DAQ-2025-002118

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DAQC-CI105620001-25
Site ID 10562 (B1)

MEMORANDUM

TO: FILE – OLYMPIA SALES COMPANY – Cabinet Manufacturing Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: April 2, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: March 25, 2025

SOURCE LOCATION: 1537 South 700 West
Salt Lake City, 84104
DIRECTIONS: From I-15 south bound, take the 1300 south exit. Head west to
700 West. The office is located through the show room.

SOURCE CONTACTS: Nathan Powell, Plant Manager
801-972-4050 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Olympia manufactures wood furniture from raw lumber. The
lumber is milled, assembled, coated, boxed, and shipped.
Lumber and plywood arrive by truck. The machine cuts the
lumber and plywood into various sizes. Some of the cut lumber
goes through a molder, framing, clamping, and sanding before
coating. Dust particles generated from the cutting and sanding
operations are routed to a baghouse before the treated air is
vented inside or outside the building. The source uses High
Volume Low Pressure (HVLP) spray guns to apply the coatings.
Acetone is used to clean the lines and the spray guns. The
different parts of the furniture are assembled, boxed, and
shipped.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN105620006-23, dated
September 26, 2023
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Olympia Sales Company- Cabinet Manufacturing
Facility

1537 South 700 West 1537 South 700 West
Salt Lake City, UT 84104 Salt Lake City, 84104

SIC Code: 2434: (Wood Kitchen Cabinets)
0 . ) $ . ) - "
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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 modifications to permitted equipment and processes have occurred since the previous inspection. Records are kept for a minimum of two years for both digital and hard copy files. No R307-107 applicable breakdowns have occurred. An Emission Inventory for the 2024 activity year has been submitted and is attached to this inspection memo.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Wood Cabinet Manufacturing Plant
II.A.2 Five (5) Paint Booths Control Device: Particulate Filters
II.A.3 One (1) Baghouse Maximum Flow Rate: 66,000 acfm
II.A.4 Sanding, Milling and Sawing Areas Control Device: Baghouse
II.A.5 Natural Gas Fired Heaters Maximum Combined Heaters Rating: 4MMBTU/hr* *Noted for informational purposes only

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II.A.6 Two (2) Air Make-up Units Maximum Combined Air Make-up units Rating: 4.5 MMBtu/hr* Fuel Type: Natural Gas *Noted for informational purposes only.
Status: In Compliance. The listed equipment was observed during the inspection. No additional equipment was detected during the site visit.

II.B Requirements and Limitations
II.B.1 Site Wide Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. All paint booth exhaust points - 10% opacity B. The baghouse exhaust stack - 10% opacity C. All other points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point from the operating baghouse or paint booth vents during this inspection. See the attached VEO. II.B.1.b The baghouse shall control process streams from all sanding and wood working process areas. The baghouse exhaust point shall either be vented inside or outside the building dependent upon the owner/operators desired operating procedures. [R307-401-8] Status: In Compliance. All dust from the sanding and woodworking processes are vented to the baghouse. After filtering the dust, the baghouse vents inside the building during the winter to help warm the building. The baghouse vents outside during the summer. II.B.1.c The Olympia Sales shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the baghouse. The static pressure differential across the baghouse shall be between 0.5 to 8.0 inches of water column. [R307-401-8] Status: In Compliance. A manometer has been installed that measures the differential pressure across the baghouse. Baghouse pressure records were reviewed for the calendar year of 2024, and the three existing months of 2025. The recorded ranges appeared to stay within 1.1 to 1.4 inches of water column. See the attached differential log. II.B.1.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in 0.25-inch water column increments. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. The owner/operator shall record the reading of the pressure gauge at least once per operating day. [R307-401-8] Status: In Compliance. The pressure gauge is located in an accessible and easily viewed location. The gauge is capable of indicating .25-inch increments. A pressure gauge reading is recorded once per operating day. The gauge is calibrated once a year. The last calibration occurred on September 11, 2024. See the attached date recorded on the 2024 log readings.

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II.B.2 Paint Booth Operations and VOC and HAP Limitations II.B.2.a The Olympia Sales shall meet all requirements of R307-343 Emission Standards for Wood Furniture Manufacturing Operations. [R307-343] Status: In Compliance. In June of 2023, Olympia Sales switched to a new top coat product. The Plant Manager, Nathan Powell, identifies this product as a cured single component topcoat. The associated SDS states the pounds of VOC per pound of solids as 0.94 which is under the limit of Table 1 for this type of top coat. See the attached SDS for Sher-Wood KEMVAR Conversion Varnish. II.B.2.b Each paint spray booth shall be equipped with a set of paint arrestor particulate filters to control particulate emissions. All air exiting the paint booths shall pass through these filters or equivalent control device prior to venting to the atmosphere. [R307-401-8] Status: In Compliance. Each of the five paint booths were observed with the appropriate filters. All air from the booths are vented through the filters prior to release to the atmosphere. Filters are replaced as needed based on the amount of use and airflow. II.B.2.c The plant-wide emissions of VOCs and HAPs from all of the paint booths and painting operations shall not exceed: 49.9 tons per rolling 12-month period for VOCs generated from painting activities 15.45 tons per rolling 12-month period for all combined HAPs from painting activities 8.24 tons per rolling 12-month period for xylene 4.51 tons per rolling 12-month period for toluene 0.20 tons per rolling 12-month period for methanol 0.38 tons per rolling 12-month period for formaldehyde 0.07 tons per rolling 12-month period for methyl isobutyl ketone 2.05 tons per rolling 12-month period for ethyl benzene. [R307-401-8] II.B.2.c.1 Compliance with each limitation shall be determined on a rolling 12-month total. No later than 20 days after the end of each month, a new 12-month total shall be calculated using data from the previous 12 months. [R307-401-8] II.B.2.c.2 The VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC and HAP in each material used D. Gallons of each VOC and HAP emitting material used E. The amount of VOC and HAP emitted monthly by each material used shall be calculated by the following procedure: VOC = (% VOC by Weight/100) x [Density (lb/gal)] x Gal Consumed x 1 ton/2000 lb HAP = (% HAP by Weight/100) x [Density (lb/gal)] x Gal Consumed x 1 ton/2000 lb F. The amount of VOC or HAP emitted monthly from all materials used.
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G. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. [R307-401-8] Status: In Compliance. The reported 12-month rolling totals for the time period of March 2024 through February 2025, were reported as follows: 25.81 tons of VOC 4.00 tons of HAPS 2.93 tons of xylene 0.23 tons of toluene 2.60 pounds (0.0013 tons) of methanol 0.06 pounds (3e-5 tons) of formaldehyde 0.0 of methyl isobutyl ketone 0.74 tons of ethyl benzene Calculations are recorded as required using the recommended calculations. See the attached rolling total log indicating the product lines, gallons used, densities, pounds used, VOC percentages, and individual HAP chemicals. The 12-month totals in pounds and tons are recorded on the last three rows. II.B.2.d The Olympia Sales shall use only High Volume Low Pressure spray guns, electrostatic application, or equivalent coating processes in all painting operations. [R307-401-8] Status: In Compliance. Only HVLP spray guns are used in the coating operations. II.B.2.e All paint and solvent barrels shall be kept in a proper storage room. The barrels shall have sealed lids until they are ready to be used in the painting operations. Once a paint barrel becomes empty, the paint barrel shall be removed from the painting process and re-sealed with a proper lid. The empty barrels shall be placed in a storage area to await pickup. [R307-401-8] Status: In Compliance. All VOC containing products are kept in a storage room and are sealed until used. II.B.2.f The Olympia Sales shall keep an Inspection and Maintenance Plan for the painting operations. The plan shall require that one time each month all pumps, piping, hoses and spray guns of each painting process shall be visually inspected for leaks. A record shall be kept which shall record the inspector's name, the date of the inspection, and the result of the inspection. The record shall also document all maintenance of the pumps, piping, hoses and spray guns which takes place and the associated date. The record shall be made available to the Director upon request. [R307-401-8] Status: In Compliance. Monthly visual leak inspection records of pumps, piping, hoses, and spray guns are recorded. The maintenance record includes the staff inspector initials, a note of the maintenance needed, and how the maintenance was completed with the completion date. See the attached Paint Room Inspection log.

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.

Status: No Federal Subparts are applicable at this time.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible emissions were observed from any exhaust stack from the
operating baghouse or any vent from the operating paint booths. See the attached VEO for additional
information.
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. All VOC containing products are kept in sealed containers. The standard
operating procedure is to clean spills immediately.

Davis and Salt Lake Counties and Ozone Nonattainment Areas: Emissions Standards for Wood Furniture
Manufacturing Operations [R307-343]

Status: In Compliance. Coatings and solvents were kept in closed containers when not in use. The
volatile organic compound (VOC) content of the used coating indicated compliance with the limits in
R307-343-4 Table 1. With regards to the solvent cleaning operations as per R307-343-7(3), this
facility uses only acetone to clean parts and spray guns. The source is aware of all of the
requirements for this rule and maintains good housekeeping techniques to reduce emissions. A copy
of the Rule was provided during this inspection.

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Olympia Sales Company - Cabinet
Manufacturing Facility. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN105620006-23, dated September 26, 2023, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Particulate Matter - PM10 6.11 2.882
Particulate Matter - PM2.5 6.11 2.871
Volatile Organic Compounds 49.90

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Ethyl Benzene (CAS #100414) 4100 1516
Formaldehyde (CAS #50000) 760 0.34
Methanol (CAS #67561) 400 4.00
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 140
Toluene (CAS #108883) 9020 788
Xylenes (Isomers And Mixture) (CAS #1330207) 16480 6020

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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
AO AN105620006-23 dated September 26, 2023, at the time of
this inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual maintaining the same targeting frequency.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO, baghouse pressure logs, Sher-wood Kemvar topcoat
SDS,VOC/HAPs 12-month rolling totals, monthly paint room
inspection log, and SLEIS emissions inventory report
Susan Weisenberg <[e-mail]>
Re: request for additional information regarding solvent cleaners
1 message
Nate Powell <[e-mail]>Tue, Apr 8, 2025 at 8:12 AM
To: Susan Weisenberg <[e-mail]>
Susan,
Acetone is the only solvent we use to clean our spray guns and other equipment. That was spelled out in
our old permit, and we have stuck with it.
Hope that helps,
Nathan
From: Susan Weisenberg <[e-mail]>
Sent: Friday, April 4, 2025 3:39 PM
To: Nate Powell <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Subject: request for addional informaon regarding solvent cleaners

Dear Mr. Powell,
My name is Susan Weisenberg and I inspected your operation on March 25th. My section manager has requested that I
gather additional details regarding your facility's use of solvent cleaners.
Many cabinet manufacturers use a solvent cleaner to clean their HVLP spray guns and other equipment. Although your
Approval Order doesn't specifically mention this regulation, please note that solvent cleaners are regulated under R343-
7(3), which states that solvent cleaning operations must use cleaning materials with a VOC composite vapor pressure of
no more than 1 mm Hg at 20 degrees Celsius, unless an add-on control device is used as specified in R307-343-6.
This regulation does not apply if you are using acetone or another product that is not currently classified as a regulated
VOC. Please contact me if you have any questions. Thank you for your time with this.
Sincerely,
Susan
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
4/8/25, 8:31 AM State of Utah Mail - Re: request for additional information regarding solvent cleaners
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6995481730131320334%7Cmsg-f:1828844027981977733…1/1
2024 Emissions Inventory Report
Olympia Sales Company: Cabinet Manufacturing Facility (10562)
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)2.88262 0.0002 2.88282
PM10-FIL PM10 Filterable 2.87105 <.00001 2.87105
PM25-PRI PM2.5 Primary (Filt + Cond)2.88262 0.0002 2.88282
PM25-FIL PM2.5 Filterable 2.87105 <.00001 2.87105
PM-CON PM Condensible 0.01156 <.00001 0.01156
SO2 Sulfur Dioxide 0.00122 0.00004 0.00125
NOX Nitrogen Oxides 0.20289 0.00603 0.20892
VOC Volatile Organic Compounds 26.06888 0.00143 26.07031
CO Carbon Monoxide 0.17042 0.04171 0.21214
7439921 Lead <.00001 <.00001 <.00001
NH3 Ammonia 0.00099 <.00001 0.00099

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
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 0.758
50000 Formaldehyde (HAP)VOC 0.00017
110543 Hexane (HAP)VOC 0.00365
7439965 Manganese (HAP)PM <.00001
7439976 Mercury (HAP)- <.00001
67561 Methanol (HAP)VOC 0.002
91203 Naphthalene (HAP)VOC <.00001
7440020 Nickel (HAP)PM <.00001
7782492 Selenium (HAP)PM <.00001
108883 Toluene (HAP)VOC 0.39405
1330207 Xylenes (Mixed Isomers) (HAP)VOC 3.01
91576 2-Methylnaphthalene (HAP)PM <.00001

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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