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HomeMy WebLinkAboutDAQ-2024-010586 DAQE-AN127360004-24 {{$d1 }} Sid Clements C & C Cast Polymers Incorporated 1525 West 275 South Lindon, UT 84042 sidclem1@aol.com Dear Mr. Clements: Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN2736002-06 for a 10-Year Review and Permit Updates Project Number: N127360004 The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year administrative review of this source and its respective AO. C & C Cast Polymers Incorporated must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Lucia Mason, who can be contacted at (385) 707-7669 or lbmason@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. Sincerely, {{$s }} Bryce C. Bird Director BCB:LM:jg 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 September 6, 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-AN127360004-24 Administrative Amendment to Approval Order DAQE-AN2736002-06 for a 10-Year Review and Permit Updates Prepared By Lucia Mason, Engineer (385) 707-7669 lbmason@utah.gov Issued to C & C Cast Polymers Incorporated - Cultured Marble Manufacturing Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality September 6, 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.................................................................................................................. 3 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 5 PERMIT HISTORY ..................................................................................................................... 7 ACRONYMS ................................................................................................................................. 8 DAQE-AN127360004-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name C & C Cast Polymers Incorporated C & C Cast Polymers Incorporated - Cultured Marble Manufacturing Mailing Address Physical Address 1525 West 275 South 1525 West 275 South Lindon, UT 84042 Lindon, UT 84042 Source Contact UTM Coordinates Name: Sid Clements 436,035 m Easting Phone: (801) 623-0071 4,464,800 m Northing Email: sidclem1@aol.com Datum NAD83 UTM Zone 12 SIC code 3089 (Plastics Products, NEC) SOURCE INFORMATION General Description C & C Cast Polymers Incorporated manufactures cured resin vanity tops, tub surrounds, and showers in Lindon, Utah County. The appropriate molds are sprayed with a gel coat in a vented area. The molds are then filled with a mixture of catalyzed resin, fillers, and color. The molds are vibrated and then placed on drying racks. The dried material is removed from the mold, and the rough edges are ground off. The product is polished with a buffing compound and sent out to the job site. NSR Classification 10-Year Review Source Classification Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA Utah County Airs Source Size: B Applicable Federal Standards None Project Description This project is a 10-year review of this source and the Approval Order associated with it. The DAQ is updating the language and format of the 2006 AO. Additionally, Approval Order DAQE-AN2736002-06 includes methyl chloride as a HAP emitted by the facility. The source confirmed that methyl chloride is DAQE-AN127360004-24 Page 4 no longer used at the facility. The DAQ is removing methyl chloride emissions from this AO accordingly. No other changes in operations or equipment are currently taking place at the Cultured Marble Plant. 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 0.01 Nitrogen Oxides 0.04 Volatile Organic Compounds 13.74 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Dimethyl Phthalate (CAS #131113) 2420 Methyl Methacrylate (CAS #80626) 760 Styrene (CAS #100425) 19500 Toluene (CAS #108883) 2320 Change (TPY) Total (TPY) Total HAPs -1.24 12.50 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] DAQE-AN127360004-24 Page 5 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 C & C Polymers Incorporated Cultured Marble Manufacturing Facility II.A.2 Two (2) gel spray guns II.A.3 One (1) bulk resin storage tank II.A.4 Miscellaneous containers, including Tanks Buckets II.A.5 Miscellaneous natural gas heaters and furnace Rating: <5 MMBtu/hr each II.A.6 Miscellaneous material shaping equipment, including Saws Grinders Sanders II.A.7 Miscellaneous propane forklifts and heaters SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not exceed the following opacity limits for the indicated emission units. A. All heating equipment - 10% opacity. B. All vents to the atmosphere - 10% opacity. [R307-401-8] II.B.1.a.1 The owner/operator shall conduct visible opacity emissions according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall use natural gas and/or propane as fuel in all combustion equipment. [R307-401-8] DAQE-AN127360004-24 Page 6 II.B.2 VOC & 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. 13.74 tons per rolling 12-month period of VOCs (including all HAPs). B. 12.50 tons per rolling 12-month period of all HAPs combined. C. 9.75 tons per rolling 12-month period for styrene. D. 0.38 tons per rolling 12-month period for methyl methacrylate. E. 1.16 tons per rolling 12-month period for toluene. F. 1.21 tons per rolling 12-month period for dimethyl phthalate. [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 Director shall use the rolling 12-month total to determine compliance. Except for styrene, 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]. The source shall follow AP-42 Chapter 4.4, Polyester Resin Plastic Products Fabrication, to calculate styrene emissions. [R307-401-8] 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] DAQE-AN127360004-24 Page 7 II.B.2.a.3 The owner/operator shall keep records each month of the following for all VOC and HAP emissions, with the exception of styrene: A. The name (as per 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 cover all VOC/HAP-containing materials when not in use. [R307-401-8] II.B.2.c The owner/operator shall comply with the applicable requirements under R307-342 for adhesives and sealants. [R307-342] II.B.2.d The owner/operator shall comply with the applicable requirements under R307-353 for plastic part coatings. [R307-353] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN2736002-06 dated January 13, 2006 DAQE-AN127360004-24 Page 8 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by 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- RN127360004 August 14, 2024 Sid Clements C & C Cast Polymers Incorporated 1525 West 275 South Lindon, UT 84042 sidclem1@aol.com Dear Sid Clements, Re: Engineer Review - Administrative Amendment to Approval Order DAQE-AN2736002-06 for a 10-Year Review and Permit Updates Project Number: N127360004 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. C & C Cast Polymers Incorporated should complete this review within 10 business days of receipt. C & C Cast Polymers Incorporated should contact Lucia Mason at (385) 707-7669 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Lucia Mason at lbmason@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If C & C Cast Polymers Incorporated does not respond to this letter within 10 business days, the project will move forward without source concurrence. If C & C Cast Polymers 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N127360004 Owner Name C & C Cast Polymers Incorporated Mailing Address 1525 West 275 South Lindon, UT 84042 Source Name C & C Cast Polymers Incorporated- Cultured Marble Manufacturing Source Location 1525 West 275 South Lindon, UT 84042 UTM Projection 436,035 m Easting, 4,464,800 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3089 (Plastics Products, NEC) Source Contact Sid Clements Phone Number (801) 623-0071 Email sidclem1@aol.com Billing Contact Sid Clements Phone Number (801) 623-0071 Email sidclem1@aol.com Project Engineer Lucia Mason, Engineer Phone Number (385) 707-7669 Email lbmason@utah.gov Notice of Intent (NOI) Submitted July 10, 2024 Date of Accepted Application July 26, 2024 Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 2 SOURCE DESCRIPTION General Description C & C Cast Polymers Incorporated manufactures cured resin vanity tops, tub surrounds, and showers in Lindon, Utah County. The appropriate molds are sprayed with a gel coat in a vented area. The molds are then filled with a mixture of catalyzed resin, fillers, and color. The molds are vibrated and then placed on drying racks. The dried material is removed from the mold and the rough edges are ground off. The product is polished with a buffing compound and sent out to the job site. NSR Classification: 10-Year Review Source Classification Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA Utah County Airs Source Size: B Applicable Federal Standards None Project Proposal Administrative Amendment to Approval Order DAQE-AN2736002-06 for a 10- Year Review and Permit Updates Project Description This project is a 10- year review of this source and the Approval Order associated with it. The DAQ is updating the language and format of the 2006 AO. Additionally, Approval Order DAQE-AN2736002-06 includes methyl chloride as a HAP emitted by the facility. The source confirmed that methyl chloride is no longer used at the facility. The DAQ is removing methyl chloride emissions from this AO accordingly. No other changes in operations or equipment are currently taking place at the Cultured Marble Plant. EMISSION IMPACT ANALYSIS This is a 10- year review. No increases in emissions or equipment additions are being made at this time. Therefore, no modeling is currently required. [Last updated August 13, 2024] Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 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) Carbon Monoxide 0.01 Nitrogen Oxides 0.04 Volatile Organic Compounds 13.74 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Dimethyl Phthalate (CAS #131113) 2420 Methyl Methacrylate (CAS #80626) 760 Styrene (CAS #100425) 19500 Toluene (CAS #108883) 2320 Change (TPY) Total (TPY) Total HAPs -1.24 12.50 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding 10- Year Review This is a 10- year review. No increases in emissions or equipment additions are being made at this time. Therefore, a BACT analysis is not currently required. [Last updated August 13, 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 N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 5 SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 NEW C & C Polymers Incorporated Cultured Marble Manufacturing Facility II.A.2 NEW Two (2) gel spray guns II.A.3 NEW One (1) bulk resin storage tank II.A.4 NEW Miscellaneous containers including Tanks Buckets II.A.5 NEW Miscellaneous natural gas heaters and furnace Rating: <5MMBtu/hr each II.A.6 NEW Miscellaneous material shaping equipment including Saws Grinders Sanders II.A.7 NEW Miscellaneous propane forklifts and heaters SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 NEW Site-Wide Requirements II.B.1.a NEW The owner/operator shall not exceed the following opacity limits for the indicated emission units. A. All heating equipment - 10% opacity. B. All vents to the atmosphere - 10% opacity. [R307-401-8] Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 6 II.B.1.a.1 NEW The owner/operator shall conduct visible opacity emissions according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b NEW The owner/operator shall use natural gas and/or propane as fuel in all combustion equipment. [R307-401-8] II.B.2 NEW VOC & HAP Requirements II.B.2.a NEW The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: A. 13.74 tons per rolling 12-month period of VOCs (including all HAPs). B. 12.50 tons per rolling 12-month period of all HAPs combined. C. 9.75 tons per rolling 12-month period for styrene. D. 0.38 tons per rolling 12-month period for methyl methacrylate. E. 1.16 tons per rolling 12-month period for toluene. F. 1.21 tons per rolling 12-month period for dimethyl phthalate. [R307-401-8] II.B.2.a.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 Director shall use the rolling 12-month total to determine compliance. Except for styrene, 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] The source shall follow AP-42 Chapter 4.4, Polyester Resin Plastic Products Fabrication, to calculate styrene emissions. [R307-401-8] II.B.2.a.2 NEW 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] Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 7 II.B.2.a.3 NEW The owner/operator shall keep records each month of the following for all VOC and HAP emissions with the exception of styrene: A. The name (as per 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 NEW The owner/operator shall cover all VOC/HAP containing materials when not in use. [R307-401-8] II.B.2.c NEW The owner/operator shall comply with the applicable requirements under R307-342 for adhesives and sealants. [R307-342] II.B.2.d NEW The owner/operator shall comply with the applicable requirements under R307-353 for plastic parts coatings. [R307-353] Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 8 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN2736002-06 dated January 13, 2006 REVIEWER COMMENTS 1. Comment regarding 10 -Year Review: This is a 10- year review. The equipment list and emission summary have been moved to different sections. All contact information has been confirmed and updated. The language and formatting of the permit has been updated to reflect modern Approval Orders. On July 31, 2024, the source confirmed they no longer use methylene chloride which was listed on the 2006 AO (DAQE-AN2736002-06) at 1.24 tons per rolling 12-month period. Methyl chloride emissions have been removed accordingly. No other changes to equipment or operations are taking place at this time. [Last updated August 14, 2024] 2. Comment regarding Federal Standard Applicability: NSPS, 40 CFR 60 No standards under NSPS 40 CFR 60 apply to the source. NESHAP, 40 CFR 61 No standards under NESHAP 40 CFR 61 apply to the source. MACT, 40 CFR 63 Subpart HHHHHH establishes national emission standards for hazardous air pollutants with respect to paint stripping and miscellaneous surface coat operations at area sources. In regard to spray coating operations, Subpart HHHHHH only applies to coatings on mobile sources (ie cars) and sprays containing any target HAPs (chromium, lead, manganese, nickel, or cadmium). The gel coating used by the facility does not contain any target HAPs. Therefore, Subpart HHHHHH does not apply. Subpart U establishes national emission standards for hazardous air pollutants for Group I polymers and resins. However, Subpart U does not apply to area sources and therefore is not applicable to the facility. Subpart JJJ establishes national emission standards for hazardous air pollutants for Group IV polymers and resins. However, Subpart JJJ does not apply to area sources and therefore is not applicable to the facility. 40 CFR 63 Subpart WWWW establishes national emission standards for hazardous air pollutants with respect to reinforced plastic composites. Subpart WWWW only applies to major HAP sources. The facility is not a major HAP source and therefore is not subject to Subpart WWWW. [Last updated August 14, 2024] Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 9 3. Comment regarding 10- Year Review: 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 61 (NESHAP), 40 CFR 60 (NSPS) or 40 CFR (MACT) regulations. Therefore, Title V does not apply to this facility. [Last updated August 14, 2024] Engineer Review N127360004: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing August 14, 2024 Page 10 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 Lucia Mason <lbmason@utah.gov> Compliance Review of 10- Year Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing 5 messages Lucia Mason <lbmason@utah.gov>Mon, Aug 5, 2024 at 10:21 AM To: Chad Gilgen <cgilgen@utah.gov> Hi Chad, Could you review this ER of a 10- Year Review? Let me know if you have any questions or feedback. Thanks, Lucia 10YR, 12736 0004: C & C Cast Polymers Incorporate… FINAL ER, 12736 C & C Cast Polymers Incorporated- Cultured Marble Manufacturing.rtf 1488K Chad Gilgen <cgilgen@utah.gov>Sun, Aug 11, 2024 at 3:59 PM To: Lucia Mason <lbmason@utah.gov> Hi Lucia, I have completed the compliance review for this 10-year review ER. See attached for a comment. Thanks, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) 8/13/24, 9:59 AM State of Utah Mail - Compliance Review of 10- Year Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2055290896512226160&simpl=msg-a:r-3215764927754096821&simpl=msg-f:1807130134852357405&simpl…1/3 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] FINAL ER, 12736 C & C Cast Polymers Incorporated- Cultured Marble Manufacturing_cg.rtf 1489K Lucia Mason <lbmason@utah.gov>Mon, Aug 12, 2024 at 8:12 AM To: Chad Gilgen <cgilgen@utah.gov> Thanks Chad. I've added the two state rules in the attached draft. Let me know if you have more comments. Lucia [Quoted text hidden] COMP #2 ER, 12736 C & C Cast Polymers Incorporated- Cultured Marble Manufacturing .rtf 1492K Chad Gilgen <cgilgen@utah.gov>Tue, Aug 13, 2024 at 9:38 AM To: Lucia Mason <lbmason@utah.gov> Hi Lucia, Thanks for sending that over. The changes look good and I have no further comments. I have also signed off on the WAL. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 8/13/24, 9:59 AM State of Utah Mail - Compliance Review of 10- Year Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2055290896512226160&simpl=msg-a:r-3215764927754096821&simpl=msg-f:1807130134852357405&simpl…2/3 Lucia Mason <lbmason@utah.gov>Tue, Aug 13, 2024 at 9:46 AM To: Chad Gilgen <cgilgen@utah.gov> Thanks! [Quoted text hidden] 8/13/24, 9:59 AM State of Utah Mail - Compliance Review of 10- Year Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2055290896512226160&simpl=msg-a:r-3215764927754096821&simpl=msg-f:1807130134852357405&simpl…3/3 Lucia Mason <lbmason@utah.gov> DAQ Approval Order Review (10 days), 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing 4 messages Lucia Mason <lbmason@utah.gov>Wed, Aug 14, 2024 at 5:11 PM To: Sid Clements <sidclem1@aol.com> Hi Sid, The DAQ has completed C&C Cast Polymers Incorperated's updated Approval Order. Before it is issued you have ten days to review the document and get back to the Division of Air Quality (DAQ) with any concerns. The updated permit is attached. If you have any questions or concerns please get back to me by 8/28/24 at the latest. Hope you're having a good week! Lucia SOURCE #1 ER, 12736 C & C Cast Polymers Incorporated- Cultured Marble Manufacturing.rtf 1491K Lucia Mason <lbmason@utah.gov>Thu, Aug 29, 2024 at 3:01 PM To: Sid Clements <sidclem1@aol.com> Hey Sid, Please take a look at the attached draft Approval Order and get back to me with any questions or concerns. If it looks good to you we can move forward with issuing the permit. Thanks, Lucia [Quoted text hidden] Sid Clements <sidclem1@aol.com>Fri, Aug 30, 2024 at 9:12 AM To: Lucia Mason <lbmason@utah.gov> I think it looks good. You should be able to turn it in. Thanks for your help. 9/3/24, 7:12 AM State of Utah Mail - DAQ Approval Order Review (10 days), 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r717297627037361278&simpl=msg-a:r6381771289478374634&simpl=msg-a:r-4309643308246188183&simpl…1/2 Sent from my iPhone On Aug 29, 2024, at 3:01 PM, Lucia Mason <lbmason@utah.gov> wrote: [Quoted text hidden] Lucia Mason <lbmason@utah.gov>Tue, Sep 3, 2024 at 6:56 AM To: Sid Clements <sidclem1@aol.com> Thank you! [Quoted text hidden] 9/3/24, 7:12 AM State of Utah Mail - DAQ Approval Order Review (10 days), 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r717297627037361278&simpl=msg-a:r6381771289478374634&simpl=msg-a:r-4309643308246188183&simpl…2/2 Lucia Mason <lbmason@utah.gov> Periodic Permit Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing (Division of Air Quality) 7 messages Lucia Mason <lbmason@utah.gov>Wed, Jul 31, 2024 at 11:07 AM To: sidclem1@aol.com Hi Sid, C & C Cast Polymers' Approval Order (AO) is due for its customary 10-year review. This review typically involves updating your old permit (DAQE-AN2736002-06) to align with the language and formatting of current AOs. As I began the review process, I noticed that you would likely qualify for a Small Source Exemption (SSE), as your annual emissions appear to be below the thresholds that necessitate an AO. Before proceeding with updates to your AO, I wanted to offer you the option to switch to an SSE. If you choose this route, you would no longer need to pay the annual NSR fee or undergo regular compliance inspections. To make this switch please submit an SSE application here: https://utahgov.co1.qualtrics.com/jfe/form/SV_3t4JtgzRudum7l3 For more information about SSEs, you can visit the Department of Environmental Quality's website here: https://deq.utah.gov/air-quality/new-source-review-exemptions-from-permitting-air-quality Alternatively, you're welcome to maintain your current AO. If you choose to keep your existing permit, I will contact you to confirm your contact information and discuss any relevant permit updates. Please let me know how you would like to proceed. Feel free to reach out with any questions. Best, Lucia Lucia Mason <lbmason@utah.gov>Wed, Jul 31, 2024 at 2:08 PM To: sidclem1@aol.com Hi Sid, I checked your compliance report again and I realized I read the numbers wrong. You won't be able to qualify for a SSE. Sorry for the confusion. I'm going to go ahead with your standard permit updates. Could you please confirm or update the following: Site Name: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing 7/31/24, 3:43 PM State of Utah Mail - Periodic Permit Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing (Division of Air Quality) https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r3548334454467814909&simpl=msg-a:r-220274910463596075&simpl=msg-a:r-3323014125995721042&simp…1/3 Source Address/Contact: Physical Address: 1525 West 275 South, Lindon UT 84042 Billing Address: 1555 W 200 S, Lindon UT 84042 Work Fax Number: (801) 796-8049 Work Phone Number: (801) 796-8048 Company Address/Contact: Physical Address: 1555 W 200 S, Lindon UT 84042 Mailing Address: 1555 W 200 S, Lindon UT 84042 Work Phone Number: (801) 796-8048 Email: marblemakers@aol.com Relevant Individuals: Primary Approval Order Contact: Name: Sid Clements Physical Address: missing Work Fax Number: provide if available Work Phone Number: (801) 623-0071 Email: sidclem1@aol.com You're welcome to list a name, phone number and email for a seperate billing contact if someone else should receive invoices. Additionally, your compliance report says that you no longer use Methyl Methacrylate and Methylene Chloride. Is this correct? If so, would you like me to remove them from your permit or do you plan on using them in the future? Apologies again for misleading you earlier. Please let me know if you have any questions. Thanks for your time, Lucia [Quoted text hidden] Sid Clements <sidclem1@aol.com>Wed, Jul 31, 2024 at 2:10 PM To: Lucia Mason <lbmason@utah.gov> This is Sid Clements with C&C Cast Polymers, DBA Master Bath. I guess I don’t qualify for the exemption so just let me know what updates you need, I will look for another email or text. Thank you. Sent from my iPhone On Jul 31, 2024, at 11:07 AM, Lucia Mason <lbmason@utah.gov> wrote: 7/31/24, 3:43 PM State of Utah Mail - Periodic Permit Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing (Division of Air Quality) https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r3548334454467814909&simpl=msg-a:r-220274910463596075&simpl=msg-a:r-3323014125995721042&simp…2/3 [Quoted text hidden] Sid Clements <sidclem1@aol.com>Wed, Jul 31, 2024 at 2:17 PM To: Lucia Mason <lbmason@utah.gov> The address has been updated to 1525 W 275 S Lindon, Utah 84042, that is the current updated and correct address for the physical address and billing address. Sent from my iPhone On Jul 31, 2024, at 2:10 PM, Sid Clements <sidclem1@aol.com> wrote: This is Sid Clements with C&C Cast Polymers, DBA Master Bath. I guess I don’t qualify for the exemption so just let me know what updates you need, I will look for another email or text. Thank you. [Quoted text hidden] Lucia Mason <lbmason@utah.gov>Wed, Jul 31, 2024 at 2:18 PM To: Sid Clements <sidclem1@aol.com> Ok great! Thank you! [Quoted text hidden] Sid Clements <sidclem1@aol.com>Wed, Jul 31, 2024 at 2:22 PM To: Lucia Mason <lbmason@utah.gov> We can delete the Methylene Chloride. Sent from my iPhone On Jul 31, 2024, at 2:18 PM, Lucia Mason <lbmason@utah.gov> wrote: [Quoted text hidden] Lucia Mason <lbmason@utah.gov>Wed, Jul 31, 2024 at 2:27 PM To: Sid Clements <sidclem1@aol.com> Sounds good. Thank you! [Quoted text hidden] 7/31/24, 3:43 PM State of Utah Mail - Periodic Permit Review, 12736: C & C Cast Polymers Incorporated- Cultured Marble Manufacturing (Division of Air Quality) https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r3548334454467814909&simpl=msg-a:r-220274910463596075&simpl=msg-a:r-3323014125995721042&simp…3/3 Lucia Mason <lbmason@utah.gov> Six 10-Year Review Projects 2 messages Alan Humpherys <ahumpherys@utah.gov>Wed, Jun 12, 2024 at 9:49 AM To: Lucia Mason <lbmason@utah.gov> Lucia, Please work on the following 10-year review projects. Site #1: 12132 Peer: Christine Old AO: DAQE-AN121320016-22, Feb 23, 2022 Notes: II.B.3.b should state "baghouses" instead of just "baghouse." I'll add it to the list to review. Site #2: 14016 Peer: Tim Old AO: DAQE-AN0140160001-07, May 17, 2007 Site #3: 12736 Peer: EQ Old AO: DAQE-AN2736002-06, Jan 13, 2006 Site #4: 10270 Peer: Dungan Old AO: DAQE-412-00, July 6, 2000 Notes: Needs name change (was Metalcraft) (same or different?) Site #5: 12202 Peer: Dungan Old AO: DAQE-817-01, Oct 4, 2001 Notes: Needs name change (was Metalcraft) (same or different?) Site #6: 10833 Peer: Dylan Old AO: DAQE-AN108330005-12, Nov 28, 2012 Thanks, Alan 7/31/24, 3:43 PM State of Utah Mail - Six 10-Year Review Projects https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801671042937908281&simpl=msg-f:1801671042937908281&simpl=msg-a:r3589728101253066642 1/2 -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Lucia Mason <lbmason@utah.gov>Wed, Jun 12, 2024 at 12:12 PM To: Alan Humpherys <ahumpherys@utah.gov> Ok great! I just met with Teri to set up macros and get an overview of TEMO. I'll start working through one of the ten year reviews before meeting with you later today. [Quoted text hidden] 7/31/24, 3:43 PM State of Utah Mail - Six 10-Year Review Projects https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801671042937908281&simpl=msg-f:1801671042937908281&simpl=msg-a:r3589728101253066642 2/2 1 DAQC-327-24 Site ID 12736 (B1) MEMORANDUM TO: FILE – C & C CAST POLYMERS INCORPORATED THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: March 25, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: March 6, 2024 SOURCE LOCATION: 1525 West 275 South, Lindon UT 84042 C & C Cast Polymers operations take place in the building directly west of the Master Bath building, which is visible from 200 South. C & C Cast Polymers is located east of the Lake Side Power Station. SOURCE CONTACT(S): Sid Clements, Manager, (801) 623-0071, sidclem1@aol.com marblemakers@aol.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: C & C Cast Polymers Incorporated manufactures cured resin vanity tops, tub surrounds, and showers. The appropriate molds are sprayed with a gel coat in a vented area. The molds are then filled with a mixture of catalyzed resin, fillers, and color. The molds are vibrated and then placed on drying racks. The dried material is removed from the mold and the rough edges are grinded off. The product is polished with a buffing compound and sent out to the job site. APPLICABLE REGULATIONS: Approval Order DAQE-AN2736002-06, dated January 13, 2006 SOURCE EVALUATION: General Conditions: 1. This Approval Order (AO) applies to the following company: Site Office C & C Cast Polymers, Inc. 1555 West 200 South Lindon, UT 84042 Phone Number (801) 796-8048 Fax Number (801) 796-8049 00 2 The equipment listed in this AO shall be operated at the following location: Same as above. Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 4,464.748 km. Northing, 435.940 km. Easting, Zone 12 Status: In Compliance. The address was changed to 1525 West 275 South by the USPS but the building was not moved. All other information listed in this condition is unchanged and correct. 2. All definitions, terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these AO conditions refer to those rules. Status: This is not a compliance issue. 3. The limits set forth in this AO shall not be exceeded without prior approval in accordance with R307-401. Status: In Compliance. C & C Cast Polymers did not exceed any of the limits set forth in this AO. 4. Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved in accordance with R307-401-1. Status: In Compliance. C & C Cast Polymers did not make any modifications to the equipment or processes that could affect emissions covered by this AO. 5. All records referenced in this AO, which are required to be kept by the owner/operator, shall be made available to the Executive Secretary or Executive Secretary’s representative upon request, and the records shall include the two-year period prior to the date of the request. Records shall be kept for a minimum two years. Status: In Compliance. C & C Cast Polymers maintains records for a minimum of two years. 6. C & C Cast Polymers shall operate the reinforced plastics manufacturing plant in accordance with the terms and conditions of this AO, which was written pursuant to C & C Cast Polymers’ Notice of Intent submitted to the Division of Air Quality (DAQ) on July 5, 2005. Status: In Compliance. C & C Cast Polymers maintains that their operations are in compliance with the terms and conditions of this AO. 7. This AO shall replace the AO (DAQE-AN2736001-02) dated November 25, 2002. Status: In Compliance. Only this AO was used to determine compliance. 3 8. The approved installations shall consist of the following equipment: A. Two (2) gel spray guns B. Miscellaneous containers including tanks and buckets C. Miscellaneous natural gas heaters and furnace D. Miscellaneous propane fork lifts and heaters E. Miscellaneous saws, grinders, sanders and etc. F. One (1) bulk resin storage tank Status: In Compliance. There was no unapproved equipment observed onsite during this inspection. Additional equipment information gathered at the time of inspection: F- One (1) bulk resin storage tank is still on-site but has not been used for several years. The source indicated that resin is now purchased in 2800 lbs. totes and gel coat is purchased in 55-gallon drums. Limitations and Tests Procedures 9. Visible emissions from the following emission points shall not exceed the following values: A. All heating equipment - 10% opacity B. All vents to the atmosphere - 10% C. Forklifts - 20% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Status: In Compliance. There were no visible emissions observed from the heating equipment, vents, and forklifts during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. Fuels 10. The owner/operator shall use natural gas and/or propane as fuel in the combustion equipment. Status: In Compliance. C & C Cast Polymers only uses natural gas/and or propane as fuel in the combustion equipment. 4 VOC and Hazardous Air Pollutants (HAPs) Limitations 11. VOC/HAP containing materials shall be covered except when in use. Status: In Compliance. There were no uncovered VOC/HAP containing materials observed during this inspection. 12. The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement applicators, etc. and associated operations shall not exceed: 13.74 tons per rolling 12-month period for VOC (including all HAPs) 9.75 tons per rolling 12-month period for Styrene 0.38 tons per rolling 12-month period for Methyl Methacrylate 1.16 tons per rolling 12-month period for Toluene 1.21 tons per rolling 12-month period for Dimethyl Phthalate 1.24 tons per rolling 12-month period for Methylene Chloride 13.74 tons per rolling 12-month period for all HAPs combined Status: In Compliance. The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement applicators, etc. and associated operations did not exceed the AO limits in the rolling 12-month period from March 2023 through February 2024: 3.19 tons per rolling 12-month period for VOC (including all HAPs) 2.56 tons per rolling 12-month period for Styrene 2.91 tons per rolling 12-month period for all HAPs combined C & C Cast Polymers no longer uses Methyl Methacrylate and Methylene Chloride. Compliance with each of the limitations shall be determined on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Except for styrene emissions, the VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC and HAP emitting material, such as paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC and HAP in each material used D. Gallons of each VOC and HAP emitting material used 5 E. The amount of VOC and HAP emitted monthly by each material used shall be calculated by the following procedure: VOC = % VOC by Weight x [Density ( lb )] x Gal Consumed x 1 ton 100) (gal) 2000 lb HAP = % HAP by Weight x [Density ( lb )] x Gal Consumed x 1 ton 100) (gal) 2000 lb F. The amount of VOC or HAP emitted monthly from all materials used G. The amount of VOC or HAP reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. The source shall follow AP-42 Chapter 4.4, Polyester Resin Plastic Products Fabrication, to calculate styrene emissions. Status: In Compliance. C & C Cast Polymers maintains a monthly record of VOC and HAP emitting materials to determine VOC and HAP emissions. Records & Miscellaneous 13. 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 Executive Secretary which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. Status: In Compliance. C & C Cast Polymers Incorporated conducts regular maintenance of the two gel spray guns. Acetone is used to clean the spray guns. 14. The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. Status: In Compliance. C & C Cast Polymers Incorporated submitted the 2020 Emissions Inventory Report, and the emissions indicated compliance with the PTEs of this AO. 15. The owner/operator shall comply with R307-107. General Requirements: Unavoidable Breakdowns. Status: In Compliance. C & C Cast Polymers Incorporated has not experienced any breakdowns since the last inspection. 6 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards. Status: In Compliance. There were no visible emissions observed from the heating equipment, vents, and forklifts during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. R307-309. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. Status: In Compliance. There were no visible emissions observed during the inspection. R307-325. Ozone Nonattainment and Maintenance Areas: General Requirements. Status: In Compliance. All observed VOC containing materials were in covered storage containers. R307-342. Adhesives and Sealants. Status: In Compliance. C & C Cast Polymers Incorporated uses Bondo, a polyester resin, with a VOC Content of 203 g/L, which is less than the 250 g/L for contact bonds listed in Table 1. R307-353. Plastic Parts Coatings. Status: In Compliance. C & C Cast Polymers Incorporated uses Axiom Marble coating to provide a clear coat, water-resistant, and glossy finish. The VOC Content on the SDS indicated 37% (w/w), which converts to 3.07 lbs/gallon and indicates compliance with Table 1 of R307-353-5 for top coat clear coat. EMISSION INVENTORY: C & C Cast Polymers Incorporated submitted the 2020 activity year Emissions Inventory Report as follows: Pollutant Tons/yr 1. CO ...................................................................... 0.025 2. NOx ..................................................................... 0.03 3. PM10 ................................................................... 0.28 4. SOx ..................................................................... 0.00018 5. VOCs .................................................................. 3.59 7 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In Compliance with the conditions of DAQE-AN2736002-06, dated January 13, 2006, at the time of inspection. The facility appeared to be adequately maintained and operated properly. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. ATTACHMENTS: VEO Form, Rolling 12-month VOC/HAP email