HomeMy WebLinkAboutDAQ-2025-000003
DAQE-AN104860011-24
{{$d1 }}
Thomas Allen
L3Harris EDO Western Corporation
2645 South 300 West
South Salt Lake City, UT 84115
thomas.allen@l3harris.com
Dear Mr. Allen:
Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN104860010-15 to
Replace the Ultrasonic Vapor Degreaser
Project Number: N104860011
The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on March 20,
2024. L3Harris EDO Western Corporation must comply with the requirements of this AO, all applicable
state requirements (R307), and Federal Standards.
The project engineer for this action is Mr. Enqiang He, who can be contacted at (801) 556-1580 or
ehe@utah.gov. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter.
Sincerely,
{{$s }}
Bryce C. Bird
Director
BCB:EH:jg
cc: Salt Lake County Health Department
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
December 5, 2024
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
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APPROVAL ORDER
DAQE-AN104860011-24
Administrative Amendment to Approval Order
DAQE-AN104860010-15 to Replace the
Ultrasonic Vapor Degreaser
Prepared By
Mr. Enqiang He, Engineer
(801) 556-1580
ehe@utah.gov
Issued to
L3Harris EDO Western Corporation
Issued On
{{$d2 }}
Issued By
{{$s }}
Bryce C. Bird
Director
Division of Air Quality
December 5, 2024
TABLE OF CONTENTS
TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12
DAQE-AN104860011-24
Page 3
GENERAL INFORMATION
CONTACT/LOCATION INFORMATION
Owner Name Source Name
L3Harris EDO Western Corporation L3Harris EDO Western Corporation
Mailing Address Physical Address
2645 South 300 West 2645 South 300 West
South Salt Lake City, UT 84115 South Salt Lake City, UT 84115
Source Contact UTM Coordinates
Name: Thomas Allen 424,080 m Easting
Phone: (801) 461-9377 4,507,350 m Northing
Email: thomas.allen@l3harris.com Datum NAD83
UTM Zone 12
SIC code 3679 (Electronic Components, NEC)
SOURCE INFORMATION
General Description
L3Harris EDO Western Corporation (L3Harris EDO), formerly EDO Corporation/Electro Acoustics
Division, operates an electronic equipment manufacturing plant in Salt Lake County. The equipment and
processes include storage pressing, wastewater treatment, firing, grinding, electrodes, electric kilns,
poling, electro-mechanical assembly, engineering/ceramic, and exterior areas. L3Harris EDO also
operates labs that include a clean room, a testing and coating room, LWAA/ovens, a spray booth, IT,
exterior processes, and miscellaneous exhaust hoods.
NSR Classification
Administrative Amendment
Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B
Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN104860011-24
Page 4
Project Description
The source has proposed to replace the ultrasonic vapor degreaser listed under II.A.10 in the AO
DAQE-AN104860010-15 with two (2) small vapor degreasers. Emissions from the new degreasers will
vent through the same existing ventilation system to the atmosphere. This replacement will not increase
the potential to emit any air pollutant or cause emissions of any new air pollutant. Therefore, the
replacement meets the applicability listed in R307-401-12, Reduction in Air Pollutants. This
administrative amendment will update the AO to include the two (2) small vapor degreasers.
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)
CO2 Equivalent 0 1598.00
Carbon Monoxide 0 1.25
Nitrogen Oxides 0 2.00
Particulate Matter - PM10 0 0.03
Particulate Matter - PM2.5 0 0.03
Sulfur Dioxide 0 0.05
Volatile Organic Compounds 0 6.50
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
4,4-Methylene Bis(2-Chloroaniline) (CAS #101144) 0 1600
Chlorine (CAS #7782505) 0 6000
Generic HAPs (CAS #GHAPS) 0 200
Methylene Chloride (Dichloromethane) (CAS #75092) 0 3200
Toluene (CAS #108883) 0 4000
Change (TPY) Total (TPY)
Total HAPs 0 7.50
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]
DAQE-AN104860011-24
Page 5
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]
SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Integrated Mission Systems Manufacturer of electro-acoustic equipment
II.A.2 Building 1 areas include the following: Powder Prep and Storage Area, Pressing Area, Wastewater Treatment Area, Firing Area, Grinding Area, Electrode Area, Electric Kilns, Poling Area, Electro-Mechanical Assembly Area, Engineering/Ceramic Area, and Exterior Area II.A.3 Powder Prep. and Storage Area Kiln 16, natural gas-fired, rated less than 4.8 MMBtu, vented to the atmosphere, installed in 1994 Kiln C-1, electric, vented through interior baghouse SFC64-4 Kiln C-2, electric, vented through interior baghouse SFC64-4 Kiln, calcining, electric, vented through interior baghouse SFC64-4 Jaw crusher, vented through interior baghouse SFC64-4
II.A.4 Pressing Area Small Spray Dryer, vented through baghouse SFC32-4 Large spray dryer, vented through baghouse SFC32-4 Six (6) hydraulic presses, vented through SFC64-4
DAQE-AN104860011-24
Page 6
II.A.5 Wastewater Treatment Area Cartridge baghouse, Model #SFC64-4 Manufactured by United Air Specialists Air to cloth ratio: 1.23:1 Air flow rate: 20,000 ACFM Installed: 2011 Cartridge baghouse, model #SFC 32-4 Manufacturer: United Air Specialists Air to cloth ratio: 2.8:1 Air flow rate: 23,000 ACFM II.A.6 Firing Area, all vented through baghouse SFC32-4 Kiln E-25, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1991
Kiln E-24, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1991 Kiln E-23, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1970
Kiln E-17, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1970
22 Electric kilns, designated 10-15, 19-22, Lab 1-4, listed for informational purposes only.
II.A.7 Grinding Area, Particulate Wet Collectors Four (4) particulate wet collectors, manufactured by Farr, model #TM-33 Located on the roof.
II.A.8 Electroding (Silvering) Area, Spray Booth
Spray booth, manufactured by EDO Silvering Booth, which uses water-based/toluene based solvents
Five (5) Electroding kilns (electric), manufactured by Blue M, vented to atmosphere
Three (3) Tunnel kilns (electric), vented to atmosphere Six (6) Silvering kilns (electric), S3 - S8, vented to atmosphere
II.A.9 Electric Kilns Five (5) electroding kilns vented to atmosphere. Manufactured by Blue M Listed for informational purposes only.
II.A.10 Poling Area, Particulate Wet (mist) Three (3) wet particulate (mist) collectors manufactured by Farr, model #TM-33, vented to
atmosphere, mounted on the roof
Two (2) ultrasonic vapor degreasers, 15 gallons of solvent capacity each - new equipment
II.A.11 Electro-Mechanical Assembly Area Four (4) Drying Ovens, electric-powered, manufacturers and models: VWR 1350FD, Despatch LFD2-24-3, Blue M OV-490A-2, Tenney Bench Master - model #14* Aqueous Circuit Board Washing System, electric-powered, manufactured by ECD, model #9300, vented to the atmosphere* *Listed for informational purposes only
II.A.12 Engineering/Ceramics Area
One (1) emergency diesel-fired generator rated at 130 kW, manufactured by Caterpillar, model
#3304 SR-4, installed in 1994 (estimate)
II.A.13 Exterior Area (East) High Temperature Nomex Filter Baghouse, manufactured by Dalamatic Dust Collector, model #DLM7/8/10 air to cloth ratio - 5:1 and air flow rate - 31,070 ACFM Drum crusher, manufactured by RAM Pactor The engine is Kohler 18 hp gasoline-powered engine. It is used occasionally for site maintenance.
DAQE-AN104860011-24
Page 7
II.A.14 Building 2 areas include the following: Acoustic Engineering Lab, Clean Room, Testing and Coating Room, LWAA/Ovens, LWAA/Ovens and Spray Booth, IT and Exterior Area (East) II.A.15 Acoustic Engineering Lab
Two (2) Blue M ovens, electric-powered, vented to atmosphere Listed for informational purposes only.
II.A.16 Clean Room One (1) VWR electric oven, vented to atmosphere Listed for informational purposes only.
II.A.17 Testing and Coating Room One (1) VWR and one Blue M electric oven, vented to atmosphere Listed for informational purposes only.
II.A.18 LWAA/Ovens Spray Booth, manufactured by EDO, vented to atmosphere Curing ovens #1 and #2, manufactured by Lanly, model #0803048; #3 and #4, manufactured by Despatch Oven Co., model #S-100; #5, #6, and #7, manufactured by Wisconson, model #SWN-58-6E. All ovens electric-power and vented to atmosphere Drying room, recirculates (not vented to atmosphere), custom built Blue M oven, electric-powered, vented to atmosphere *All listed for informational purposes only.
II.A.19 LWAA/Ovens and Spray Booth Two (2) curing electrically powered ovens, one manufactured by Wisconsin and the other
manufactured by Grieve;
Two (2) drying electric-powered ovens, one manufactured by VWR and the other manufactured by Blue;
One (1) spray booth manufactured by Paashe
Except for the spray booth, all other equipment listed for informational purposes only.
II.A.20 IT and Exterior Area (East) Two (2) emergency generators manufactured by Kohler. Smaller one powered by natural gas and rated at 15 kW The second one powered by diesel fuel and rated at 150 kW
II.A.21 Miscellaneous Exhaust Hoods Miscellaneous hoods located throughout the facility in both buildings 1 & 2
DAQE-AN104860011-24
Page 8
SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements and Limitations
II.B.1.a The owner/operator shall not allow visible emissions from the following points to exceed the
following values:
A. 10% opacity for baghouses and wet collectors
B. 10% opacity for natural gas-operated equipment
C. 20% opacity for diesel engine exhausts and all other points.
[R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method. [R307-401-8]
II.B.1.b The owner/operator shall not consume more than 26,250 decatherms of natural gas per rolling
12-month period. [R307-401-8]
II.B.1.b.1 To comply with the natural gas consumption limit, the owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months B. Determine the natural gas consumption by monthly gas bills from a utility company C. Keep the natural gas consumption records for all periods when the plant is in operation. [R307-401-8]
II.B.1.c The owner/operator shall use diesel fuel and natural gas as combustion fuels. [R307-401-8]
II.B.2 VOC & HAP Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (the ovens,
spray booths, and associated operations) on site:
6.50 tons per rolling 12-month period of VOCs
3.00 tons per rolling 12-month period of chlorine
2.00 tons per rolling 12-month period of toluene
0.80 tons per rolling 12-month period of methylene bis 2-chloroaniline
1.60 tons per rolling 12-month period of methylene chloride
6.00 tons per rolling 12-month period of lead.
[R307-401-8]
DAQE-AN104860011-24
Page 9
II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8]
II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs.
[R307-401-8]
II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per 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 comply with the applicable requirements in R307-335. [R307-335]
II.B.3 Baghouse Conditions
II.B.3.a The owner/operator shall operate baghouses to control particulate emissions from all low- and
high-temperature operations. The low-temperature operations include batching, milling, and spray drying; the high-temperature operations include calciner kilns, Bisque kilns, and high-fire
kilns. All exhaust streams from these operations shall be vented to their designated baghouses
before being vented to the atmosphere. [R307-401-8]
II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across each of the baghouses. [R307-401-8]
II.B.3.b.1 The pressure gauges shall be located such that an inspector/operator can safely read the
indicators at any time. [R307-401-8]
II.B.3.b.2 The pressure gauges shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8]
II.B.3.c During operation of the baghouses, the owner/operator shall maintain the static pressure
differential within the range recommended by the manufacturer for normal operations.
[R307-401-8]
DAQE-AN104860011-24
Page 10
II.B.3.c.1 The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] II.B.3.c.2 The owner/operator shall maintain the following records of the static pressure differential:
A. Unit identification B. Manufacturer recommended static pressure differential for the unit
C. Daily static pressure differential readings
D. Date of reading. [R307-401-8]
II.B.3.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the pressure gauges. [R307-401-8]
II.B.3.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8]
II.B.4 Emergency Engine Requirements
II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.4.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 130-kW and 150-kW emergency generator engines and natural gas in the 15-kW emergency generator engine. [R307-401-8]
II.B.4.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
DAQE-AN104860011-24
Page 11
PERMIT HISTORY
This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN104860010-15 dated February 5, 2015 Incorporates NOI dated March 20, 2024 Incorporates Additional information dated April 2, 2024 Incorporates Name Change dated April 12, 2024 Incorporates Additional Information dated August 28, 2024
DAQE-AN104860011-24
Page 12
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
Department of
Environmental Quality
KimbeilyD Shelley
Executive Dn ectoi
State of Utah
SPENCERJ COX
Governor
DIVISION OF AIR QUAL11Y
Bryce C Bird
Dn ectoi
DEIDRE HENDERSON
Lieutenant Goveinoi
RN104860011
Novembei 19, 2024
Thomas Allen
L3Harris EDO Western Corpoiation
2645 South 300 West
South Salt Lake City, UT 84115
tomas.allen@13harris com
Dear Thomas Allen,
Re. Engineei Review
Admimstiative amendment to Approval Order DAQE-AN104860010-15 to Replace the
Ultiasonic Vapor Degreaser
Project Number: N104860011
The DAQ requests a company repiesentative review and sign the attached Engineei Review (ER) This
ER identifies all applicable elements of the New Souice Review (NSR) peimitting piogram. L3Harris
EDO Western Corporation should complete this review within 10 business days of receipt
L3 Harris EDO Western Corporation should contact Mr. Enqiang He at (801) 556-1580 if there aie
questions or concerns with the review of the diaft permit conditions Upon resolution of your concerns,
please email Mr. Enqiang He at ehe@utah.gov the signed cover letter Upon receipt of the signed covei
letter, the DAQ will piepaie an Approval Ordei (AO) for signatuie by the DAQ Diiector
If L3Hams EDO Western Corporation does not respond to this letter within 10 business days, the pioject
will move foiward without source concunence. If L3Hairis EDO Western Corporation has concerns that
cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order piolubiting
construction.
(Signature & Date)
195 Noilh 1950 West • Salt Lake City, U T
Mailing Addiess PO Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Tax (SOI) 536-4099 -TDD (801) 903-3978
M'U'ip deq Utah gov
Punted on 100% recycled papei
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
Pioject Numbei
Owner Name
Mailing Addiess
N104860011
LSHarris EDO Westein Corpoiation
2645 South 300 West
South Salt Lake City, UT 84115
Source Name
Souice Location
LSHairis EDO Western Corpoiation
2645 South 300 West
South Salt Lake City, UT 84115
UTM Projection
UTM Datum
UTM Zone
SIC Code
424,080 m Easting, 4,507,350 m Northing
NAD83
UTM Zone 12
3679 (Electiomc Components, NEC)
Source Contact
Phone Numbei
Email
Thomas Allen
(801)461-9377
tomas.allen@13harris.com
Billing Contact
Phone Numbei
Email
Thomas Allen
(801)461-9377
tomas.allen@13hairis.com
Pioject Engineei
Phone Number
Email
Mr Enqiang He, Engineei
(801)556-1580
ehe@utah gov
Notice of Intent (NOI) Submitted
Date of Accepted Application
Maich 20, 2024
October 2, 2024
Engineei Review N104860011 L3Hams EDO Westein Coipoiation
Novembei 19,2024
Page 1
SOURCE DESCRIPTION
General Description
L3Hairis EDO (LSHairis EDO) Western Corporation, foimerly EDO Coipoiation/Electio
Acoustics Division, opeiates an electronic equipment manufactuie plant m Salt Lake County.
The equipment and processes include storage piessing, wastewatei tieatment, filing, gihiding,
electiode, electnc kilns, poling, electro-mechanical assembly, engineenng/ceramic, and extenoi
areas LSHains EDO also opeiates labs that include a clean loom, a testing and coating 100m,
LWAA/ovens, LWAA/ovens spray booth, IT, extenoi piocesses, and miscellaneous exhaust
hoods.
NSR Classification:
Administrative Amendment
Source Classification
Located in Noithern Wasatch Fiont O^ NAA, Salt Lake City UT PM2 5 NAA, Salt Lake County
S02 NAA
Salt Lake County
Ans Souice Size: B
Applicable Federal Standaids
NSPS (Part 60), A' Geneial Piovisions
NSPS (Part 60), HIP Standards of Peifoimance for Stationaiy Compiession Ignition Internal
Combustion Engines
MACT (Pait 63), A. Geneial Provisions
MACT (Part 63), ZZZZ- National Emissions Standaids for Hazardous An Pollutants for
Stationary Reciprocating Internal Combustion Engines
Project Proposal
Administiative amendment to Appioval Older DAQE-AN104860010-15 to Replace the
Ultrasonic Vapor Degieaser
Project Description
The souice has proposed to replace the ultrasonic vapor degieasei listed under II A 10 in the AO
DAQE-AN 104860010-15 with two (2) small vapor degreaseis. Emissions from the new
degreaseis will vent thiough the same existing ventilation system to the atmosphere This
replacement will not increase the potential to emit of any air pollutant 01 cause emissions of any
new air pollutant. Theiefore, the leplacement meets the applicability listed in R307-401-12,
Reduction in Air Pollutants This administiative amendment will update the AO to include the
two (2) small vapor degreasers.
EMISSION IMPACT ANALYSIS
This administiative amendment is for a reduction in air pollutants; there will be no emission increases.
Theiefoie, modeling is not lequired at this time [Last updated October 2, 2024]
Engmeei Review N104860011 L3Hams EDO Western Coipoiation
Novembei 19,2024
Page 2
SUMMARY OF EMISSIONS
The emissions listed below aie an estimate of the total potential emissions from the somce. Some
rounding of emissions is possible
Criteria Pollutant Change (TPY)Total (TPY)
CO2 Equivalent 0 1598.00
Carbon Monoxide 0 1 25
Nitrogen Oxides 0 2 00
Paiticulate Mattel - PM10 0 0.03
Paiticulate Matter - PM25 0 0 03
Sulfur Dioxide 0 0.05
Volatile Organic Compounds 0 6 50
Hazardous Air Pollutant Change (Ibs/yr)Total (Ibs/yr)
4,4-Methylene Bis(2-Chloioamline) (CAS #101144)0 1600
Chlorine (CAS #7782505)0 6000
Generic HAPs (CAS #GHAPS)0 200
Methylene Chloride (Dichloromethane) (CAS #75092)0 3200
Toluene (CAS #108883)0 4000
Change (TPY)Total (TPY)
Total HAPs 0 7.50
Note: Change in emissions indicates the difference between previous AO and proposed modification.
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Review of BACT for New/Modified Emission Units
1. BACT review regarding the new degreasers
This administiative amendment is foi a ieduction in air pollutants, theie will be no emission
incieases Therefoie, a BACT analysis is not requited. [Last updated Octobei 2, 2024]
SECTION I: GENERAL PROVISIONS
The intent is to issue an an quality AO authorizing the pioject with the following recommended
conditions and that failuie 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):
1.1 All definitions, terms, abbreviations, and lefeiences used in this AO conform to those used in
the UAC R307 and 40 CFR Unless noted otheiwise, references cited in these AO conditions
refer to those uiles. [R307-101]
1.2 The limits set forth in this AO shall not be exceeded without pnor appioval [R307-401]
1.3 Modifications to the equipment or processes appioved by this AO that could affect the
emissions coveied by this AO must be reviewed and approved. [R307-401-1]
1.4 All records leferenced in this AO oi in other applicable rules, which are lequued to be kept by
the owner/operator, shall be made available to the Directoi or Director's repiesentative upon
lequest, and the records shall include the two-year period prior to the date of the icquest
Unless otherwise specified in this AO or in other applicable state and federal rules, recoids
shall be kept for a minimum of two (2) yeais. [R307-401-8]
I 5 At all times, including periods of startup, shutdown, and malfunction, owneis and operators
shall, to the extent practicable, maintain and opeiate any equipment approved undei this AO,
including associated air pollution contiol equipment, in a manner consistent with good air
pollution control piactice for minimizing emissions Deteimmation of whethei acceptable
operating and maintenance piocedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoi ing results, opacity
observations, review of opeiating and maintenance procedures, and inspection of the souice.
All maintenance perfoimed on equipment authorized by this AO shall be iccoided. [R307-
401-4]
1.6 The owner/operator shall comply with UAC R307-107 Geneial Requnements: Breakdowns
[R307-107]
17 The owner/opeiatoi shall comply with UAC R307-150 Series. Emission Inventoiies [R307-
150]
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Page 4
I 8 The owner/opei atoi shall submit documentation of the status of consti notion or modification
to the Dnectoi within 18 months fiom the date of this AO. This AO may become invalid if
consti uction is not commenced within 18 months from the date of this AO or if constiuction is
discontinued foi 18 months oi moie. To ensuie piopei ciedit when notifying the Director,
send the documentation to the Dnector, attn.. NSR Section [R307-401-18]
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an aii 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.l Integrated Mission Systems
Manufacturei of electio-acoustic equipment
II.A 2 Building 1 Areas include the following:
Powder Prep and Storage Area, Pressing Area, Wastewater Treatment Area, Firing Area,
Grinding Aiea, Electiode Aiea, Electnc Kilns, Poling Area, Electro-Mechanical Assembly
Area, Engineeiing/Ceiamic Area and Extenoi Aiea
II.A.3 Powder Prep, and Storage Area
Kiln 16, natural gas-fired, rated less than 4 8 MMBtu, vented to atmosphere, installed in 1994
Kiln C-l, electric, vented through interior baghouse SFC64-4
Kiln C-2, electiic, vented through interioi baghouse SFC64-4
Kiln, calcining, electric, vented through interioi baghouse SFC64-4
Jaw crusher, vented thiough interioi baghouse SFC64-4
II.A.4 Pressing Area
Small Spray Dryer, vented through baghouse SFC32-4
Large spiay diyei, vented thiough baghouse SFC32-4
Six (6) hydraulic presses, vented through SFC64-4
II A 5 Wastewater Treatment Area
Cartndge baghouse, Model # SFC64-4
Manufactuied by United An Specialists
Air to cloth ratio' 1 23'1
Air flow rate: 20,000 ACFM
Installed. 2011
Cartndge baghouse, model #SFC 32-4
Manufacturer' United Air Specialists
Air to cloth ratio: 2 8'1
Air flow late. 23,000 ACFM
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II A 6 Firing Area, all vented through baghouse SFC32-4
Kiln E-25, natural-gas fired, mted less than 4 8 MMBtu/hi, installed m 1991
Kiln E-24, natuial-gas fired, rated less than 4 8 MMBtu/hr, installed in 1991
Kiln E-23, natural-gas filed, lated less than 4.8 MMBtu/hi, installed in 1970
Kiln E-17, natural-gas filed, rated less than 4.8 MMBtu/hr, installed in 1970
22 Electric kilns, designated 10-15, 19-22, Lab 1-4, listed for informational purposes only
II A 7 Grinding Area, Particulate Wet Collectors
Foui (4) particulate wet collectors, manufactuied by Fan, model numbei TM-33 Located on
the roof
II.A.8 Electroding (Silvering) Area, Spray Booth
Spray booth, manufactured by EDO
Silveiing Booth which uses watei based / toluene-based solvents
5 Electroding kilns (electric), manufactuied by Blue M, vented to atmosphere
3 Tunnel kilns (electric), vented to atmospheie
6 Silveiing kilns (electiic), S3 - S8, vented to atmospheie
II A 9 Electric Kilns
Five (5) electioding kilns vented to atmosphere Manufactuied by Blue M Listed foi
informational pm poses only
II.A.10 Poling Area, Particulate Wet (mist)
Three (3) wet particulate (mist) collectors manufactuied by Fair, model numbei TM-33,
vented to atmosphere, mounted on the roof
Two (2) ultrasonic vapor degieaseis, 15 gallons of solvent capacity each - new equipment
II A.ll Electro-Mechanical Assembly Area
Four (4) Drying Ovens, electric-powered, manufactuieis and models. VWR 1350FD,
Despatch LFD2-24-3, Blue M OY-490A-2, Tenney Bench Master - model # 14*
Aqueous Circuit Board Washing System, electnc-poweied, manufactuied by ECD, model #
9300, vented to the atmosphere*
*Listed foi informational pm poses only
II A.12 Engineering/Ceramics Area
One (1) emergency diesel-fired generatoi rated at 130 kW, manufactuied by Caterpillai,
model number 3304 SR-4, installed in 1994 (estimate). Please see leviewei's comment for
explanation
II. A 13 Exterior Area (East)
High TempeiatuieNomex Filter Baghouse, manufactured by Dalamatic Dust Collector, model
number DLM7/8/10. aii to cloth latio - 5.1 and air flow rate - 31,070 ACFM
Dium crushei, manufactured by RAM Factor. The engine is Kohler 18 hp gasoline-powered
engine. It is used occasionally for site maintenance.
II A.14 Building 2 areas include the following:
Acoustic Engineering Lab, Clean Room, Testing and Coating Room, LWAA/Ovens,
LWAA/Ovens and Spray Booth, IT and Extenoi Aiea (East)
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II .A 15 Acoustic Engineering Lab
Two (2) Blue M ovens, electi ic-powered, vented to atmosphere Listed for informational
pm poses only
II A.16 Clean Room
One VWR electric oven, vented to atmosphere. Listed for informational pm poses only.
II.A.17 Testing and Coating Room
One VWR and one Blue M electi ic ovens, vented to atmosphere Listed foi informational
pm poses only.
II.A.18 LWAA/Ovens
Spiay Booth, manufactuied by EDO, vented to atmosphere
Curing ovens #1 and #2, manufactured by Lardy, model # 0803048; #3 and #4, manufactuied
by Despatch Oven Co , model # S-l 00; #5, #6 and #7, manufactuied by Wisconson, model #
SWN-58-6E. All ovens electric-power and vented to atmospheie
Diying room, reciiculates (not vented to atmosphere), custom built
Blue M oven, electi ic-powered, vented to atmospheie
*A11 listed for informational puiposes only
II.A.19 LWAA/Ovens and Spray Booth
Two curing electrically poweied ovens, one manufactured by Wisconsin and the othei
manufactured by Grieve;
Two drying electric-powered ovens, one manufactuied by VWR and the other manufactuied
by Blue;
One spiay booth manufactuied by Paashe
Except for the spray booth, all other equipment listed for informational puiposes only
II.A.20 IT and Exterior Area (East)
Two emeigency generators manufactured by Kohler. Smaller one powered by natural gas and
lated at 15 kW. The second one poweied by diesel fuel and rated at 150 kW.
II A 21 Miscellaneous Exhaust Hoods
Miscellaneous hoods located thioughoutthe facility in both building 1 & 2
SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authonzing 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.l Requirements and Limitations
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II.B.l.a
NEW
The owner/opeiatoi shall not allow visible emissions fiom the following points to exceed the
following values.
A. 10% opacity foi baghouses and wet collectors
B. 10% opacity for natural gas opeiated equipment
C. 20% opacity for diesel engine exhausts and all other points
[R307-401-8]
II B 1 a.l Opacity obseivations of emissions from stationaiy somces shall be conducted according to 40
CFR 60, Appendix A, Method. [R307-401-8]
II.B.l.b
NEW
The owner/operator shall not consume more than 26,250 decatherms of natuial gas per lolling
12-month penod. [R307-401-8]
II.B l.b 1
NEW
To comply with the natuial gas consumption limit, the ownei/opeiatoi shall:
A. Calculate a new 12-month total by 20th day of each month using data from the
pievious 12 months
B. Determine the natural gas consumption by monthly gas bills fiom a utility company
C. Keep the natural gas consumption iccoids for all periods when the plant is in
opeiation.
[R307-401-8]
II.B.l.c The owner/opeiator shall use diesel fuel and natuial gas as combustion-fuels. [R307-401-8]
IIB.2
NEW
VOC & HAP Requirements
II B 2 a
NEW
The ownei/operatoi shall not emit more than the following from evapoiative sources (the
ovens, spiay booths and associated operations) on site:
6.50 tons pei rolling 12-month period of VOCs
3 00 tons per rolling 12-month peiiod of chlonne
2 00 tons per rolling 12-month penod of toluene
0.80 tons per rolling 12-month period of methylene bis 2-chloroamlme
1.60 tons per lolling 12-month period of methylene chloride
6 00 tons per lolling 12-month period of lead.
[R307-401-8]
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Page8
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 ownei/opeiatoi shall use a mass-balance method to
calculate emissions fiom evaporative souices The ownei/operator may use the following
equations with applicable units to comply with the mass-balance method'
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]
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 leclaimed
from the quantities calculated above to provide the monthly total emissions of VOCs and
HAPs. [R307-401-8]
II.B.2.a.3
NEW
The owner/opeiator shall keep records each month of the following'
A. The name (as per SDS) of the VOC- and HAP-emitting matenal
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 mateiial
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 ownei/operator shall comply with the applicable lequirements in R307-335 [R307-335]
IIB.3
NEW
Baghouse Conditions
II.B.3.a
NEW
The owner/operator shall operate baghouses to control particulate emissions from all low and
high temperature operations. The low temperature operations include batching, milling, and
spray drying; the high tempeiatuie opeiations include calciner kilns, Bisque kilns, and high
fire kilns All exhaust streams fiom these opeiations shall be vented to their designated
baghouses befoie being vented to the atmosphere [R307-401-8]
II.BJ.b
NEW
The owner/operator shall install a manometei or magnehehc pressure gauge to measuie the
static pressuie diffeiential acioss each of the baghouses. [R3 07-401-8]
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Page 9
II.B 3 b 1
NEW
The piessuie gauges shall be located such that an inspector/opeiatoi can safely read the
indicators at any time [R307-401-8]
II.B.3.b.2
NEW
The piessure gauges shall measuie the static pressuie differential in 1-inch water column
increments or less [R307-401-8]
II B3 c
NEW
Dunng opeiation of the baghouses, the owner/opei ator shall maintain the static pressuie
differential within the range recommended by the manufactui er for normal operations [R307-
401-8]
II.B 3 c I
NEW
The owner/operator shall record the static pressuie differential at least once per opeiating day
while the baghouse is operating [R307-401-8]
II.B.3.C.2
NEW
The owner/opeiatoi shall maintain the following recoids of the static piessure diffeientiah
A. Unit identification
B Manufactui er recommended static pressure diffeiential foi the unit
C. Daily static piessuie diffeiential readings
D. Date of reading.
[R307-401-8]
II.B.3 d
NEW
At least once every 12 months, the owner/operatoi shall calibrate the piessuie gauges in
accoidance with the manufacturei's instructions or replace the piessure gauges. [R307-401-8]
II B 3.d 1
NEW
The owner/operator shall maintain records of the piessure gauge calibiations and
replacements. [R307-401-8]
II B 4
NEW
Emergency Engine Requirements
II.B.4 a
NEW
The owner/operator shall not operate each emeigency engine on site foi moie than 100 houis
per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engines duiing emergencies. [40 CFR 63 Subpait ZZZZ, R307-401-8]
II.B 4 a 1
NEW
To determine compliance with a rolling 12-month total, the owner/opeiatoi shall calculate a
new 12-month total by the 20th day of each month using data from the pievious 12 months.
Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following.
A. The date the emeigency engine was used
B. The duiation of operation in houis
C. The leason for the emergency engine usage
[R307-401-8, 40 CFR 63 Subpart ZZZZ]
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II B.4.a.2
NEW
To deteimine the duiation of operation, the ownei/operator shall install a non-iesettable hour
metei foi each emergency engine [R307-401-8, 40 CFR 63 Subpait ZZZZ]
II B.4.b
NEW
The owner/operatoi shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in the 130-kW and 150-kW emergency geneiator engines, and natural gas in the 15-kW
emeigency geneiatoi engine. [R307-401-8]
II BAb.l
NEW
The owner/operator shall only combust diesel fuel that meets the definition of ultia-low sulfur
diesel (ULSD), which has a sulfui content of 15 ppm or less. [R307-401-8]
II.B.4.b.2
NEW
To demonstrate compliance with the ULSD fuel lequirement, the ownei/opeiator shall
maintain lecords of diesel fuel purchase invoices oi obtain certification of sulfur content from
the diesel fuel supplier. The diesel fuel pm chase invoices shall indicate that the diesel fuel
meets the ULSD lequiiements. [R307-401-8]
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Page 11
PERMIT HISTORY
When issued, the approval older shall supersede (if a modification) 01 will be based on the
following documents'
Supeisedes
Incorporates
Incorporates
Incorporates
Incorpoiates
AO DAQE-AN104860010 dated Febiuaiy 5, 2015
A Replacement Request dated March 19, 2024
Additional information dated April 2, 2024
Name Change dated Apiil 12, 2024
Additional Infoimation dated August 28, 2024
REVIEWER COMMENTS
1 Comment regarding Reduction in Air Pollutants:
The source has pioposed to leplace the ultiasonic vapoi degieasei listed undei II A 10 in the AO DAQE-
AN 104860010-15 with two (2) small vapoi degieaseis Emissions horn the new degieaseis will vent thiough
the same existing ventilation system to the atmospheie This replacement will not mciease the potential to emit
of any an pollutant oi cause emissions of any new ail pollutant Theiefoie, the leplacement meets the
applicability listed m R307-401-12, Reduction in An Pollutants This admmistiative amendment will update
the AO to include the two (2) small vapoi degreaseis.
The new vapoi degreaseis aie subject to the lequirements in R307-335; therefoie, II.B.2.b is added
to this AO
[Last updated November 19, 2024]
2. Comment regarding Federal standard applicability:
The following Federal standaids were determined to apply to the emergency generator engine in the
previous review.
NSPS (Part 60), HIP Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines.
MACT (Part 63), ZZZZ' National Emissions Standards foi Flazardous Aii Pollutants foi Stationary
Reciprocating Internal Combustion Engines
[Last updated October 2, 2024]
3 Comment regarding Title V Applicability:
Title V of the 1990 Clean An Act (Title V) applies to the following.
1 Any major souice;
2 Any source subject to a standaid, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationaiy Sources;
3 Any source subject to a standaid or other requirement under Section 112 of the Act, Hazardous
Aii Pollutants; oi
4. Any Title IV affected source.
This facility is not a major source and is not a Title IV source It is subject to NSPS Subpart IIII and
MACT Subpart ZZZZ lequirements However, the Fedeial standaids specifically exempt the souice
Engineei Review N104860011 L3Hains EDO Western Coipoiation
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Page 12
from the obligation to obtain a Title V permit, provided that the souice is not lequned to obtain the
permit foi a leason other than being an aiea souice undei the Subparts IIII and ZZZZ. Theiefore,
Title V is not lequired foi the source. [Last updated Octobei 2, 2024]
Engmeei Review N104860011 L3Hams EDO Western Coipoiation
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Page 13
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
40 CFR
AO
BACT
CAA
CAAA
CDS
CEM
GEMS
CFR
CMS
CO
C02
C02e
COM
DAQ/UDAQ
DAQE
EPA
FDCP
GHG
GWP
HAP or HAPs
ITA
LB/HR
LB/YR
MACT
MMBTU
NAA
NAAQS
NESHAP
NOI
NOv
NSPS
NSR
PM10
PM25
PSD
PTE
R307
R307-401
S02
Title IV
Title V
TPY
UAC
VOC
document'
Title 40 of the Code of Fedeial Regulations
Approval Ordei
Best Available Control Technology
Clean Air Act
Clean Air Act Amendments
Classification Data System (used by EPA to classify sources by size/type)
Continuous emissions monitor
Continuous emissions monitoring system
Code of Federal Regulations
Continuous monitoring system
Cai bon monoxide
Caibon Dioxide
Carbon Dioxide Equivalent - 40 CFR Part 98, Subpait A, Table A-l
Continuous opacity monitor
Division of An Quality
This is a document tracking code for internal UDAQ use
Enviionmental Piotection Agency
Fugitive dust contiol plan
Gieenhouse Gas(es) - 40 CFR 52 21 (b)(49)(i)
Global Wanning Potential - 40 CFR Part 86 1818-12(a)
Hazardous aii pollutant(s)
Intent to Appiove
Pounds pei hour
Pounds pei yeai
Maximum Achievable Control Technology
Million British Thermal Units
Nonattainment Aiea
National Ambient Air Quality Standards
National Emission Standaids for Hazardous An Pollutants
Notice of Intent
Oxides of nitrogen
New Source Performance Standaid
New Source Review
Particulate mattei less than 10 microns in size
Particulate matter less than 2 5 microns in size
Prevention of Significant Deterioiation
Potential to Emit
Rules Senes 307
Rules Series 307 - Section 401
Sulfur dioxide
Title IV of the Clean Air Act
Title V of the Clean Air Act
Tons per year
Utah Administiative Code
Volatile organic compounds
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Page 14
DAQE-
RN104860011 November 19, 2024 Thomas Allen
L3Harris EDO Western Corporation 2645 South 300 West South Salt Lake City, UT 84115
tomas.allen@l3harris.com Dear Thomas Allen,
Re: Engineer Review: Administrative amendment to Approval Order DAQE-AN104860010-15 to Replace the Ultrasonic Vapor Degreaser Project Number: N104860011 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. L3Harris EDO Western Corporation should complete this review within 10 business days of receipt. L3Harris EDO Western Corporation should contact Mr. Enqiang He at (801) 556-1580 if there are
questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Enqiang He at ehe@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 L3Harris EDO Western Corporation does not respond to this letter within 10 business days, the project will move forward without source concurrence. If L3Harris EDO Western Corporation 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 N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
Project Number N104860011 Owner Name L3Harris EDO Western Corporation Mailing Address 2645 South 300 West
South Salt Lake City, UT 84115 Source Name L3Harris EDO Western Corporation
Source Location 2645 South 300 West South Salt Lake City, UT 84115
UTM Projection 424,080 m Easting, 4,507,350 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3679 (Electronic Components, NEC) Source Contact Thomas Allen Phone Number (801) 461-9377 Email tomas.allen@l3harris.com Billing Contact Thomas Allen Phone Number (801) 461-9377
Email tomas.allen@l3harris.com Project Engineer Mr. Enqiang He, Engineer
Phone Number (801) 556-1580 Email ehe@utah.gov
Notice of Intent (NOI) Submitted March 20, 2024 Date of Accepted Application October 2, 2024
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 2
SOURCE DESCRIPTION General Description
L3Harris EDO (L3Harris EDO) Western Corporation, formerly EDO Corporation/Electro Acoustics Division, operates an electronic equipment manufacture plant in Salt Lake County. The equipment and processes include storage pressing, wastewater treatment, firing, grinding,
electrode, electric kilns, poling, electro-mechanical assembly, engineering/ceramic, and exterior areas. L3Harris EDO also operates labs that include a clean room, a testing and coating room, LWAA/ovens, LWAA/ovens. spray booth, IT, exterior processes, and miscellaneous exhaust hoods. NSR Classification: Administrative Amendment Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA
Salt Lake County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal
Administrative amendment to Approval Order DAQE-AN104860010-15 to Replace the Ultrasonic Vapor Degreaser Project Description The source has proposed to replace the ultrasonic vapor degreaser listed under II.A.10 in the AO DAQE-AN104860010-15 with two (2) small vapor degreasers. Emissions from the new degreasers will vent through the same existing ventilation system to the atmosphere. This replacement will not increase the potential to emit of any air pollutant or cause emissions of any
new air pollutant. Therefore, the replacement meets the applicability listed in R307-401-12, Reduction in Air Pollutants. This administrative amendment will update the AO to include the two (2) small vapor degreasers.
EMISSION IMPACT ANALYSIS This administrative amendment is for a reduction in air pollutants; there will be no emission increases.
Therefore, modeling is not required at this time. [Last updated October 2, 2024]
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 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) CO2 Equivalent 0 1598.00 Carbon Monoxide 0 1.25
Nitrogen Oxides 0 2.00
Particulate Matter - PM10 0 0.03
Particulate Matter - PM2.5 0 0.03
Sulfur Dioxide 0 0.05
Volatile Organic Compounds 0 6.50 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
4,4-Methylene Bis(2-Chloroaniline) (CAS #101144) 0 1600
Chlorine (CAS #7782505) 0 6000
Generic HAPs (CAS #GHAPS) 0 200
Methylene Chloride (Dichloromethane) (CAS #75092) 0 3200
Toluene (CAS #108883) 0 4000 Change (TPY) Total (TPY) Total HAPs 0 7.50
Note: Change in emissions indicates the difference between previous AO and proposed modification.
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding the new degreasers
This administrative amendment is for a reduction in air pollutants; there will be no emission increases. Therefore, a BACT analysis is not required. [Last updated October 2, 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 N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 5
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Integrated Mission Systems Manufacturer of electro-acoustic equipment
II.A.2 Building 1 Areas include the following: Powder Prep and Storage Area, Pressing Area, Wastewater Treatment Area, Firing Area, Grinding Area, Electrode Area, Electric Kilns, Poling Area, Electro-Mechanical Assembly
Area, Engineering/Ceramic Area and Exterior Area II.A.3 Powder Prep. and Storage Area Kiln 16, natural gas-fired, rated less than 4.8 MMBtu, vented to atmosphere, installed in 1994 Kiln C-1, electric, vented through interior baghouse SFC64-4 Kiln C-2, electric, vented through interior baghouse SFC64-4 Kiln, calcining, electric, vented through interior baghouse SFC64-4
Jaw crusher, vented through interior baghouse SFC64-4
II.A.4 Pressing Area Small Spray Dryer, vented through baghouse SFC32-4 Large spray dryer, vented through baghouse SFC32-4 Six (6) hydraulic presses, vented through SFC64-4 II.A.5 Wastewater Treatment Area Cartridge baghouse, Model # SFC64-4
Manufactured by United Air Specialists Air to cloth ratio:1.23:1 Air flow rate: 20,000 ACFM Installed: 2011 Cartridge baghouse, model #SFC 32-4 Manufacturer: United Air Specialists Air to cloth ratio: 2.8:1
Air flow rate: 23,000 ACFM
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 6
II.A.6 Firing Area, all vented through baghouse SFC32-4 Kiln E-25, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1991 Kiln E-24, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1991
Kiln E-23, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1970 Kiln E-17, natural-gas fired, rated less than 4.8 MMBtu/hr, installed in 1970 22 Electric kilns, designated 10-15, 19-22, Lab 1-4, listed for informational purposes only
II.A.7 Grinding Area, Particulate Wet Collectors Four (4) particulate wet collectors, manufactured by Farr, model number TM-33. Located on the roof.
II.A.8 Electroding (Silvering) Area, Spray Booth Spray booth, manufactured by EDO Silvering Booth which uses water based / toluene-based solvents 5 Electroding kilns (electric), manufactured by Blue M, vented to atmosphere 3 Tunnel kilns (electric), vented to atmosphere 6 Silvering kilns (electric), S3 - S8, vented to atmosphere
II.A.9 Electric Kilns Five (5) electroding kilns vented to atmosphere. Manufactured by Blue M. Listed for informational purposes only
II.A.10 Poling Area, Particulate Wet (mist)
Three (3) wet particulate (mist) collectors manufactured by Farr, model number TM-33, vented to atmosphere, mounted on the roof Two (2) ultrasonic vapor degreasers, 15 gallons of solvent capacity each - new equipment
II.A.11 Electro-Mechanical Assembly Area Four (4) Drying Ovens, electric-powered, manufacturers and models: VWR 1350FD, Despatch LFD2-24-3, Blue M OV-490A-2, Tenney Bench Master - model # 14* Aqueous Circuit Board Washing System, electric-powered, manufactured by ECD, model # 9300, vented to the atmosphere* *Listed for informational purposes only.
II.A.12 Engineering/Ceramics Area One (1) emergency diesel-fired generator rated at 130 kW, manufactured by Caterpillar, model number 3304 SR-4, installed in 1994 (estimate). Please see reviewer's comment for explanation. II.A.13 Exterior Area (East) High Temperature Nomex Filter Baghouse, manufactured by Dalamatic Dust Collector, model number DLM7/8/10. air to cloth ratio - 5:1 and air flow rate - 31,070 ACFM Drum crusher, manufactured by RAM Pactor. The engine is Kohler 18 hp gasoline-powered engine. It is used occasionally for site maintenance.
II.A.14 Building 2 areas include the following:
Acoustic Engineering Lab, Clean Room, Testing and Coating Room, LWAA/Ovens, LWAA/Ovens and Spray Booth, IT and Exterior Area (East).
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 7
II.A.15 Acoustic Engineering Lab Two (2) Blue M ovens, electric-powered, vented to atmosphere. Listed for informational purposes only
II.A.16 Clean Room One VWR electric oven, vented to atmosphere. Listed for informational purposes only. II.A.17 Testing and Coating Room One VWR and one Blue M electric ovens, vented to atmosphere. Listed for informational
purposes only. II.A.18 LWAA/Ovens Spray Booth, manufactured by EDO, vented to atmosphere Curing ovens #1 and #2, manufactured by Lanly, model # 0803048; #3 and #4, manufactured by Despatch Oven Co., model # S-100; #5, #6 and #7, manufactured by Wisconson, model #
SWN-58-6E. All ovens electric-power and vented to atmosphere. Drying room, recirculates (not vented to atmosphere), custom built Blue M oven, electric-powered, vented to atmosphere *All listed for informational purposes only II.A.19 LWAA/Ovens and Spray Booth Two curing electrically powered ovens, one manufactured by Wisconsin and the other
manufactured by Grieve; Two drying electric-powered ovens, one manufactured by VWR and the other manufactured by Blue;
One spray booth manufactured by Paashe. Except for the spray booth, all other equipment listed for informational purposes only.
II.A.20 IT and Exterior Area (East) Two emergency generators manufactured by Kohler. Smaller one powered by natural gas and rated at 15 kW. The second one powered by diesel fuel and rated at 150 kW.
II.A.21 Miscellaneous Exhaust Hoods Miscellaneous hoods located throughout the facility in both building 1 & 2
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 Requirements and Limitations
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 8
II.B.1.a NEW The owner/operator shall not allow visible emissions from the following points to exceed the following values: A. 10% opacity for baghouses and wet collectors B. 10% opacity for natural gas operated equipment
C. 20% opacity for diesel engine exhausts and all other points. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method. [R307-401-8] II.B.1.b NEW The owner/operator shall not consume more than 26,250 decatherms of natural gas per rolling 12-month period. [R307-401-8]
II.B.1.b.1 NEW To comply with the natural gas consumption limit, the owner/operator shall:
A. Calculate a new 12-month total by 20th day of each month using data from the
previous 12 months
B. Determine the natural gas consumption by monthly gas bills from a utility company
C. Keep the natural gas consumption records for all periods when the plant is in
operation. [R307-401-8]
II.B.1.c The owner/operator shall use diesel fuel and natural gas as combustion-fuels. [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 (the ovens, spray booths and associated operations) on site:
6.50 tons per rolling 12-month period of VOCs 3.00 tons per rolling 12-month period of chlorine 2.00 tons per rolling 12-month period of toluene 0.80 tons per rolling 12-month period of methylene bis 2-chloroaniline 1.60 tons per rolling 12-month period of methylene chloride
6.00 tons per rolling 12-month period of lead. [R307-401-8]
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 9
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 owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]
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]
II.B.2.a.3 NEW The owner/operator shall keep records each month of the following:
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 comply with the applicable requirements in R307-335. [R307-335]
II.B.3
NEW
Baghouse Conditions
II.B.3.a NEW The owner/operator shall operate baghouses to control particulate emissions from all low and high temperature operations. The low temperature operations include batching, milling, and spray drying; the high temperature operations include calciner kilns, Bisque kilns, and high
fire kilns. All exhaust streams from these operations shall be vented to their designated baghouses before being vented to the atmosphere. [R307-401-8]
II.B.3.b NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across each of the baghouses. [R307-401-8]
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 10
II.B.3.b.1 NEW The pressure gauges shall be located such that an inspector/operator can safely read the indicators at any time. [R307-401-8]
II.B.3.b.2 NEW The pressure gauges shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8]
II.B.3.c NEW During operation of the baghouses, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8]
II.B.3.c.1 NEW The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] II.B.3.c.2 NEW The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification B. Manufacturer recommended static pressure differential for the unit C. Daily static pressure differential readings
D. Date of reading. [R307-401-8]
II.B.3.d NEW At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the pressure gauges. [R307-401-8] II.B.3.d.1 NEW The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8]
II.B.4 NEW Emergency Engine Requirements
II.B.4.a NEW The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.1 NEW To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage
[R307-401-8, 40 CFR 63 Subpart ZZZZ]
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 11
II.B.4.a.2 NEW To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.4.b NEW The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 130-kW and 150-kW emergency generator engines, and natural gas in the 15-kW emergency generator engine. [R307-401-8] II.B.4.b.1 NEW The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.4.b.2 NEW To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 12
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN104860010 dated February 5, 2015
Incorporates A Replacement Request dated March 19, 2024 Incorporates Additional information dated April 2, 2024 Incorporates Name Change dated April 12, 2024 Incorporates Additional Information dated August 28, 2024
REVIEWER COMMENTS
1. Comment regarding Reduction in Air Pollutants: The source has proposed to replace the ultrasonic vapor degreaser listed under II.A.10 in the AO DAQE-AN104860010-15 with two (2) small vapor degreasers. Emissions from the new degreasers will vent through the same existing ventilation system to the atmosphere. This replacement will not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant. Therefore, the replacement meets the applicability listed in R307-401-12, Reduction in Air Pollutants. This administrative amendment will update the AO to include the two (2) small vapor degreasers. The new vapor degreasers are subject to the requirements in R307-335; therefore, II.B.2.b is added to this AO. [Last updated November 19, 2024] 2. Comment regarding Federal standard applicability:
The following Federal standards were determined to apply to the emergency generator engine in the previous review: NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. [Last updated October 2, 2024] 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; or 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. It is subject to NSPS Subpart IIII and MACT Subpart ZZZZ requirements. However, the Federal standards specifically exempt the source
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 13
from the obligation to obtain a Title V permit, provided that the source is not required to obtain the permit for a reason other than being an area source under the Subparts IIII and ZZZZ. Therefore,
Title V is not required for the source. [Last updated October 2, 2024]
Engineer Review N104860011: L3Harris EDO Western Corporation November 19, 2024 Page 14
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
Utah Division of Air Quality
New somce Review Section
Ownership Change/Company Name Change Notification
The following infoimation is necessaiy befoie the Division will be able to make the name
change you have lequested Please letuin this document within 30 days of leceipt
Please be awaie that aH lecoids associated with this company will change to the new name unless you specifically
indicate otherwise The fee assessed foi making these changes is authorized by the legislatuie foi the actual time spent
by the leviewei
Note If this name change is the result of a sale 01 acquisition, both the buyer & the seller must sign this document
as pi oof of the closuie of the agi cement
Reason foi Owneislnp Change/Company Name Change L3Technolog.es/Hams merger_______________
Company Name
Current Previous
LSHarns EDO Western Corporation EDO Corporation/Electro Acoustics Div
Parent Company Patent Company
Company Addiess
Current Previous
2645 South 300 West, Salt Lake City, UT -84115 2645 South 300 West, Salt Lake City,
UT -84115
Appioval Oideis Affected and Sites Foi Each Appioval Oidei
Approval Order # (DAQE-ANxxxxxxxxxx-xx)Site Name & Address (for each Approval Order)
DAQE-AN0104860008-07 LSHarris EDO Western Corporation - 2645
South 300 West. Salt Lake Citv. UT -84115
The undeisigned, as an authonzed lepiesentative of the company, acknowledges that the above information is conect,
and requests that the company name change be made in all An Quality lecoids
Contact Name (Please punt)
( 801 ^ 209 _ 3080
Phone Numbei
thomas.allen@l3harns.com
E-mail
Pievious Ownei
Signatuie
Name (please punt)
Title
Return this form to:
State of Utah
Division of Ah Quality
Attn NSR - Ownei slup/Name Change Notification
195 Noith 1950 West
PO Box 144820
Salt Lake City, Utah 84114-4820
SECTfON\Foirm\Name Change doe Revised 5/16/11
4/2/24, 10:04 AM State of Utah Mail - Replacement-in-kind Request
https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r3169199796914071254&simpl=msg-a:r640480422147366…1/3
Enqiang He <ehe@utah.gov>
Replacement-in-kind Request
3 messages
Enqiang He <ehe@utah.gov>Mon, Mar 25, 2024 at 12:22 PM
To: Thomas.Allen@l3harris.com
Mr. Allen,
The Division of Air Quality has received your request to replace a degreaser. I have
been assigned to review the project. I'm attaching the replacement-in-kind rule below,
please let me know how the replacement meets the requirements in (1) Applicability of
the rule.
Please respond within two weeks from today. Let me know if you have any questions.
Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: (801) 556-1580
ehe@utah.gov
Enqiang He <ehe@utah.gov>Mon, Mar 25, 2024 at 12:28 PM
To: Thomas.Allen@l3harris.com
Sorry, but here is the rule:
R307-401-11. Replacement-in-Kind Equipment.
(1) Applicability. Existing process equipment or pollution control equipment that is covered by an existing approval order or State
Implementation Plan requirement may be replaced using the procedures in (2) below if:
(a) the potential to emit of the process equipment is the same or lower;
(b) the number of emission points or emitting units is the same or lower;
(c) no additional types of air pollutants are emitted as a result of the replacement;
(d) the process equipment or pollution control equipment is identical to or functionally equivalent to the replaced equipment;
(e) the replacement does not change the basic design parameters of the process unit or pollution control equipment;
(f) the replaced process equipment or pollution control equipment is permanently removed from the stationary source, otherwise permanently
disabled, or permanently barred from operation;
(g) the replacement process equipment or pollution control equipment does not trigger New Source Performance Standards or National
Emissions Standards for Hazardous Air Pollutants under 42 U.S.C. 7411 or 7412; and
(h) the replacement of the control apparatus or process equipment does not violate any other provision of Title R307.
(2) Replacement-in-Kind Procedures.
(a) In lieu of filing a notice of intent under Section R307-401-5, the owner or operator of a stationary source shall submit a written notification
to the director before replacing the equipment. The notification shall contain a description of the replacement-in-kind equipment, including the control
capability of any control apparatus and a demonstration that the conditions of (1) above are met.
(b) If the replacement-in-kind meets the conditions of (1) above, the director will update the source's approval order and notify the owner or
operator. Public review under Section R307-401-7 is not required for the update to the approval order.
(3) If the replaced process equipment or pollution control equipment is brought back into operation, it shall constitute a new emissions unit.
4/2/24, 10:04 AM State of Utah Mail - Replacement-in-kind Request
https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r3169199796914071254&simpl=msg-a:r640480422147366…2/3
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: (801) 556-1580
ehe@utah.gov
[Quoted text hidden]
Thomas.Allen@l3harris.com <Thomas.Allen@l3harris.com>Tue, Apr 2, 2024 at 9:55 AM
To: ehe@utah.gov
EQ,
Please find the response below to the Replacement in kind applicability request:
(a) the potential to emit of the process equipment is the same or lower; The old large vapor degreaser will be
replaced by 2 new small vapor degreasers that will allow us to run smaller quantities of parts while using less
solvent.
(b) the number of emission points or emitting units is the same or lower; The 2 smaller vapor degreasers will
both be vented out the same point as the old degreaser.
(c) no additional types of air pollutants are emitted as a result of the replacement; No additional pollutants will
be emitted.
(d) the process equipment or pollution control equipment is identical to or functionally equivalent to the replaced
equipment; Correct.
(e) the replacement does not change the basic design parameters of the process unit or pollution control
equipment; Correct.
(f) the replaced process equipment or pollution control equipment is permanently removed from the stationary
source, otherwise permanently disabled, or permanently barred from operation; Old Vapor Degreaser will be
removed and disabled.
(g) the replacement process equipment or pollution control equipment does not trigger New Source Performance
Standards or National Emissions Standards for Hazardous Air Pollutants under 42 U.S.C. 7411 or 7412; No new
standards triggered.
(h) the replacement of the control apparatus or process equipment does not violate any other provision of Title
R307. No violations with new equipment.
Please reach out if you have any further questions or more detail is needed.
Thank you,
Thomas Allen, CSP
Sr. Specialist, EHS
INTEGRATED MISSION SYSTEMS - L3 TECHNOLOGIES, INC.
4/2/24, 10:04 AM State of Utah Mail - Replacement-in-kind Request
https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r3169199796914071254&simpl=msg-a:r640480422147366…3/3
A WHOLLY OWNED SUBSIDIARY OF L3HARRIS TECHNOLOGIES, INC.
2645 South 300 West, Salt Lake City, Utah 84115
Office: (801)461-9377
Cell: (801)209-3080
Thomas.Allen@L3Harris.com
From: Enqiang He <ehe@utah.gov>
Sent: Monday, March 25, 2024 12:23 PM
To: Allen, Thomas (US) - MAR <Thomas.Allen@L3Harris.com>
Subject: [EXTERNAL] Replacement-in-kind Request
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