: N127390007

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 permitting program. Storm Products
Incorporated should complete this review within 10 business days of receipt.

Storm Products Incorporated should contact Mr. Tim DeJulis at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Mr. Tim DeJulis at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment
period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by
the DAQ Director.

If Storm Products Incorporated does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Storm Products Incorporated 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 [phone] • Fax [phone] • T.D.D. [phone]
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

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N127390007
Owner Name Storm Products Incorporated
Mailing Address 165 S 800 W
Brigham City, UT, 843020

Source Name Storm Products Incorporated- Bowling Ball Manufacturing
Source Location 165 S 800 W
Brigham City, UT 84302

UTM Projection 414,215 m Easting, 4,595,544 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3949 (Sporting & Athletic Goods, NEC)

Source Contact Corbet Austin
Phone Number [phone]
Email [e-mail]

Billing Contact Corbet Austin
Phone Number [phone]
Email [e-mail]

Project Engineer Mr. Tim DeJulis, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted October 31, 2023
Date of Accepted Application November 16, 2023

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 2
SOURCE DESCRIPTION

General Description
Storm Products, located in Brigham City, Box Elder County, creates bowling balls for shipment
to national and international customers. Bowling ball manufacturing involves six stages: casting
the core, casting the ball around the core, cutting the ball to the proper dimensions, drilling finger
holes, polishing, and etching. Finished bowling balls are packaged and stored for shipping.
Particulates from cutting, cleaning, sizing, finishing, etching, and the shop is sent to outdoor
fabric filter house then vented back into building or exhausted outside for heat control. A closed
room house three styrene and two isocyanate tanks. Polyol is stored in large containers.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: B

Applicable Federal Standards
None

Project Proposal
Modification to AO DAQE-AN127390006-16 to Add Laser Etching and a Baghouse

Project Description
Storm Products has requested a modification to DAQE-AN127390006-16, dated April 21, 2016,
to replace an internally-vented fabric filter with an external venting baghouse. The plant will use
the baghouse to control emissions from laser etching, which places various designs on each
bowling ball. The laser etching will emit 0.02 tons/yr of PM10 and 0.01 tons/yr of PM2.5 after
control during the manufacture of 960,000 bowling balls per year. The number of bowling balls
manufactured will stay at the same level as in the previous AO. The baghouse has a control
efficiency of 99.9%.

EMISSION IMPACT ANALYSIS
All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are
below their respective emission threshold values in R307-410-5. Therefore, a modeling analysis is not required
at this time. [Last updated February 29, 2024]

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
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)
Particulate Matter - PM10 0.02
Particulate Matter - PM2.5 0.01
Volatile Organic Compounds 0 28.31

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Styrene (CAS #100425) 0 5540
Xylenes (Isomers And Mixture) (CAS #1330207) 0 19520
Change (TPY) Total (TPY)
Total HAPs 0 12.53

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Laser Etcher
Storm Products evaluated control options for the new laser etcher. A baghouse with a control
efficiency of 99.9% was determined to be economically feasible. This is selected as BACT.
[Last updated March 21, 2024]

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 N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 5
I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

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 Brigham City Bowling Products Manufacturing Plant

II.A.2
NEW
Baghouse
One (1) baghouse
Flowrate: 27,000 scfm
Controls emissions from the laser etcher

II.A.3 Batching Systems
Two (2) two-vessel closed batching systems

II.A.4 Batching System
One (1) three-vessel closed batching system

II.A.5 Casting Machine
One (1) Peyton-Technology casting machine

II.A.6 Ball Polisher
One (1) filtered bowling ball polisher

This equipment is listed for informational purposes only.

II.A.7
NEW
Parts Washers
Various Parts Washers

II.A.8 Vent Stack
One (1) Vent Stack
43 feet from ground level
7,500 scfm blower

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 6
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 VOC and HAPs Emission Limitations
II.B.1.a
NEW
The owner/operator shall comply with all applicable requirements of R307-304, Solvent
Cleaning, and R307-335, Degreasing for all applicable emission units on site. [R307-304,
R307-335]

II.B.1.b
NEW
The owner/operator shall not emit more than the following from the bowling ball formers;
contact cement applicators; batching and casting systems; and associated operations:

28.31 tons of VOC per rolling 12-month period
9.76 tons of xylene per rolling 12-month period
2.77 tons of styrene per rolling 12-month period.

[R307-401-8]

II.B.1.b.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 determine and log the monthly
consumption of the materials containing VOCs and HAPs. [R307-401-8]

II.B.1.b.2
NEW
The owner/operator shall keep records of consumption for all periods when the plant is in
operation. These records of consumption shall include the following:

A. Name of the VOC or HAP emitting material

B. Density of each material used (pounds per gallon)

C. Percent by weight of all VOCs and HAPs in each material used

D. Gallons of each VOC or HAP emitting material used

E. The amount of VOC or HAPs emitted monthly by each material.

[R307-401-8]

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 7
II.B.1.b.3
NEW
The owner/operator shall calculate the amount of VOC or HAPs emitted with the following
procedure:

VOC = monthly material throughput (in 1,000 of pounds) x VOC factor in (in pounds/1,000
pounds of material)

HAPs = % styrene or xylene by weight/100 x density (lb/gal) x gallons used x 1 ton/2000 lb x
emission factor.

The owner/operator has used 83% in its xylene calculations and 0.3% in its styrene
calculations.

[R307-401-8]

II.B.1.c
NEW
The owner/operator shall not operate for more than 16 hours per day and five days per week.
[R307-401-8]

II.B.1.c.1
NEW
The owner/operator shall determine the hours of operation by supervisor monitoring and
maintaining of an operations log. [R307-401-8]

II.B.2
NEW
Baghouse Requirements
II.B.2.a
NEW
The owner/operator shall use a baghouse to control particulate emissions from the laser etcher
of each produced bowling ball. [R307-401-8]

II.B.2.b
NEW
The owner/operator shall not allow visible emissions from the baghouse to exceed 10%
opacity. [R307-401-8]

II.B.2.b.1
NEW
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2.c
NEW
The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
static pressure differential across the baghouse. [R307-401-8]

II.B.2.c.1
NEW
The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. [R307-401-8]

II.B.2.c.2
NEW
The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

II.B.2.d
NEW
During operation of the baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between 2 and 7 inches of water column. [R307-401-8]

II.B.2.d.1
NEW
The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 8
II.B.2.d.2
NEW
The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Daily static pressure differential readings;

C. Date of reading.

[R307-401-8]

II.B.2.e
NEW
At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

II.B.2.e.1
NEW
The owner/operator shall maintain records of the pressure gauge calibrations and
replacements. [R307-401-8]

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 9
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN127390006-16 dated April 21, 2016
Is Derived From NOI dated October 30, 2023
Incorporates Additional information dated March 18, 2024

REVIEWER COMMENTS

1. Comment regarding Emission Estimates:
The source has estimated the PM10/PM2.5 emissions by conducting a study of what the weight of the
material being directed to the baghouse and then removing the material collected at the bottom of the
baghouse. The remaining material is the amount of PM10/PM2.5 emitted to the atmosphere.
The source has done a complete mass balance approach to estimating their VOC emissions. They use
the composition of each species, multiplied by the volume, and getting the quantity in pounds of
pollutant in each case. [Last updated February 29, 2024]

2. Comment regarding NSPS & MACT Applicability:
This source is not subject to any NSPS, NESHAP, or MACT standards. [Last updated February 29,
2024]

3. Comment regarding Title V Applicability:
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 Sources;
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 facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR
60 NSPS Subparts, 40 CFR 61 NESHAP Subparts, or 40 CFR 63 MACT Subparts. There are no
other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does
not apply to this facility. [Last updated February 29, 2024]

4. Comment regarding MDI Status in This Permit:
In a previous permit, MDI was studied because of the way the source estimated the consumption of
MDI use. Previously the source used the AP-42 emission factor for marble casting at the mid-range
of 2%.

For a previous engineering review, the source did physical testing to confirm that MDI was not
emitted. The testing showed an emissions factor of 0.0000124%. This equates to an emission rate of
0.00007 tons per year.
[Last updated February 29, 2024]

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 10
5. Comment regarding Baghouse:
In the previous permit the fabric filter in section II.A was listed "for informational purposes only."
These emissions were directed back into the building. Now, the source has replaced this fabric filter
with an externally-venting baghouse, with the associated PM10/PM2.5 emissions reflected in the
permit. "For informational purposes only," has been removed from the baghouse. [Last updated
March 7, 2024]

Engineer Review N127390007: Storm Products Incorporated- Bowling Ball Manufacturing
March 25, 2024
Page 11
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

June 14, 2019
Page 1 of 3

Sent via Certified Mail No. ___________________________________________

Timothy DeJulis
Utah Division of Air Quality
Utah Department of Environment
P.O. Box 144820
Salt Lake City, Utah 84114-4820

Storm Products, Inc.
Approval Order (AO) #DAQE-AN0127390004-07
Request for Guidance regarding a Proposed CO₂ Laser Engraving Process Change

Mr. DeJulis:

I am writing you directly, because you were the permit engineer assigned to our permit in 2015,
and should be familiar with our operation. This letter describes a proposed new laser engraving
operation at the Storm Products, Inc. (Storm) bowling ball manufacturing facility located at 165
South 800 West Street, Brigham City in Box Elder County, Utah.

The current engraving operation at the facility utilizes a high-speed router bit that mechanically
removes a small amount of the polyurethane cover material to create a model number and unique
serial number for each ball. Based on the maximum engraving dimensions, the router bit
removes a maximum of about 0.125 cubic inches of polyurethane plastic from each ball cover:
0.035 inches wide × 0.02 inches deep × 178.2 inches long = 0.12474 in³ per ball
At the currently permitted maximum production capacity of 960,000 balls per year, the total
annual amount of removed routed engraving material is: 960,000 ball/yr × 0.125 in³/ball × 87.78 lb/ft³ / 1728 in³/ft³ = 6,095 lb per year.
The routed material is relatively coarse. Practically all of this material is swept up and collected
as floor debris around the engraving stations and disposed as non-hazardous solid waste. Note
that the engraving operations was judged to be a negligible source of PM emissions during the
facility construction permitting effort several years ago.

Storm proposes to replace the current mechanical router engraving equipment with new high-
energy carbon dioxide (CO2) laser engraving equipment. The CO2 laser will use energy to
remove the polyurethane material instead of mechanically removing it with a router bit. The
laser beam itself has no temperature, but the focused energy from the CO2 laser will be
extremely intense at the engraver focal point, which is typically small and may be less than a
fraction of a millimeter. Only the ball material inside this focal point area is significantly
affected when the beam passes over the ball surface. The energy delivered by the laser will
simultaneously vaporize a portion of the surface material and will fracture and flake off the rest
of the material. As the laser focal point moves across the ball surface, the removed material
forms the engraving.

June 14, 2019
Page 2 of 3

Storm investigated potential air pollutants that might be generated by the CO2 laser engraving
process as part of our R&D effort. We solicited information from our laser vendor and our air
permitting consultant. Neither our laser vendor nor our consultant had any special knowledge
about emissions from this process. We could not find any specific air pollutant emission factors
for the laser engraving process on the polyurethane resin material used to make our ball cover.
We did find some online references that mention various combustion byproducts from the laser
cutting of solid plastics, especially plastics that contain carbon-nitrogen (CN) bonds. The
polyurethane used by Storm is formed by reacting a polyol base with a isocyanate monomer in
the presence of suitable catalysts and additives. The isocyanate component contains molecular
CN bonds. The references indicate that carbon monoxide, hydrogen cyanide, and fine particulate
may be an environmental concern when laser cutting or burning materials such as polyurethane.

Combustion Byproducts

• Carbon Monoxide

Carbon monoxide (CO) gas could be formed during the incomplete combustion of
carboniferous fuels. Storm does not believe that a significant amount of CO can be formed
during the rapid, high temperature laser engraving process. Any combustion of the ball cover
material would be very rapid and complete. Only carbon dioxide should be formed.

• Hydrogen Cyanide

Hydrogen cyanide gas might be also be formed during the thermal decomposition of some
types of plastics, including polyurethane:

The thermal decomposition of non-fire retarded polyurethane foams in air is generally quite well
understood. Generally, the initial decomposition of the foam (>300 °C) results in the
volatilization of isocyanates, amines and “yellow smoke”, leaving behind polyols in the
condensed phase. These polyols are fragments and volatilize as the temperature increases (>600
°C), leaving behind a char. This char can decompose further, leaving behind a residue, to
produce simple organic fragments and some polycyclic aromatic hydrocarbons (PAHs). In the
gas phase, isocyanates, amines and “yellow smoke” are begun to decompose at >600 °C into low
molecular weight nitrogen-containing fragments (such as benzonitrile, aniline and hydrogen
cyanide (HCN)). At >800 °C these compounds further fragment into simple molecules (such as
HCN, CO, CH4 and CH2O) and PAHs

https://link.springer.com/article/10.1007/s10973-017-6294-4

June 14, 2019
Page 3 of 3

In the absence of any available data specific to hydrogen cyanide gas formation during the
laser engraving process and in an abundance of caution due to the toxicity concern, Storm
directly sampled the smoke plume from the R&D laser engraving process using a SENSIT
HCN instrument to directly measure the hydrogen cyanide gas concentration in the hot
smoke. The SENSIT instrument is an advanced state-of-the-art gas analyzer designed to
provide part-per-million level measurements of hydrogen cyanide concentrations across the
range of 0 to 100 ppm in ambient air or hot smoldering smoke plumes. The SENSIT
instrument has a hot air probe, a powerful rotary vane sample pump, a probe filter, and an
advanced long life electrochemical sensor that can be field calibrated. The smoke plume in
the R&D laser engraving cell was sampled with this instrument and hydrogen cyanide gas
was not detected at a detection level below 1 ppm (one instrument count). Based on this
data, Storm believes that hydrogen cyanide emissions from the proposed laser engraving will
be insignificant.

In retrospect, the reported hydrogen cyanide emissions from the burning of polyurethane
foams in the online reference occurred during protracted thermal decomposition of a surface
char. This does not occur during laser engraving. The laser process is too quick and hot to
form a char. If any hydrogen cyanide is formed, then it is probably completely oxidized.

• Fine particulate

The smoke plume containing the fine particulate from the laser engraving will be captured
inside a ventilated enclosure and filtered with a high-efficiency particulate air (HEPA) filter
to remove the fine fume particulate. The filtered enclosure air will be returned to the
building space next to the engraving stations. The HEPA filter system will remove
practically all of the fine particulate.

Storm would appreciate your guidance on any possible permitting requirements for the new laser
engraving equipment. Does the proposed change in the engraving process equipment to convert
from mechanical routing to laser engraving require a modification to the facility air permit? If
so, then what application forms and supporting documentation are required? Could the new laser
engraving process be considered an insignificant “off-permit” change that could be incorporated
into the facility air permit during a future significant modification? Please let me know the
proper course of action at your convenience.

If you need any more information or any further clarification, please contact me directly at (435)
723-0403 ext. 1140. Thank you for your assistance.

Respectfully,

Ron Hales
Director of Engineering
8/7/23, 1:21 PM State of Utah Mail - RE: Storm Products NOI Modification - LMG update
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-f:1765988984033793857&simpl=msg-f:1765988984033793857 1/6
Tim Dejulis <[e-mail]>
RE: Storm Products NOI Modification - LMG update
1 message
Lance Traves <[e-mail]>Mon, May 15, 2023 at 1:18 PM
To: Tim Dejulis <[e-mail]>
Cc: Corbet Austin <[e-mail]>, Bart Oyler <[e-mail]>, [e-mail]
Hello Tim. We are working to finish up the NOI and modificaon request for the dust collector. As you might expect,
doing a BACT study to vent an emission source outside that already has a high-efficiency baghouse has some
complicaons. Obviously, I would hope that your Agency could agree that there is no expectaon that it is cost-
effecve to put in a replacement baghouse just to control an addional couple of % of PM10/PM2.5.

We also had to work up some construcon esmates for the use of total enclosures for the emission sources of the
requested increase for the VOC (and minor HAP) emissions. The cost for use of an RTO or TO with total enclosures for
control of less than 10 tons addional VOCs is astronomical but we are working this up.

The delays have been the result of LMG and not Storm Products. We will get this completed.

We understand that based on the emission tracking and the updated SDS/environmental data sheets that LMG
incorporated in new emission tracking calculaons for the materials used by Storm Products - the facility VOC and
HAP emissions are and have been safely below exisng permied emission limits.

Please feel free to contact us again if you have further quesons. Lance.

Lance S. Traves, CHMM
President
Labyrinth Management Group, Inc.
239 South Court Street
Medina, Ohio 44256
Office: 330-764-4825
Cell: 330-603-9234
Fax: [phone]
[e-mail]
P Practice sustainability; do not print this e-mail unless necessary.
8/7/23, 1:21 PM State of Utah Mail - RE: Storm Products NOI Modification - LMG update
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-f:1765988984033793857&simpl=msg-f:1765988984033793857 2/6
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Confidentiality & Disclosure Notice: This e-mail and its contents or attachments are confidential information and intended solely for the addressee(s)
identified in this message. Any unauthorized review, use, disclosure or distribution is prohibited. If you have received this message and are not the intended
recipient please immediately alert the sender by reply e-mail and then delete this message and its attachments, if any are present.

From: Tim Dejulis [mailto:[e-mail]]
Sent: Monday, May 15, 2023 3:01 PM
To: Lance Traves <[e-mail]>
Cc: Corbet Ausn <[e-mail]>; Bart Oyler <[e-mail]>;
[e-mail]
Subject: Re: Storm Products NOI Modificaon - NOI Process Form Queson

Bart,

We're waiting on an answer from Storm Products on their latest NOI? Could we get an update from Storm Products on
the impending NOI?

Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

On Fri, Apr 28, 2023 at 4:17 PM Tim Dejulis <[e-mail]> wrote:
Bart,

We've had a compliance inspection on Storm Products recently. It looks like Storm can use this baghouse to externally
vent emissions by simply opening a valve and the compliance inspector was told that this valve will be closed, so that
the baghouse vents internally. It's been three months, since February 2, for Storm Products to get the NOI finalized and
we're wondering where the NOI is, in light of the recent compliance inspection? Could we have an idea when Storm
Products will be delivering the NOI to the DAQ for the emissions from the brand new baghouse and the other changes
needed? Please let me know if you have any questions or concerns. Thank you.

8/7/23, 1:21 PM State of Utah Mail - RE: Storm Products NOI Modification - LMG update
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-f:1765988984033793857&simpl=msg-f:1765988984033793857 3/6
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

On Thu, Feb 2, 2023 at 5:47 PM Tim Dejulis <[e-mail]> wrote:
Lance,

I was going to see where Storm Products was with their application today, but you beat me to it.

When the permitting agency is determining whether a source is new or modified, we look to the existing AO. If we
don't see the baghouse listed in the current AO, then it is new as far as the permitting agency is concerned. Storm
already has the baghouse listed for information purposes only, so this would be classified as modified. Either option
is fine by me though because we'll look at the calculations that should be a part of the notice-of-intent.

The cost per ton of pollution removed is the deciding factor in Storm's BACT analysis, regardless of the emission
rate alone. Multiply this emission rate by the production rate and divide the cost of installing the pollution control by
this number. This value would be the determining factor in Storm's BACT analysis the DAQ would base our
decision on.

Yes, Storm Products will have to go through all the options (cyclone, wet scrubber, etc.) to control the emissions
from the bowling ball production in the BACT analysis. Storm is putting in an externally venting baghouse and we
must have all the options considered in the record, so the DAQ can justify to the public that we considered each
control option. I would presume that PM10/PM2.5 would not be a problem with such a high rate of control within the
baghouse though.

When Labryrinth and Storm are ready to present the NOI, I recommend having another pre-NOI so we can review
the application. Please let me know when I should schedule time to meet with everybody.

Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
8/7/23, 1:21 PM State of Utah Mail - RE: Storm Products NOI Modification - LMG update
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-f:1765988984033793857&simpl=msg-f:1765988984033793857 4/6
airquality.utah.gov

On Thu, Feb 2, 2023 at 1:46 PM Lance Traves <[e-mail]> wrote:
Tim – On behalf of Storm Products, we are trying to wrap up this month the NOI mod applicaon.

So, I wanted to confirm that the NOI applicaon does not require the submission of NOI Form 3 as the facility
is already permied and the processes are just being modified. Instead, only Form 4 will be used for the NOI
applicaon. Is this correct??

The reason I ask is that as previously discussed, as part of the mod the ball finishing operaons that vent to
the baghouse will be exhausted into the ambient air verses back into the building. So, this operaon I expect
will be a new separate Emission Unit included in the updated modified air permit.

Also, I assume only 1 Process For 4 is submied and we supplement info with an applicaon text document.
Further, on NOI Process Form 4, the Box #3 has boxes to check for “New” or “Increase” associated with
“Equipment ” and “Process”. I was thinking Storm should check the Equipment “New ” box as the ball finishing
operaon is new equipment to be added including the baghouse as an Emission Unit (although already noted
in permit) and then also check the Process “Increase” box as the raw material amounts are being increased.
Does this sound correct??

Thanks in advance for your guidance. Lance.

Lance S. Traves, CHMM
President
Labyrinth Management Group, Inc.
239 South Court Street
Medina, Ohio 44256
Office: 330-764-4825
Cell: 330-603-9234
Fax: [phone]
[e-mail]
P Practice sustainability; do not print this e-mail unless necessary.
8/7/23, 1:21 PM State of Utah Mail - RE: Storm Products NOI Modification - LMG update
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-f:1765988984033793857&simpl=msg-f:1765988984033793857 5/6
--------------------------------------------------------------------------------------------------------------------------
Confidentiality & Disclosure Notice: This e-mail and its contents or attachments are confidential information and intended solely for the
addressee(s) identified in this message. Any unauthorized review, use, disclosure or distribution is prohibited. If you have received this message
and are not the intended recipient please immediately alert the sender by reply e-mail and then delete this message and its attachments, if any are
present.

From: Tim Dejulis [mailto:[e-mail]]
Sent: Monday, December 12, 2022 7:44 PM
To: Lance Traves <[e-mail]>
Cc: Corbet Ausn <[e-mail]>; Bart Oyler <[e-mail]>;
[e-mail]; [e-mail]
Subject: Re: Storm Products NOI Modificaon - BACT Queson for ball finishing that is already controlled

Lance,

Any PM10/PM2.5 being emitted externally to the atmosphere must have a BACT analysis included in the notice of
intent (NOI), regardless of the scale of the PM10/PM2.5 emissions. If Storm Products is using an emission
controlling unit that currently emits these emissions internally, the DAQ didn't include any of these
collected emissions in any of the previous BACT analysis', in any previous NOIs. Therefore, if these PM10/PM2.5
emissions will be emitted externally, we need a BACT analysis to cover this. Let me know if you have any further
questions. Thank you.

Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

On Thu, Dec 8, 2022 at 2:33 PM Lance Traves <[e-mail]> wrote:
Tim, On behalf of Storm Products (Storm), LMG had a specific question on the NOI modification application
LMG is preparing with respect to the ball finishing operation’s (that includes laser engraving) emission unit that
will now be permitted as exhausting to the ambient air after control by the existing high efficiency HEPA
baghouse.

As previously submitted by Storm, we believe the high efficiency baghouse PM/PM10/PM2.5 control is 98-99%
and with HEPA filters we expect it to have a grain loading that meets at least 0.008 grains/acfm. We believe
this grain loading and the high-efficiency baghouse already meets typical BACT.

8/7/23, 1:21 PM State of Utah Mail - RE: Storm Products NOI Modification - LMG update
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-f:1765988984033793857&simpl=msg-f:1765988984033793857 6/6
Furthermore, IF Strom were to replace the existing High Efficiency baghouse with another APC system with a
slightly higher control efficiency - such as a wet scrubber - the additional incremental pollutant removal by the
new very expensive APC equipment would be very small. Therefore, it would clearly never be cost-effective to
remove and replace the existing high-efficiency baghouse with another APC system of any kind.

So, LMG wants to confirm with Utah DEQ that Storm does not have to go through a BACT review paper
exercise for this ball finishing operation Emission Unit as part of the NOI modification application materials.
Please note that in the NOI application we will fully describe the existing High Efficiency baghouse and the
reasons that it already meets BACT.

If you have any immediate question, please feel free to call me. Thank you in advance for your assistance.

Respectfully,

Lance S. Traves, CHMM
President
Labyrinth Management Group, Inc.
239 South Court Street
Medina, Ohio 44256
Office: 330-764-4825
Cell: 330-603-9234
Fax: [phone]
[e-mail]
P Practice sustainability; do not print this e-mail unless necessary.
--------------------------------------------------------------------------------------------------------------------------
Confidentiality & Disclosure Notice: This e-mail and its contents or attachments are confidential information and intended solely for the
addressee(s) identified in this message. Any unauthorized review, use, disclosure or distribution is prohibited. If you have received this
message and are not the intended recipient please immediately alert the sender by reply e-mail and then delete this message and its
attachments, if any are present.

Storm Products Incorporated
165 S 800 W, Brigham City, UT 84302
October 27, 2023
VIA USPS
Utah DAQ
Division of Air Quality - Permitting
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Subject: Notice of Intent – Request to Modify Approval Order
Storm Products – Brigham City
Dear Mr. Humpherys:
Enclosed is a signed Company Information/NOI form along with the associated fee payment
for the Storm Products Incorporated facility. All other files related to this NOI have been
emailed to [e-mail].
Thank you for your help with this application. Should there be any questions, feel free to
contact me or any of the people listed below.
Ron Fleming Permit Contractor [phone] [e-mail]
Corbet Austin VP of Operations [phone] [e-mail]
Bart Oyler Safety Officer [phone] [e-mail]
Sincerely,
Corbet Austin
Vice President of Operations
Storm Products

Storm Products Incorporated

NOTICE OF INTENT
Request for AO Modification

OCTOBER 2023

Submitted by:
Storm Products Incorporated
165 S 800 W
Brigham City, UT 84302

Submitted to:
Utah Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820

Page 1
TABLE OF CONTENTS

Page
Background and Process Description ..................................................... 1
Emissions Calculations ........................................................................... 1
NSPS and NESHAP ............................................................................... 2
Process Flow Chart ................................................................................. Appendix A
Area Map ................................................................................................ Appendix B
Site Plan ................................................................................................. Appendix C
Facility Layout ......................................................................................... Appendix D
Dust Collector Photo ............................................................................... Appendix E
Dust Collector Filter Specifications ......................................................... Appendix E1
Dust Collector Emission Calculations ..................................................... Appendix F
BACT Determination – Dust Collector ..................................................... Appendix G
UDAQ Form 2 - Company Information .................................................... Attachment
UDAQ Form 5 – Emissions Information .................................................. Attachment
UDAQ Form 10 – Fabric Filter ................................................................ Attachment

BACKGROUND and PROCESS DESCRIPTION
Storm Products Incorporated operates a facility where polyester resin and urethane are used to
form bowling balls. Two of the manufacturing processes (ball finishing and laser etching)
generate particulate matter. This particulate matter is collected by a large fabric filter (dust
collector). The exhaust from this fabric filter was originally designed to be returned to the
building. This NOI is submitted to request that the current Approval Order be modified to
indicate that the fabric filter discharges outdoors. See the included appendices for details
related to the process, the facility and the fabric filter.

EMISSIONS CALCULATIONS
PM2.5 and PM10 Emissions – The ball finishing and laser etching operations both generate
PM2.5 and PM10 dust. This dust is exhausted to the large fabric filter (dust collector). Although
most of the dust is from the ball grinding operation and most of this dust consists of particles
much greater than 10 micron, the grinding and laser etching operations both emit PM2.5 and
PM10. The emission factors used to calculate emissions are in-house emission factors based

Page 2
on visual observation and conservative best engineering estimates. See Appendix F for full
details.

EMISSIONS CONTROLS
This NOI is submitted to modify the status of dust collector previously listed as “information only”
to a control device that discharges outdoors.

BACT ANALYSIS
One BACT Determination was completed and is included with this NOI. See Appendix G.

NSPS - New Source Performance Standards
The New Source Performance Standards (40 CFR 60) (NSPS) in effect at the time of this NOI
were reviewed and each was compared to the operations of this facility. No standards were
identified that applied to the facility.

NESHAP - National Emission Standards for Hazardous Air Pollutants
The NESHAP rules in effect at the time of this NOI (40 CFR 61 and 63) were reviewed and
compared to the operations of this facility. One standard was found to cover similar processes
but was ultimately determined not to apply to the facility. NESHAP “WWWW” covers Reinforced
Plastic Composites Production at sources that are major sources for HAPs. This facility is not a
major source for HAPs. For this reason, this NESHAP is not applicable.

SAFETY DATA SHEETS SUBMITTED
Because this Notice of Intent does not cover any new processes or chemicals, no Safety Data
Sheets were submitted as part of this Notice of Intent.

Appendix A – Process Flow
Storm Products, Inc.
Appendix B – Area Map
Area Map
Storm Products, Inc.
165 S 800 W
Brigham City, UT 84302
Date Drawn: October 26, 2023
Drawn By: Ron Fleming
Storm Products
Appendix C – Site Map
Site Map
Storm Products, Inc.
165 S 800 W
Brigham City, UT 84302
Date Drawn: October 26, 2023
Drawn by: Ron Fleming
S
8
0
0

W

W 200 S
Dust Collector
Discharge Point
Storage
Building
Main
Building
Offices
Property
Line
Appendix D – Facility Layout
Facility Layout
Storm Products
165 S 800 W
Brigham City, UT 84302
Date Drawn: October 18, 2023
Drawn By: Ron Fleming
Appendix E – Dust Collector

Dust Collector
Storm Products, Inc.
165 S 800 W
Brigham City, UT 84302

Date Drawn: October 18, 2023
Drawn By: Ron Fleming

Schenck Process LLC
7901 NW 107th Terrace
Kansas City, MO 64153
Tel: [phone]
Fax: [phone]
www.schenckprocess.com\us
FILTER EMISSIONS STATEMENT
for
DYNA-MAC 16 oz. Dacron Polyester Bags
Customer: Storm Bowling Bowls
Reference: 2017-46841-P5K-JH Rev 0 1100342593
Equipment: 144MCF361 Style III Filter
Application: 5202 Sq. ft. of media with an air to media ratio of 5.2:1 @ 27000 CFM
Schenck Process LLC warrants its filters to be free of mechanical defects for a period of one year from
the date of shipment in accordance with the “Warranty and Limitation” statement included with the
original proposal.
Schenck Process LLC also warrants the emissions of its new Dyna-MAC 16 oz. Dacron Polyester bags,
when properly installed, applied and maintained, and when operated per the design parameters
referenced in the original proposal and in accordance with the manufacturer’s operations manuals, to
emit no more than 0.001 grains/dscf of air based on PM 2.5 efficiency testing. Based on an inlet loading
of 10 grains/dscf they will provide at least 99.99% capture efficiency.
The Buyer will be responsible for any emissions testing expense and Schenck Process LLC reserves
the right to be present during any emission tests and shall be notified at least 2 weeks prior to the testing.
Emissions testing must be conducted within 30 days of start-up, or 60 days from equipment shipment.
Misuse, abuse, operating outside the stated parameters, and / or water, oil, or hydrocarbons will void
the emissions expectation. Schenck Process LLC shall not be held responsible for any failures or
excess emissions due to upset operating conditions.
Under no circumstances will Schenck Process LLC be liable or responsible for incidental or
consequential damages.
Drew Gormley
Application Engineer, Filtration
August 2, 2022
Cc:
Appendix F
PM Emissions from Ball Finishing and Laser Etch
Storm Products, Inc.
Pounds Tons
Per Day Per Hour Per Year Per Year
Total debris (particles) collected by dust collector and disposed (lbs)5,000 312.5 1,250,000 625.0
Fraction of total debris that is PM10 (including PM2.5)0.02 0.02 0.02 0.02
Dust (PM10)(includes PM2.5) collected and disposed (lbs)100.00 6.25 25,000 12.5
Dust (PM10)(includes PM2.5) escaping 99.9% efficent dust collector filters (lbs)0.10 0.00626 25.0 0.01251
Dust (PM2.5) escaping dust collector filters (assumes 50% PM2.5) (lbs)0.05 0.00313 12.51 0.00626
The emissions calculated above above are based on the assumptions below.
1. All finsihing and etching is performed indoors. Any emissions not captured would fall to the floor indoors.
2. Most of the material removed from the balls are large particles from the ball finishing (grinding) operation.
3. The fraction of the debris that is PM10 or smaller was determined by visual observation.
4. The filters in the dust collector are rated for 99.99% capture. The calculations assume a worst case 99.9% efficiency.
5. The PM10 collected by the dust collector is assumed to be 50% PM2.5.
Appendix G
BACT Determination – Ball Finishing and Laser Etching
Facility: Storm Products – Brigham City, UT
Process: Ball Finishing and Laser Etching
Pollutant(s) Considered: PM2.5, PM10
Date of Determination: October 26, 2023
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)
This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants.
Description of Emissions – The facility manufactures bowling balls with a urethane outer shell.
Once formed, the balls are finished (ground) and laser etched. These two processes create
particulate matter.
Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest feasible control alternative was determined
to be Control Alternative #1.
Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1.Dust collector with high efficiency
(99.9+%) polyester media
0.0125 tons PM 12.5 tons PM $4,345
2.Discharge with no controls 12.5 tons PM 0.0 tons PM Baseline
(No cost)
Control Alternative 1 – Purchase and install a 27,000 CFM dust collector with high efficiency
filters.
Energy Impacts: Energy would be consumed to provide electricity for the main dust collector
fan. This dust collector would operate 4,000 hours per year (16 x 5 x 50).
1 x 100 HP x 0.746 KW/HP = 74.6 KW/hr x 4,000 hrs/yr = 298,400 KW/yr = 1,015 MMBTU/yr
Environmental Impacts: PM emissions would be lower.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would be tolerable.
Page 2
Cost Factor Annual Cost ($)
Initial cost – Purchase and install 27,000 CFM dust collector.
Purchase price ............ $113,900
Installation Cost .......... 25,000
Total ........................... $138,900
Annual cost assumes a ten year equipment life.
13,890
Cost to finance (averaged over life) (assumes 6% rate) 4,614
Electrical cost (main fan): 74.6 KW/Hr x 4,000 Hrs x $0.12 / KW 35,808
Total Annual Cost: $54,312
PM reduction using this BACT: 12.5 tons PM
Cost per ton to control: $4,345/ton PM
Other Considerations: None.
Control Alternative 2 – Exhaust to Outdoors with No Control – This method requires ducting and
an exhaust fan, but would not have any filtration.
Energy Impacts: Energy would consumed to provide electricity for the main exhaust fans. This
device would operate 4,000 hours per year.
1 x 75 HP x 0.746 KW/HP = 55.95 KW/hr x 4,000 hrs/yr = 223,800 KW/yr = 759 MMBTU/yr
Environmental Impacts: PM emissions would be higher.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would be tolerable.
Cost Factor Annual Cost ($)
Initial cost – Fan, ductwork and installation
Total ........................... $12,500
Annual cost assumes a ten year equipment life.
1,250
Cost to finance (averaged over life) (assumes 6% rate) 410
Electrical cost (exhaust fan): 55.95 KW/Hr x 4,000 Hrs x $0.12/KW 26,856
Total Annual Cost: $28,516
PM reduction using this BACT: 0 tons PM
Cost per ton to control: NA
Other Considerations: None.
Conclusion: Control Alternative #1 was determined to be feasible and to constitute BACT. The
other control alternatives were not as stringent.
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)
Baghouse Description
1. Briefly describe the process controlled by this baghouse:
Gas Stream Characteristics
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (qF):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
Ƒ Nomex nylon
Ƒ Polyester
Ƒ Acrylics
Ƒ Fiber glass
Ƒ Cotton
Ƒ Teflon
Ƒ ___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
Ƒ Reverse Air Ƒ Shaker
Ƒ Pulse Jet Ƒ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Storm Products Inc
Brigham City
October 26, 2023
Grinding and laser etching of bowling balls.
27,000
27,00027,000
75 100 HP
00
00
00
00
00
0.00626 0.01251
X
MCF Filter, Model 144MCF361 Style III
5 inches 12 feet
361
12
36
99.99
16
8325.2 X
5" 1"
Unknown UnknownUnknown
0.00313 0.00626