DAQ-2025-002597

1
DAQC-CI104520001-25
Site ID 10452 (B1)

MEMORANDUM

TO: FILE – COTTONWOOD MILL & CABINET – Cabinet Manufacturing Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: March 25, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: December 19, 2024

SOURCE LOCATION: 12757 South Minuteman Way
Draper, UT 84020
SOURCE CONTACT: Dan Rees, Senior Vice President of Operations, 801-462-3144,
[e-mail]

OPERATING STATUS: In operation

PROCESS DESCRIPTION: Cottonwood Mill and Cabinet operate a custom cabinet
manufacturing plant. Emission include Particulate Matter (PM)
from wood cutting, plaining, and sanding operations, and
Volatile Organic Compounds (VOCs) from sealing and coating
operations. Only water-based glues are used. For the control of
PM during wood working operations, a system of cyclones and
baghouses capture the dust and shavings. Each work-site is
equipped with a vacuum system that removes PM as it is
generated.

To control emissions, the wood particles pass through a series of
ducts to one of two cyclone/baghouse units. The cyclones serve
as pre-separators to recover the large particulates. The baghouses
then filter out the remaining particulate. The filtered air from the
baghouses is then vented back into the building as return air and
for climate control. A third baghouse, which also vents back into
the building, controls emissions from the sanding process.
Material from the baghouses drop into sealed drums. Misting
sprays have been installed throughout the plant to further control
the sawdust and fine particulates.

/ :
2
Paint solids during painting and spraying operations are
accomplished through the use of a series of particulate arrestor
filters across the back of each paint booth. Painting and spraying
take place in the booths with the blower fan turned on to force
emissions through a set of filters about seven feet tall by ten feet
wide at the back of the booths. An enclosed chamber behind the
filters then vents the filtered emissions out a stack on the roof.
Emissions from VOCs and Hazardous Air Pollutants (HAPs) are
reduced through consumption limits, good operating practices,
and limiting the VOC/solid ratios of the coatings used.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104520007-24, dated October
17, 2024
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Cottonwood Mill & Cabinet - Cabinet
Manufacturing Facility

12757 South Minuteman Way 12757 South Minuteman Way
Draper, UT 84020 Draper, UT 84020

SIC Code: 2511: (Wood Household Furniture, Except Upholstered)

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]
3
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Cottonwood Mill & Cabinet has not exceeded any limits set forth in this Approval Order. Cottonwood Mill & Cabinet maintains records for at least two years, and maintains records of maintenance activities performed on approved equipment. According to Cottonwood Mill & Cabinet, there has been no breakdowns resulting in an emissions event. According to the 2023 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this Approval Order.

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Cabinet Manufacturing Facility

II.A.2 Spray Booth Room

II.A.3 One (1) Baghouse
Flow Rate: 35,000 CFM
*Vents internally, listed for informational purposes only

II.A.4 One (1) Baghouse
Return air fabric filter system
*Vents internally, listed for informational purposes only

Status: In Compliance.

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements II.B.1.a The owner/operator shall have a copy of this AO available on site. The owner/operator shall make a copy of the AO available to the employees who operate the air emission producing equipment. The owner/operator shall provide instruction to employees as to their responsibilities in operating the equipment according to all of the relevant conditions in this AO. [R307-401-8] Status: In Compliance. Cottonwood Mill & Cabinet has a copy of this AO available onsite. Cottonwood Mill & Cabinet also indicated that their employees receive training and instruction on their responsibilities in operating the equipment according to the relevant conditions in this AO. II.B.1.b The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities to exceed 10% opacity. [R307-401-8] Status: In Compliance. There were no visible emissions observed during this inspection. See the attachment for additional information. II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Any time interval with no visible emissions shall not be included. [40 CFR 60 Subpart A, R307-401-8] Status: In Compliance. There were no visible emissions observed from mobile sources and intermittent sources during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9.
4
II.B.1.c The owner/operator shall comply with all applicable requirements of R307-342 "Adhesives and Sealants". [R307-342] Status: In Compliance. Cottonwood Mill & Cabinet uses the Titebond III Ultimate Wood Glue which is designed for wood-to-wood applications, and has a VOC content of 0.0105 g/l. It is categorized as a contact bond, and indicates compliance with Table 1 of R307-342-5. See the SDS in the attachment. II.B.1.d The owner/operator shall comply with all applicable requirements of R307-343 "Wood Furniture
Manufacturing Operations". [R307-343]

Status: In Compliance. Cottonwood Mill & Cabinet operates five painting booths all
equipped with downdraft ventilation and paint arrestor particulate filters. Exhaust air
from each of the spray booths is routed through the particulate arrestor filter before being
vented to the atmosphere. Cottonwood Mill & Cabinet uses high volume, low pressure
(HVLP) spray guns.
The coatings are stored in a flammable storage room. All VOC-containing coatings and
coating-related waste materials are stored in closed containers, especially when not in use.
Spills are quickly cleaned.
The Technical Data Sheets of the coatings and associated VOC content reviewed onsite
included AkzoNobel 5 Sheen, 0.979 lb/lb, AkzoNobel 10 Sheen, 0.994 lb/lb, AkzoNobel 15
Sheen, 0.974 lb/lb, and AkzoNobel 20 Sheen, 0.985 lb/lb. The VOC contents indicated
compliance with the VOC limits of the two component polyurethane topcoat in Table 1 of
R307-343-4. See the coating category in the attachment.
II.B.1.e The owner/operator shall keep a copy of all manufacturers' operating instructions for pollution control equipment and pollution emitting equipment on site. Manufacturer instructions shall be made available to all employees who operate the equipment and shall be made available to compliance inspectors upon their request. [R307-401-8] Status: In Compliance. Cottonwood Mill & Cabinet maintains a copy of all manufacturers operating instructions for pollution control equipment and pollution emitting equipment on site. According to Cottonwood Mill & Cabinet, the manufacturer operating instructions are made available to all employees who operate the equipment, and to compliance inspectors upon request. II.B.1.f The owner/operator shall install paint arrestor particulate filters on all spray booths. All air exiting the spray booths shall be routed through the arrestor filters before being vented to the atmosphere. [R307-401-8] Status: In Compliance. Cottonwood Mill & Cabinet operates “five, three-sided Paint Booths in one enclosed room with positive air across from the Paint Booths, and negative air being pulled through filter banks.” Exhaust air from each of the spray booths is routed through the particulate arrestor filter before being vented to the atmosphere. II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following rate from the Spray Booth Exhaust: Pollutant lb/hr VOC 5.2 [R307-401-8]
5
II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-401-8] II.B.2.a.2 Test Frequency The owner/operator shall conduct a stack test on the emission unit as required by the Director. The Director may require the owner/operator to perform a stack test at any time. No initial testing is required. [R307-401-8] Status: Compliance undetermined. The director has not required Cotton Mill & Cabinet to perform a stack test at this time. II.B.2.b The owner/operator shall not allow the VOC content of coatings used in the booth to exceed the limits established in R307-343-4, Table 1. The owner/operator shall not allow high solids paints to be thinned or otherwise reduced beyond manufacturers recommendations. These parameters shall be tested if directed by the Director using the appropriate ASTM method or another method approved by the Director. [R307-401-8] II.B.2.c The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 22.55 tons per rolling 12-month period of VOCs 9.99 tons per rolling 12-month period of any one (1) HAP 12.21 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.c.1 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.c.2 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.c.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
6
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. The rolling 12-month emissions of VOCs and HAPs from January to December 2024, indicated the following: 2.67 tons per rolling 12-month period of VOCs 0.224 tons per rolling 12-month period of all HAPs combined Cottonwood Mill & Cabinet used the mass-balance method to calculate emissions from evaporative sources. See additional information in the attachment and email communication. II.B.3 Stack Testing II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.a.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.3.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.3.a.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.3.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.3.a.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.3.a.6 Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]

7
II.B.3.b Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.3.b.1 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] Status: Compliance undetermined. The director has not required Cotton Mill and Cabinet to perform a stack test at this time.

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.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-305 - Nonattainment and Maintenance Areas for PM10: Emission Standards Status: In Compliance. There were no visible emissions observed during this inspection. See the attachment for additional information.
R307-325 - Ozone Nonattainment and Maintenance Areas: General Requirements

Status: In Compliance. The coatings are stored in a flammable storage room. All VOC-containing
coatings and coating-related waste materials are stored in closed containers, especially when not in
use. Spills are quickly cleaned.
R307-305 - Solvent Cleaning

Status: Exemption. Cottonwood Mill & Cabinet is claiming exemption R307-304-3(1) which states
that “The requirements of R307-304 do not apply to the operations that are subject to R307-342
through R307-347 and R307-349 through R307-355.” See additional information in R307-343 below.
R307-342 - Adhesives and Sealants
Status: In Compliance. Cottonwood Mill & Cabinet uses the Titebond III Ultimate Wood Glue which is designed for wood-to-wood applications, and has a VOC content of 0.0105 g/l. It is categorized as a contact bond, and indicates compliance with Table 1 of R307-342-5. See the SDS in the attachment.

8
R307-343 - Emissions Standards for Wood Furniture Manufacturing Operations

Status: In Compliance. Cottonwood Mill & Cabinet operates five paint booths all equipped with
downdraft ventilation and paint arrestor particulate filters. Exhaust air from each of the spray
booths is routed through the particulate arrestor filter before being vented to the atmosphere.

Cottonwood Mill & Cabinet uses high volume, low pressure (HVLP) spray guns. The coatings are
stored in a flammable storage room. All VOC-containing coatings and coating-related waste
materials are stored in closed containers, especially when not in use. Spills are quickly cleaned.

The Technical Data Sheets of the coatings and associated VOC content reviewed onsite included
AkzoNobel 5 Sheen, 0.979 lb/lb, AkzoNobel 10 Sheen, 0.994 lb/lb, AkzoNobel 15 Sheen, 0.974 lb/lb,
and AkzoNobel 20 Sheen, 0.985 lb/lb. The VOC contents indicated compliance with the VOC limits of
the two component polyurethane topcoat in Table 1 of R307-343-4. See the coating category in the
attachment.

EMISSION INVENTORY: Status: In Compliance. According to the 2023 Emissions Inventory
Report, the emissions indicated compliance with the PTEs of this Approval Order.

Listed below are the Actual Emissions Inventory provided from Cottonwood Mill & Cabinet - Cabinet
Manufacturing Facility. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN104520007-24, dated October 17, 2024 is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 1.00 ---
Nitrogen Oxides 1.00 ----
Particulate Matter - PM10 1.00 0.752
Particulate Matter - PM2.5 1.00 0.37
Sulfur Dioxide 1.00 ----
Volatile Organic Compounds 22.55 3.73

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 24420 936.8

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Cottonwood Mill & Cabinet is in compliance with the conditions
in Approval Order (AO) DAQE-AN104520007-24, dated
October 17, 2024. Cottonwood Mill & Cabinet maintains good
housekeeping practices.

HPV STATUS: Not Applicable.

9
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Normal hours of operation are from 0700 to
1530, Monday through Friday.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: Applicable Supporting Documentation Included