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Home My WebLink AboutDAQ-2024-008987 DAQE-AN104820003-24 {{$d1 }} Max Kelsch Fashion Cabinet Manufacturing, Incorporated 5440 West Axel Park Road West Jordan, UT 84081 max@fashioncabinet.com Dear Mr. Kelsch: Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN104820002-22 to Change Type of Primer Basecoat, Resulting in a Reduction in Air Pollutants under Rule R307-401-12 Project Number: N104820003 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on May 21, 2024. Fashion Cabinet Manufacturing, Incorporated must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Christine Bodell, who can be contacted at (385) 290-2690 or cbodell@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. Sincerely, {{$s }} Bryce C. Bird Director BCB:CB:jg cc: Salt Lake County 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 Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director July 3, 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-AN104820003-24 Administrative Amendment to Approval Order DAQE-AN104820002-22 to Change Type of Primer Basecoat, Resulting in a Reduction in Air Pollutants under Rule R307-401-12 Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to Fashion Cabinet Manufacturing, Incorporated - Cabinet Manufacturer Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality July 3, 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-AN104820003-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Fashion Cabinet Manufacturing, Incorporated Fashion Cabinet Manufacturing, Incorporated - Cabinet Manufacturer Mailing Address Physical Address 5440 West Axel Park Road 5440 West Axel Park Road West Jordan, UT 84081 West Jordan, UT 84084 Source Contact UTM Coordinates Name: Max Kelsch 413,605 m Easting Phone: (801) 280-0646 4,492,186 m Northing Email: max@fashioncabinet.com Datum NAD83 UTM Zone 12 SIC code 2434 (Wood Kitchen Cabinets) SOURCE INFORMATION General Description Fashion Cabinet Manufacturing, Incorporated (Fashion Cabinet) manufactures and finishes kitchen cabinets. Various wood products (lumber, fiberboard, and plywood) are milled, sanded, and assembled into boxes and doors. The fabricated products are then sprayed with various combinations of sealer, stain, and topcoats in spray booths. Dust from the milling and sanding operations is captured by baghouses and vented indoors or outdoors, depending on the time of year. The surface coating lines are controlled by particulate filters, HVLP guns, and VOC and HAP emission limitations. Various natural gas-fired heaters rated less than 5.0 MMBtu/hr are used throughout the facility. NSR Classification Administrative Amendment Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: SM Applicable Federal Standards None DAQE-AN104820003-24 Page 4 Project Description Fashion Cabinet has requested an administrative amendment to Approval Order (AO) DAQE-AN104820002-22, dated November 2, 2022, to reduce the VOC and HAPs limits outlined in Condition II.B.2.a. Fashion Cabinets' emissions of VOCs and HAPs are associated with the application of various coatings, sealers, and stains to fabricated cabinets produced within the facility. A significant portion of the customer cabinet orders produced by Fashion Cabinets have a paint-grade finish, in which cases a base "primer coating" is applied to the surface of the cabinets prior to the application of the top coatings. Fashion Cabinet will be switching to a primer coating with a lower VOC and HAP content than what is currently used. The changes will result in a net decrease in all emissions. This project meets the requirements of Utah Administrative Code R307-401-12, Reduction in Air Pollutants, and does not require a public comment period. 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) Carbon Monoxide 0 0.10 Nitrogen Oxides 0 0.49 Particulate Matter - PM10 0 4.66 Particulate Matter - PM2.5 0 4.66 Volatile Organic Compounds -6.69 49.31 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Cumene (CAS #98828) 0 240 Ethyl Benzene (CAS #100414) -320 2600 Formaldehyde (CAS #50000) 0 300 Generic HAPs (CAS #GHAPS) 0 61 Hexane (CAS #110543) 0 780 Toluene (CAS #108883) 0 2440 Xylenes (Isomers And Mixture) (CAS #1330207) -1960 14600 Change (TPY) Total (TPY) Total HAPs -1.14 10.51 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] DAQE-AN104820003-24 Page 5 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] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Fashion Cabinet Manufacturing, Incorporated Cabinet Manufacturer II.A.2 Six (6) Manual Spray Booths Controls: Particulate Filters (each) II.A.3 One (1) Automated Spray Booth Controls: Particulate Filters II.A.4 Three (3) Baghouses with Cyclones Three (3) baghouses in series with three (3) cyclones Maximum Capacities: One (1) 50 hp baghouse; two (2) 100 hp baghouses Control milling and sanding operations II.A.5 Miscellaneous Boilers and Heaters Includes: Space Heaters and Air Make-Up Units Maximum Rated Capacity: Less than 5.0 MMBtu/hr each Fuel: Natural Gas II.A.6 One (1) Laminator Listed for Identification Purposes Only DAQE-AN104820003-24 Page 6 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Source-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. Spray booth ventilation exhaust stacks - 10% opacity. B. Baghouses - 10% opacity. C. All other emission points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall comply with all applicable requirements of UAC R307-343, "Wood Furniture Manufacturing Operations." [R307-343] II.B.1.c The owner/operator shall comply with all applicable requirements of UAC R307-342, "Adhesives and Sealants." [R307-342] II.B.2 VOC and HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: A. 49.31 tons per rolling 12-month period of VOCs. B. 8.76 tons per rolling 12-month period of all HAPs combined. C. 1.30 tons per rolling 12-month period of ethyl benzene. D. 0.15 tons per rolling 12-month period of formaldehyde. E. 1.22 tons per rolling 12-month period of toluene. F. 7.30 tons per rolling 12-month period of xylene. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] DAQE-AN104820003-24 Page 7 II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name as per Safety Data Sheet (SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material. G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.2.b The owner/operator shall not use a primer basecoat that contains greater than 0.2% VOCs by weight or contains any HAPs for all paint-grade cabinet finishes. [R307-401-8] II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the SDS for the primer basecoat. [R307-401-8] II.B.3 Baghouse Requirements II.B.3.a The owner/operator shall control all milling and sanding operations with baghouses in series with cyclones. [R307-401-8] II.B.3.b The owner/operator shall maintain the pressure drop for each milling and sanding baghouse between 4.0 and 6.0 inches of water column. [R307-401-8] II.B.3.b.1 The owner/operator shall monitor and record the pressure drop once daily, while the baghouses are operating. [R307-401-8] II.B.3.b.2 The owner/operator shall monitor the pressure drop with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.3.b.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8] II.B.3.c The owner/operator shall not vent the baghouses outside of the building during the period from September 30th through May 1st of each year. [R307-401-8] DAQE-AN104820003-24 Page 8 II.B.3.c.1 The owner/operator shall inspect the baghouse vents monthly to verify whether venting is indoors or outdoors. Records of baghouse vent inspections shall include the following: A. Date of inspection. B. Name of person conducting inspection. C. Vent location. D. Inspection results (venting indoors or outdoors). [R307-401-8] II.B.4 Spray Booth Requirements II.B.4.a The owner/operator shall equip each spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the spray booths shall pass through this control system before being vented to the atmosphere. [R307-401-8] II.B.4.b The spray booths shall be equipped with HVLP spray guns, or an equivalent method, to control VOC emissions. [R307-343-5] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN104820002-22 dated November 2, 2022 Is Derived From NOI dated May 21, 2024 DAQE-AN104820003-24 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 RMEC PJ24E-4783 May 21, 2024 Bryce Bird Director Utah Division of Air Quality 195 North 1950 West P.O. Box 144820 Salt Lake City, Utah 84114-4820 SUBJECT: ADMINISTRATIVE AMENDMENT REQUEST RE: FASHION CABINETS MANUFACTURING, INC. – CABINET MANUFACTURER (UDAQ Approval Order: DAQE-AN104820001-21) 5440 West Axel Park Road West Jordan, UT 84081 Dear Mr. Bird: On behalf of Fashion Cabinets Manufacturing, Inc. (Fashion Cabinets), RMEC Environmental, Inc. (RMEC) is hereby providing the Utah Division of Air Quality (UDAQ) with the following request for an administrative amendment of the above-referenced Approval Order (AO). This request is in accordance with the provisions for a “Reduction in Air Pollutants” as per Utah Administrative Code R304-401-12. The basis for this request is due to a reduction in the emissions of volatile organic compound (VOCs) and hazardous air pollutants (HAPs) associated with primer coatings that are used in the facility’s cabinet manufacturing and coating operations. DESCRIPTION OF MODIFICATION Background Information Fashion Cabinets’ emissions of VOCs are associated with application of various coatings, sealers, and stains to fabricated cabinets produced within the facility. A significant portion of the customer cabinet orders produced by Fashion Cabinets have a paint grade finish, in which cases a base “primer coating” is applied to the surface of the cabinets prior to the application of the top coatings. In recent months, Fashion Cabinets has transitioned to using Sher-Wood® 5421W Gen II Universal Primer as the basecoat for all paint grade cabinet finishes. Sher-Wood® 5421W is a water-based primer containing only 0.2% VOC (0.025 lbs/gallon). Prior to this transition, Fashion Cabinets used Sher-Wood® Kemvar® 5411S Wood Surfacer as the primer for all paint grade cabinet finishes. Sher-Wood® Kemvar® 5411S is an oil-based primer containing 34.3% VOC (3.74 lbs/gallon) in addition to 5.0% xylene (0.545 lbs/gallon) and 0.80 ethylbenzene (0.087 lbs/gallon). Copies of SDSs for both primer products are provided in Attachment A. After several months of production, Fashion Cabinets has validated the performance of the new, low-VOC primer and intends to continue using this, or similar products, for all paint grade cabinet orders going forward. With that decision, Fashion Cabinets is hereby requesting a decrease in VOC and HAP emissions limitations as specified in the current AO. IDEQ-AQD RMEC PJ23E-4681 Page 2 of 3 May 21, 2024 Calculation of Emission Reductions Primer usage at the facility can fluctuate month-to-month and year-to-year depending on the prevalence of cabinet orders with paint grade finishes. Based on historical emission tracking data, the most primer usage in a 12-month rolling period was in the 2021 calendar year when 3,604 gallons of primer were applied. Fashion Cabinets is requesting a reduction based on this historical maximum primer usage. Table 1, below, provides a summary of changes in emissions in VOCs and HAPs based on the change in primer coatings: Table 1: Summary of Changes in VOC and HAP Emissions from Primer Coatings Air Contaminant Composition Throughput Emissions (lbs/gallon) (gallons) (lbs) (tons) Sher-Wood® 5421W Gen II Universal Primer VOCs 0.025 3,604 90 0.045 Sher-Wood® Kemvar® 5411S Wood Surfacer VOCs 3.735 -3,604 -13,461 -6.730 Xylene 0.545 -1,964 -0.982 Ethylbenzene 0.087 -314 -0.157 Net Change in VOCs -13,371 -6.685 Net Change in Xylene -1,964 -0.982 Net Change in Ethylbenzene -314 -0.157 REVISED VOC AND HAP EMISSION REQUIREMENTS The revised VOC and HAP limitation for the proposed changes to the AO are presented in Table 2, below, based on the net changes in emissions presented in Table 1: Table 2: Summary of Source Revised VOC and HAP Emission Limitations Pollutant Current Approval Order Limit Net Changes in Emission Revised Limit (lbs) (tons) (lbs) (tons) (lbs) (tons) VOCs 112,000 56.00 -13,461 -6.73 98,539 49.27 Xylenes 16,560 8.28 -1,964 -0.98 14,596 7.30 Ethylbenzene 2,920 1.46 -314 -0.16 2,606 1.30 CLOSING In closing, we will clarify that no other changes in the facility details or site contact information are required as part of the request. IDEQ-AQD RMEC PJ23E-4681 Page 3 of 3 May 21, 2024 Please feel free to contact me or Max Kelsch if you have any questions or concerns regarding this request. Max can be reached at 801.280.0646 ext. 312. or by email at max@fashioncabinet.com. I can be reached at 801.467.3661 or by email at dhancock@rmec.net. Sincerely, Daryl Hancock, CHMM, CEM Principal Scientist RMEC ENVIRONMENTAL, INC. ATTACHMENTS: Attachment A – Primer SDSs ATTACHMENT A – PRIMER SDSs 12.64 lbs/g * (0.2%/100%) = 0.025 lbs/gallon 10.89 lbs/gallon *(34.3%/100?) = 3.74 lbs/gallon