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Home My WebLink AboutDAQ-2025-0021171 DAQC-CI105580001-25 Site ID 10558 (B1) MEMORANDUM TO: FILE – CABINETRY BY KARMAN – Cabinet Manufacturing Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Susan Weisenberg, Environmental Scientist DATE: March 31, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: March 24, 2025 SOURCE LOCATION: 6000 South Stratler Street Murray, UT 84157 DIRECTIONS: From I-15 southbound, take exit 300 (5300 South). Take 320 W/S Commerce Drive to Stratler Street in Murray SOURCE CONTACTS: Allen Garcia, General Manager 801-281-6400 agarcia@cabinetrybykarman.com OPERATING STATUS: Operating normally. PROCESS DESCRIPTION: Cabinetry by Karman operates a wood furniture manufacturing facility. Pieces are sanded and finished prior to final assembly within contained areas that are vented to a central vacuum system which then vents to a cyclone. After exiting the cyclone, the air passes through a baghouse. VOC and HAP containing finish coatings are either manually sprayed in an assembly line with a gas fired dyer or are sprayed in an automated multi-component system. The automated system is a self-contained spray system that precisely measures each piece to eliminate overspray. Paint drippings are collected for reuse. This system also includes a drying oven. Finished pieces are assembled into the final product. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN105580010-25, dated February 27, 2025 SOURCE EVALUATION: Name of Permittee: Permitted Location: Cabinetry By Karman - Cabinet Manufacturing Facility P.O. Box 57086 6000 South Stratler Street Murray, UT 84157 Murray, UT 84157 SIC Code: 2511: (Wood Household Furniture, Except Upholstered) 0 . ) $ . ) - " 2 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] Status: In Compliance. No limits were exceeded based on observations and a review of the submitted documents. No additional equipment or processes were found during this inspection. Records, including maintenance documents, are kept as required and were provided during the inspection. No R307-107 applicable breakdowns have occurred. An Emissions Inventory was submitted for the 2023 activity year and the Summary Report is attached to this memo. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Cabinetry By Karman II.A.2 One (1) Multi-Component Spray Coating System Reciprocating spray machine and a multi-level electric/gas oven Contained within a spray booth Cefla #CE-3570B II.A.3 Five (5) Spray Booths Equipped with HVLP spray guns and particulate filters II.A.4 One (1) Cyclone Vents to baghouse II.A.5 One (1) Baghouse Vents internally 3 II.A.6 Two (2) Drying Ovens Status: In Compliance. The listed equipment has been installed and was operating on the day of this inspection. The source environmental contact, Allen Garcia, stated that the actual manufacturer of II.A.2, the multi-component spray coating system, should be the German manufacturer of Venjakob rather than the listed Cefla. With regards to the two drying ovens listed on II.A.6, one of the ovens is fueled by gas, while the second oven is an air-dry system. II.B Requirements and Limitations II.B.1 Site Wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point on site to exceed 10% opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point. II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall comply with all applicable requirements of R307-343 for Wood Furniture Manufacturing Operations in Davis and Salt Lake Counties and ozone non-attainment areas. [R307-343] Status: In Compliance. Each R307-343 applicable VOC containing product line was reviewed and found to be compliant with Table 1. A spreadsheet containing the name of each product, and the VOC pounds per pound of solids was provided. See the attached spreadsheet, "V/HAP AVERAGING CALCULATIONS” (ending in the month of February 2025). The VOC lbs/per lbs of solids are recorded under Column C. The coatings are applied with HVLP sprays. All VOC containing product lines are continuously enclosed. II.B.1.c The owner/operator shall equip each paint spray booths and the reciprocating spray machine with a set of paint arrester particulate filters to control particulate emissions. All air exhaust from spray booths as well as reciprocating spray machine shall pass through these filters before being vented to the atmosphere. [R307-401-8] Status: In Compliance. The five manual spray booths and the multi-component spray system were observed with the required particulate filters. All air exhaust passes through these filters before being vented to the atmosphere. The filters are replaced based on use and air flow. II.B.2 Volatile Organic Compound (VOC) and Hazardous Air Pollutant (HAP) Limitations II.B.2.a The owner/operator shall not emit more than the following from lacquer spray booths, solvent cleaning, combustion sources, and associated surface coating operations following on site: A. 49.00 tons of VOC's per rolling 12-month period B. 12.16 tons of combined HAP's per rolling 12-month period C. 9.99 tons of any single HAP per rolling 12-month period [R307-401-8] Status: In Compliance. The rolling12-month totals for the time period of March 2024 through February 2025, were reported as 21.2 tons of VOC and 4.576 tons of total HAPS. No single HAP exceeded the 9.99 ton limit. The highest rolling 12-month total for a single HAP was for Xylene which was reported at 2.35 tons. See the attached “2025 Usage Report”. 4 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 the applicable units to comply with the mass balance method: VOCs = [% VOC by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] Status: In Compliance. The reported emissions are calculated as required. See the attached rolling 12-month Usage Report. 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] Status: Not Applicable as this facility does not currently use or reference at reclamation system. Some VOC topcoat product drips are collected in the multi-coating system but the product is reused as it is pumped through the system rather than reclaimed. 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] Status: In Compliance. SDS for each VOC containing product is maintained on site. The data from these data sheets are entered into the calculating spreadsheets. Records of each VOC containing product that includes the weight, density, and amount, is maintained as required on the spreadsheets used to calculate totals. (See the V/HAP AVERAGING CALCULATIONS and Usage Report). Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. MACT Subpart JJ National Emission Standards for Wood Furniture Manufacturing Operations Status: Not Applicable. This subpart applies to Major Sources, per 60.800(a). Cabinetry by Karman is a Minor Source. 5 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Solvent Cleaning [R307-304] Status: Not Applicable. This facility is exempt due to the applicability of R307-343. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. No visible emissions were observed from any point or vent during this inspection. All entrances and operation areas are paved. Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: In Compliance. All VOC containing products are sealed and applied correctly. Spills are cleaned up immediately. Davis and Salt Lake Counties and Ozone Nonattainment Areas: Emissions Standards for Wood Furniture Manufacturing Operations [R307-343] Status: In Compliance. The source is aware of this Rule and operates in compliance with the established procedures and applicable VOC limits of Table 1. A printed copy of the Rule was provided at the time of this inspection. See Condition II.B.1.b for more information. Cabinetry by Karman is exempt from R307-343-7 for Solvent Cleaning Operations due to the use of acetone as the cleaner for parts and spray guns. EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided from Cabinetry By Karman - Cabinet Manufacturing Facility. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN105580010-25, dated February 27, 2025, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Carbon Monoxide 0.50 0.196 Nitrogen Oxides 1.49 0.266 Particulate Matter - PM10 0.18 0.0206 Particulate Matter - PM2.5 0.18 0.0206 Sulfur Dioxide 0.01 0.0016 Volatile Organic Compounds 49.00 18.0503 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Ethyl Benzene (CAS #100414) 3100 0.905 Ethylene Glycol (CAS #107211) 40 Formaldehyde (CAS #50000) 200 0.056 Glycol Ethers (CAS #EDF109) 220 0.039 Methanol (CAS #67561) 20 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 200 Toluene (CAS #108883) 7260 1.761 Xylenes (Isomers And Mixture) (CAS #1330207) 13400 3.966 6 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions are on record for the last five years. COMPLIANCE STATUS & RECOMMENDATIONS: This facility should be considered to be in compliance with the February 27, 2025, AO DAQE-AN105580010-25. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual maintaining the same targeting frequency. NSR RECOMMENDATIONS: Consider changing the description of the equipment listed as II.A.2, the Multi-Component Spray Coating System was manufactured by Venjakob, rather than the stated Cefla during the next AO modification. The equipment is otherwise as described. ATTACHMENTS: VEO, V/HAP AVERAGING CALCULATIONS, 2025 Usage Report, and Emissions Inventory. 2023 Emissions Inventory Report Cabinetry by Karman (10558) Emissions Summary CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Emissions (tons, excluding tailpipe) Tailpipe Emissions (tons) Total Emissions (tons)* PM10-PRI PM10 Primary (Filt + Cond)0.02059 0.00009 0.02068 PM10-FIL PM10 Filterable 0.00515 <.00001 0.00515 PM25-PRI PM2.5 Primary (Filt + Cond)0.02059 0.00009 0.02068 PM25-FIL PM2.5 Filterable 0.00515 <.00001 0.00515 PM-CON PM Condensible 0.01544 <.00001 0.01544 SO2 Sulfur Dioxide 0.00163 0.00002 0.00164 NOX Nitrogen Oxides 0.26658 0.01617 0.28275 VOC Volatile Organic Compounds 18.05035 0.00383 18.05418 CO Carbon Monoxide 0.196 0.11183 0.30783 7439921 Lead <.00001 <.00001 <.00001 NH3 Ammonia 0.0129 <.00001 0.0129 HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions (tons)* 75070 Acetaldehyde (HAP)VOC 0.00003 107028 Acrolein (HAP)VOC 0.00004 7440382 Arsenic (HAP)PM <.00001 71432 Benzene (HAP)VOC <.00001 7440417 Beryllium (HAP)PM <.00001 7440439 Cadmium (HAP)PM <.00001 7440473 Chromium (HAP)PM <.00001 7440484 Cobalt (HAP)PM <.00001 100414 Ethyl Benzene (HAP)VOC 0.90579 50000 Formaldehyde (HAP)VOC 0.05562 171 Glycol Ethers (HAP)VOC 0.03949 110543 Hexane (HAP)VOC 0.00359 7439965 Manganese (HAP)PM 0.00379 7439976 Mercury (HAP)- <.00001 91203 Naphthalene (HAP)VOC <.00001 7440020 Nickel (HAP)PM <.00001 7782492 Selenium (HAP)PM <.00001 108883 Toluene (HAP)VOC 1.76167 1330207 Xylenes (Mixed Isomers) (HAP)VOC 3.96616 91576 2-Methylnaphthalene (HAP)PM <.00001 *Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated. 1/2