DAQ-2024-011066

DAQE-AN121010007-24

{{$d1 }}

Scott Lindsay
TCR Composites Inc.
219 North 530 West
Ogden, UT 84404
[e-mail]

Dear Mr. Lindsay:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-493-01 for a 10-Year
Review and Permit Updates
Project Number: N121010007

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. TCR Composites Inc. 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 [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.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:LM:jg

cc: Weber-Morgan 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

September 6, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
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{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN121010007-24
Administrative Amendment to Approval Order DAQE-493-01 for a
10-Year Review and Permit Updates

Prepared By
Lucia Mason, Engineer
[phone]
[e-mail]

Issued to
TCR Composites Inc.

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 ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 6
ACRONYMS ................................................................................................................................. 7

DAQE-AN121010007-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
TCR Composites Inc. TCR Composites Inc.

Mailing Address Physical Address
219 North 530 West 219 North 530 West
Ogden, UT 84404 Ogden, UT 84404

Source Contact UTM Coordinates
Name: Robert Eyre 417,000 m Easting
Phone: [phone],568,609 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2295 (Coated Fabrics, Not Rubberized)

SOURCE INFORMATION
General Description
TCR Composites Inc. is an advanced composite materials manufacturer specializing in thermoset epoxy
resins and custom pre-impregnated (prepreg) composite materials. These products are used in an array of
industries, including aerospace, automotive, industrial, and marine. The facility is located in Weber
County.

The process starts with roving and woven manmade fibers (carbon, glass, aramid) that are purchased from
third party suppliers. The roving and woven materials are then impregnated with TRC composites' custom
two-part epoxy-resin systems according to customer needs. After impregnation, the prepreg is sent
through a process that varies in temperature and time based on the resin system before being shipped to
customers. Following the manufacturing processes, all impregnation equipment is cleaned with a 50:50
cleaning solvent blend of MEK and acetone.

NSR Classification
10-Year Review

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Weber County
Airs Source Size: B

DAQE-AN121010007-24
Page 4

Applicable Federal Standards
None
Project Description
This project is a 10-year review of this source and the approved order associated with it.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Volatile Organic Compounds 0 6.60

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

DAQE-AN121010007-24
Page 5

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 TCR Composites Inc. Composite materials manufacturing facility
II.A.2 Miscellaneous Equipment
Material handling equipment
Compressed-air equipment
Lab/testing instruments and equipment
Liquid/solids mixing equipment
Refrigeration/freezer equipment
Industrial maintenance tools and equipment

For informational purposes only

II.A.3 Two (2) Electric Duct-Heating Elements Ducted in series in a single staging-enclosure. Power rating: 32kW Voltage: 460V/3Ph Area: 16' x 16' For informational purposes only

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions on site to exceed 10% opacity. [R307-301-8]
II.B.1.a.1 The owner/operator shall conduct observations of emissions from stationary sources in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 VOC Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources, such as cleaning solvent methyl ethyl ketone (MEK) or equivalent on site: 6.6 tons per rolling 12-month period of VOCs. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 15th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]
DAQE-AN121010007-24
Page 6

II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs. [R307-401-8] II.B.2.a.3 The owner/operator shall keep monthly records of the following for all periods when the plant is
in operation: A. The name of the VOC emitting material used.
B. The amount of cleaning solvent and VOC containing materials consumed each day.
C. The location of cleaning solvent and VOC containing materials consumed each day. The building to which the material was delivered/issued may be considered as used location.
[R307-401-8]

II.B.2.b The owner/operator shall comply with the applicable requirements under R307-304 for solvent cleaning. [R307-304]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-493-01 dated June 27, 2001

DAQE-AN121010007-24
Page 7

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN121010007 September 3, 2024 Scott Lindsay
TCR Composites Inc. 219 North 530 West Ogden, UT 84404
[e-mail] Dear Scott Lindsay,
Re: Engineer Review - Administrative Amendment to DAQE-493-01 for a 10-Year Review and Permit Updates. Project Number: N121010007 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. TCR Composites Inc. should complete this review within 10 business days of receipt. TCR Composites Inc. should contact Lucia Mason at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Lucia Mason at [e-mail] 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 TCR Composites Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If TCR Composites Inc. 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 N121010007: TCR Composites Inc. September 3, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N121010007 Owner Name TCR Composites Inc. Mailing Address 219 North 530 West
Ogden, UT, 84404 Source Name TCR Composites Inc.
Source Location 219 North 530 West Ogden, UT 84404
UTM Projection 417,000 m Easting, 4,568,609 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2295 (Coated Fabrics, Not Rubberized) Source Contact Robert Eyre Phone Number [phone] Email [e-mail] Billing Contact Jolene Cheshire Phone Number [phone]
Email [e-mail] Project Engineer Lucia Mason, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 13, 2024 Date of Accepted Application July 15, 2024

Engineer Review N121010007: TCR Composites Inc. September 3, 2024 Page 2
SOURCE DESCRIPTION General Description
TCR Composites Inc. is an advanced-composite materials manufacturer specializing in thermoset epoxy-resins and custom pre-impregnated (prepreg) composite materials. These products are used in an array of industries including aerospace, automotive, industrial, and marine. The facility is
located in Weber County. The process starts with roving and woven manmade fibers (carbon, glass, aramid) that are purchased from third party suppliers. The roving and woven materials are then impregnated with TRC composites' custom two-part epoxy-resin systems according to customer needs. After impregnation, the prepreg is sent through a process that varies in temperature and time based on the resin system before being shipped to customers. Following the manufacturing processes, all impregnation equipment is cleaned with a 50:50 cleaning-solvent blend of MEK and acetone. NSR Classification: 10- Year Review
Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Weber County Airs Source Size: B
Applicable Federal Standards None Project Proposal Administrative Amendment to DAQE-493-01 for a 10-Year Review and Permit Updates.
Project Description This project is a 10- year review of this source and the approved order associated with it. EMISSION IMPACT ANALYSIS This is a 10- year review. No changes to equipment or emissions are being made at this time. Therefore, modeling is not currently required. [Last updated August 19, 2024]

Engineer Review N121010007: TCR Composites Inc. September 3, 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) Volatile Organic Compounds 0 6.60 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N121010007: TCR Composites Inc. September 3, 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 changes to equipment or emissions are being made at this time. Therefore, a BACT analysis is not currently required. [Last updated August 19, 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 N121010007: TCR Composites Inc. September 3, 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 TCR Composites Inc. Composite materials manufacturing facility
II.A.2 NEW Miscellaneous Equipment 1) Material handling equipment 2) Compressed-air equipment 4) Lab/testing instruments and equipment 5) Liquid/solids mixing equipment 6) Refrigeration/freezer equipment 7) Industrial maintenance tools and equipment For informational purposes only

II.A.3
NEW
Two (2) Electric Duct-Heating Elements
Ducted in series in a single staging-enclosure Power rating: 32kW Voltage: 460V/3Ph
Area: 16' x 16'
For informational purposes only

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1
NEW
Site-Wide Requirements
II.B.1.a NEW The owner/operator shall not allow visible emissions on site to exceed 10% opacity. [R307-301-8] II.B.1.a.1 NEW The owner/operator shall conduct observations of emissions from stationary sources in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]

Engineer Review N121010007: TCR Composites Inc. September 3, 2024 Page 6
II.B.2 NEW VOC Requirements
II.B.2.a NEW The owner/operator shall not emit more than the following from evaporative sources such as cleaning solvent methyl ethyl ketone (MEK) or equivalent on site: 6.6 tons per rolling 12-month period of VOCs. [R307-401-8] II.B.2.a.1 NEW The owner/operator shall calculate a new 12-month total by the 15th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]
II.B.2.a.2 NEW The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs. [R307-401-8] II.B.2.a.3 NEW The owner/operator shall keep monthly records of the following for all periods when the plant is in operation:
A. The name of the VOC emitting material used. B. The amount of cleaning solvent and VOC containing materials consumed each day. C. The location of cleaning solvent and VOC containing materials consumed each day.
The building to which the material was delivered/issued may be considered as used
location.
[R307-401-8]
II.B.2.b NEW The owner/operator shall comply with the applicable requirements under R307-304 for solvent cleaning. [R307-304]

Engineer Review N121010007: TCR Composites Inc. September 3, 2024 Page 7
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-493-01 dated June 27, 2001
REVIEWER COMMENTS
1. Comment regarding 10-Year Review:
The format and wording of the requirements has been updated to reflect the language and layout of modern permits. All contact information and addresses have been confirmed and updated. On August 15th, 2024, the source confirmed that two staging ovens referenced in the 1998 AO (DAQE-493-01) have been replaced with a staging-enclosure heated with two electric-heating
elements in series. These electric-heating elements along with other miscellaneous equipment have been added to the permit for informational purposes only. No other changes in equipment are taking place.
There are no changes in emissions. The only emission limit listed in the 1998 AO was for VOCs.
Accordingly, all other criterial pollutants and HAPs are missing from the Summary of Emissions section. [Last updated August 26, 2024] 2. Comment regarding Federal Standard Applicability: NSPS Requirements, 40 CFR 60 No standards under NSPS 40 CFR 60 apply to the source. NESHAP Requirements, 40 CFR 61 No standards under NESHAP 40 CFR 61 apply to the source.
MACT Requirements, 40 CFR 63 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. Subpart WWWW establishes national emission standards for hazardous air pollutants regarding reinforced plastic composites production for major HAP sources. The facility is not a major HAP source, therefore Subpart WWWW is not applicable.
[Last updated August 20, 2024]

Engineer Review N121010007: TCR Composites Inc. September 3, 2024 Page 8
3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary 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), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. There are no other reasons
why this source would be required to obtain a part 70 permit as an area source; therefore, Title V does not apply to this facility. [Last updated August 19, 2024]

Engineer Review N121010007: TCR Composites Inc. September 3, 2024 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 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 <[e-mail]>
TCR Composites Signed UDAQ AO Permit
2 messages
Scott Lindsay <[e-mail]>Tue, Sep 3, 2024 at 11:52 AM
To: "[e-mail]" <[e-mail]>
Cc: Robert Eyre <[e-mail]>, "Mrs. Randi Hadley" <[e-mail]>
Dear Lucia,

Per your communication with Mr. Rob Eyre (TCR Composites), we have reviewed the UDAQ AO Permit documentation package.
Thank you for your assistance with moving this requirement through the appropriate approval system channels. The signed copy is attached for your records.
Should you have any questions, please feel free to continue communicating with TCR Composites through Rob.

Best regards,
Scott Lindsay

Scott Lindsay

Scott Lindsay
President and General Manager
219 North 530 West, Ogden, UT 84404
t: [phone]
[e-mail]
www.tcrcomposites.com
9/3/24, 4:06 PM State of Utah Mail - TCR Composites Signed UDAQ AO Permit
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1809198289344320437&simpl=msg-f:1809198289344320437&simpl=msg-a:r6649286450752491913 1/2
CONFIDENTIALITY NOTICE: This e-mail is intended solely for use of the individual or entity to which it is addressed and may contain
information that is proprietary, privileged and exempt from disclosure under applicable law. If the reader is not the intended recipient or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this
communication is strictly prohibited. This communication may also contain data subject to U.S. export laws. If so, that data subject to the
International Traffic in Arms Regulation cannot be disseminated, distributed or copied to foreign nationals, residing in the U.S. or abroad,
without the approval of the U.S. Department of State. If you have received this communication in error, please notify the sender by reply e-mail
and destroy the e-mail message and any physical copies made of the communication.
#5 2024-09-03 TCR-Signature_SOURCE 10YR 12101 TCR Composites Inc.-Defense Depot Ogden.pdf
243K
Lucia Mason <[e-mail]>Tue, Sep 3, 2024 at 3:56 PM
To: Scott Lindsay <[e-mail]>
Thank you!
[Quoted text hidden]
9/3/24, 4:06 PM State of Utah Mail - TCR Composites Signed UDAQ AO Permit
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1809198289344320437&simpl=msg-f:1809198289344320437&simpl=msg-a:r6649286450752491913 2/2
Lucia Mason <[e-mail]>
5 New 10-year reviews
1 message
Alan Humpherys <[e-mail]>Thu, Jun 13, 2024 at 8:08 AM
To: Lucia Mason <[e-mail]>
Lucia,
Here are 5 more 10-year reviews. They were initially started by another engineer, so the projects are created with some work done already. Please let me know
what questions you have.
Project #1: 12188-0006
Old AO: DAQE-AN2188004-05
Peer: EQ
Project #2: 12101-0007
Old AO: DAQE-493-01
Peer: Tim
Site #3: 10520-0004
Old AO: DAQE-1041-93
Peer: Dylan
Site #4: 10954-0002
Old AO: DAQE-251-93
Peer: Christine
Site #5: 10017-0004
Old AO: DAQE-AN0100170001-09
Peer: Tim
Thanks,
Alan
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
7/25/24, 12:41 PM State of Utah Mail - 5 New 10-year reviews
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801755276052051181&simpl=msg-f:1801755276052051181 1/2
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
7/25/24, 12:41 PM State of Utah Mail - 5 New 10-year reviews
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801755276052051181&simpl=msg-f:1801755276052051181 2/2
Lucia Mason <[e-mail]>
Periodic Permit Review (Utah Division of Air Quality)
4 messages
Lucia Mason <[e-mail]>Wed, Jul 10, 2024 at 12:32 PM
To: [e-mail]
Hi Robert,
The Utah Division of Air Quality is conducting a 10- Year Review of TCR Composites Inc.- Defense Depot Ogden and the Approval Order (AO)
associated with it (DAQE-493-01).
I'm reaching out to you because you are the listed contact from our most recent compliance documentation (March 2024). The original AO was
issued in 2001 and had outdated contact information.
Our 10-year review process will primarily update the formatting and language of the AO to make it similar to modern permits. The permit
requirements will stay the same unless federal laws have changed since the AO was issued. If this is the case, requirements in the AO may be
subject to change. Your company will NOT be charged for this project.
To get started with this process please confirm, update or add as much of the following information as possible:
Site Name: TCR Composites Inc.- Defense Depot Ogden
Site UTM Coordinates: 417,000 m Easting, 4,568,400 m Northing
Source Address/Contact:
Physical Address: Building 1 B, 219 North. 530 West. Ogden, UT 84405
Billing Address: Building 1 B, 219 North. 530 West. Ogden, UT 84405
Work Fax Number: provide if available
Work Phone Number: missing
Email: provide if available
Company Address/Contact:
Physical Address: 219 North 530 West, Ogden, UT 84404
Mailing Address: same as physical address
Work Fax Number: provide if available
Work Phone Number: missing
7/25/24, 12:40 PM State of Utah Mail - Periodic Permit Review (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7264125905390451988&simpl=msg-a:r-7125617151016134108&simpl=msg-a:r2469325209715284973&sim…1/5
Email: provide if available
Relevant Individuals:
Primary Approval Order Contact:
Name: Tom Elegante
Physical Address: 219 North 530 West
Work Fax Number: provide if available
Work Phone Number: [phone]
Email: missing
Billing Contact:
Name: Tom Elegante
Physical Address: 219 North 530 West
Work Fax Number: provide if available
Work Phone Number: [phone]
Email: missing
Please let me know if you have any questions. Thanks for your time.
Best regards,
Lucia
Lucia Mason <[e-mail]>Wed, Jul 24, 2024 at 12:59 PM
To: [e-mail]
Hi Robert,
I just want to confirm this is a good email address. If you're still with TCR composites and received this email let me know. If you know of a better environmental
contact, please direct me their way.
Thanks!
Lucia
[Quoted text hidden]
Robert Eyre <[e-mail]>Wed, Jul 24, 2024 at 1:58 PM
To: Lucia Mason <[e-mail]>
7/25/24, 12:40 PM State of Utah Mail - Periodic Permit Review (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7264125905390451988&simpl=msg-a:r-7125617151016134108&simpl=msg-a:r2469325209715284973&sim…2/5
Lucia,

I apologize for not seeing your initial email; I must have mistaken it for spam, as our email security system was allowing a significant amount at that time.

I am still with TCR, and am your best option for a contact point; though there are some updates I’ll need to make for you, that I’ve highlighted below…

Site Name: TCR Composites Inc.
Site UTM Coordinates: 417,000 m Easting, 4,568,400 m Northing

Source Address/Contact:
· Physical Address: 219 North. 530 West. Ogden, UT 84404
· Billing Address: 219 North. 530 West. Ogden, UT 84404
· Work Fax Number: NA (email)
· Work Phone Number: [phone]
· Email: [e-mail]

Company Address/Contact:
· Physical Address: 219 North 530 West, Ogden, UT 84404
· Mailing Address: same as physical address
· Work Fax Number: NA
· Work Phone Number: Main [phone]
· Email: [e-mail]

Relevant Individuals:
· Primary Approval Order Contact:
Name:
7/25/24, 12:40 PM State of Utah Mail - Periodic Permit Review (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7264125905390451988&simpl=msg-a:r-7125617151016134108&simpl=msg-a:r2469325209715284973&sim…3/5
Scott Lindsay
Physical Address: 219 North 530 West
Ogden, UT 84404
Work Fax Number:
NA
Work Phone Number:
[phone]
Email:
[e-mail]

Billing Contact:
o Name: Jolene Cheshire
o Physical Address: 219 North 530 West Ogden, UT 84404
o Work Fax Number: NA
o Work Phone Number: [phone]
o Email: [e-mail]

Robert Eyre
Production Manager
219 North 530 West, Ogden, UT 84404
t: [phone]
[e-mail]
www.tcrcomposites.com
CONFIDENTIALITY NOTICE: This e-mail is intended solely for use of the individual or entity to which it is addressed and may containinformation that is proprietary, privileged and exempt from disclosure under applicable law. If the reader is not the intended recipient or agent
responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of thiscommunication is strictly prohibited. This communication may also contain data subject to U.S. export laws. If so, that data subject to the
International Traffic in Arms Regulation cannot be disseminated, distributed or copied to foreign nationals, residing in the U.S. or abroad,
7/25/24, 12:40 PM State of Utah Mail - Periodic Permit Review (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7264125905390451988&simpl=msg-a:r-7125617151016134108&simpl=msg-a:r2469325209715284973&sim…4/5
without the approval of the U.S. Department of State. If you have received this communication in error, please notify the sender by reply e-mail
and destroy the e-mail message and any physical copies made of the communication.
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
o Name: Tom Elegante
o Physical Address: 219 North 530 West
o Work Fax Number: provide if available
o Work Phone Number: [phone]
o Email: missing

Please let me know if you have any questions. Thanks for your time.

Best regards,

Lucia

This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report this email as spam.

Lucia Mason <[e-mail]>Thu, Jul 25, 2024 at 12:13 PM
To: Robert Eyre <[e-mail]>
Thanks!
[Quoted text hidden]
7/25/24, 12:40 PM State of Utah Mail - Periodic Permit Review (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7264125905390451988&simpl=msg-a:r-7125617151016134108&simpl=msg-a:r2469325209715284973&sim…5/5
TCR COMPOSITES
219 North 530 West | Ogden, UT 84404 USA
phone: [phone] | fax: [phone] | email: [e-mail]

www.tcrcomposites.com
Date: August 14, 2024
Referencing: UDAQ Approval Order: DAQE-493-01
Recipient: Lucia Mason ([e-mail] )
@ The Utah Division of Air Quality

Document Scope
Provide a summary of operations at TCR Composites Inc. to the Utah Division of Air Quality
(UDAQ) that includes critical equipment, waste disposal/recycling, and the ovens utilized in
standard processing for the purpose of the UDAQ’s 10-year permit review process that
primarily focuses on updating the formatting and language of the Approval Order (AO) to make it
similar to modern permits, a review of the permit requirements relative to the most recent
applicable federal laws, and ensuring TCR Composites Inc.’s contact information is correctly
noted for the UDAQ AO: DAQE-493-01.

Confidentiality Notice
The information provided herein is intended solely for the use of the individual or entity to which
it is addressed and may contain information that is proprietary, privileged and exempt from
disclosure under applicable law. If the reader is not the intended recipient or agent responsible for
delivering this document to the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this document is strictly prohibited. This document may also contain
data subject to U.S. export laws. If so, that data subject to the International Traffic in Arms
Regulation cannot be disseminated, distributed or copied to foreign nationals, residing in the U.S.
or abroad, without the approval of the U.S. Department of State. If you have received this
document in error, please notify the sender (an agent of TCR Composites Inc.) by replying via the
medium through which this document was received and destroy this document and any physical
copies made of this document.

Definitions
 UDAQ: Utah Division of Air Quality
 AO: Approval Order
 Thermoset epoxy resin: A polymer that cures into a rigid, durable structure through an
irreversible process that can’t be reheated or reshaped
 ISO 9001:2015 certified: A worldwide standard that demonstrates an organization’s ability to
meet the requirements of a Quality Management System (QMS)
 Advanced-composite materials: Engineered materials made by combining two or more
materials with different physical or chemical properties, such as a reinforcement and a resin
 Prepreg composite material: Material made by pre-impregnating a reinforcing fiber or fabric
with a resin or matrix material
 UAC: Utah Administrative Code
 VOC (Volatile Organic Compounds): A group of chemicals that can be vaporized into the air
or dissolved in water
TCR COMPOSITES
219 North 530 West | Ogden, UT 84404 USA
phone: [phone] | fax: [phone] | email: [e-mail]

www.tcrcomposites.com
TCR Composites Inc. Overview
TCR Composites Inc. is an ISO 9001:2015 certified advanced-composite materials-manufacturer
that specializes in thermoset epoxy-resin development and custom pre-impregnated (prepreg)
composite materials for a variety of industries that include aerospace, automotive, industrial, and
marine.

Critical Equipment
1. Facility
a. Temperature control (HVAC)
i. Processing, administrative, storage areas
b. Utilities
i. Power, gas, water, sewage
c. Receiving/shipping
i. On-loading/off-loading semi-trucks
d. Services
i. Internet/telecommunications services
ii. Fire suppression system services
iii. Common-waste disposal services
iv. Hazardous-waste services
1. Non-hazardous liquids
2. Flammable liquids
v. Paper/aluminum/plastic/electronics/steel/pallet recycling services
e. Exhaust/Make-Up Air (MAU) systems
i. Push/pull exhaust/MAU systems designed and engineered for all proprietary
impregnation-machines for use during cleaning practices, using the 50:50
cleaning solvent blend of Methyl Ethyl Ketone (MEK) and acetone
1. TCR’s 50:50 cleaning-solvent blend contains 3.347-LBS/gal total
VOC’s
a. Note: The VOC limits noted in UAC R307-304-5, under the
“Solvent Cleaning Category” of “Advanced composites
manufacturing” is 6.7-LBS/gal
ii. TCR currently holds the UDAQ AO: DAQE-493-01
1. MEK (VOC) tracking method: 12-month rolling average
a. AO: Maximum 6.6 ton per rolling 12-month period
i. Current (08-14-24) 12-month rolling average: 1.807
tons
b. Purchased MEK qty / MEK disposal qty differential = Loss
qty
2. Material-handling equipment
3. Compressed-air equipment
4. Lab/testing instruments and equipment
5. Liquid/solids mixing equipment
6. Proprietary impregnation equipment
7. Refrigeration/freezer equipment
TCR COMPOSITES
219 North 530 West | Ogden, UT 84404 USA
phone: [phone] | fax: [phone] | email: [e-mail]

www.tcrcomposites.com
8. Temperature-controlled staging and curing equipment
a. Ovens (gas and electric)
b. Note: The two staging ovens mentioned in TCR Composite Inc.’s initial UDAQ AO
request; operations summary, and specifically noted in Lucia Mason’s email
delivered on 08-12-24 (2ea. -gas fired- staging ovens rated at 400,000 BTUs/hr.), are
no longer used in TCR’s standard operation. These ovens have been replaced by 1ea.
staging-enclosure utilizing 2ea. 32KW 460V/3Ph 16”x16” electric duct-heating
elements ducted in series
9. Industrial maintenance tools and equipment

Summary of Operations
1. Roving or woven manmade fibers (carbon, glass, aramid) are purchased from an approved list
of suppliers
2. TCR manufactures customized two-part thermoset epoxy-resin systems
3. TCR impregnates supplied manmade fiber/fiber-products with customer-specified resin
systems (determined by customer-defined mechanical-properties and curing-profiles) at
customer-specified resin-content percentages.
4. Following the manufacturing processes, all impregnation equipment is cleaned with a 50:50
cleaning-solvent blend of MEK and acetone
5. TCR offers testing services for all composite and neat-resin materials manufactured at TCR,
per ASTM standards/customer specifications
6. After impregnation, the prepreg is passed through a process that varies in temperature and
time based on the resin system
7. All prepreg must “pass” all TCR inspection processes, prior to product acceptance/shipment
8. Prepreg is then shipped around the world for use in advanced-composite products

Contact Information
 Site name: TCR Composites Inc.
 Site UTM coordinates: 417,000 m Easting, 4,568,400 m Northing
 Source address/contact
o Physical address: 219 North 530 West Ogden, UT 84404
o Billing address: same as physical address
o Work fax number: NA (email)
o Work phone number: [phone]
o Email: [e-mail]
 Company address/contact
o Physical address: 219 North 530 West Ogden, UT 84404
o Mailing address: same as physical address
o Work fax number: NA (email)
o Work phone number: [phone]
o Email: [e-mail]
 Relevant individual
o Primary AO contact
TCR COMPOSITES
219 North 530 West | Ogden, UT 84404 USA
phone: [phone] | fax: [phone] | email: [e-mail]

www.tcrcomposites.com
 Name: Scott Lindsay
 Physical address: 219 North 530 West Ogden, UT 84404
 Work fax number: NA (email)
 Work phone number: [phone]
 Email: [e-mail]
 Billing Contact
o Name: Jolene Cheshire
o Physical address: 219 North 530 West Ogden, UT 84404
o Work fax number: NA (email)
o Work phone number: [phone]
o Email: [e-mail]