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Home My WebLink AboutDAQ-2025-0026091 DAQC-CI140630001-25 Site ID 14063 (B1) MEMORANDUM TO: FILE – 3FORM MATERIAL SOLUTIONS, INC. – Plastic Laminate Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: May 1, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: December 12, 2024 SOURCE LOCATION: 2300 South 2300 West West Valley City, 84119 SOURCE CONTACT: Steve Allen, EHS Manager, 801-228-7839, steve.allen@3-form.com OPERATING STATUS: In operation PROCESS DESCRIPTION: Manufactures ecoresin, a co-polyester recycled content product, used to make panels containing textiles, natural objects, and textures. The process involves taking two sheets of a plastic polyethylene terephthalate with glycol modifier (PETG) and laminating natural objects such as grass, rocks, and fabrics between the two sheets. 1. Lay-up process: A sheet of plastic is laid on a table and the insert (rocks, flowers, fabrics) are applied on the plastic in the desired pattern. The second sheet of plastic is placed on top and rolled to the laminating presses. No chemicals are used in this process and there are no sources of emissions. 2. Presses: The plastic sheets are taken to oil presses. Oil is heated and pumped into the building by two boilers located in a building attached to the main exterior wall. The oil flows into the presses and heats the laminate from room temperature to 240°F at 1800 - 2100 psi. At this point the material enters the glass transition state, meaning it reaches a plastic point (it does not become a liquid). Immediately following the laminating procedure, the plastic is cooled by cold oil that circulates through the second half of the press. / : 2 3. Fulfillment: The sheets are rolled over to fulfillment, where the plastic is cut by several blade-operated saws. There are two Computer Numerical Control (CNC) saws and three panel saws. One of the CNC saws vents to a baghouse, the other produces chips that are collected by sweeping the floor. All panel saws vent to baghouses (internal). 4. Laser: The laser operation cuts sheets of laminate into squares. The laser is composed of argon and carbon dioxide. 5. Glass shop: The glass shop lays straw reeds and other materials between 2 sheets of glass. The edges of the glass are sealed except on one side. Three chemicals (an adhesion promoter, glass resin, and Norox MEKP-925) are mixed together to form a viscous substance. After mixing, the combination is pumped through tubes between the two sheets. Once the glass is full, the tubes are removed and the last section of glass is sealed off. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN140630007-22, dated March 11, 2022 NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. SOURCE EVALUATION: Name of Permittee: Permitted Location: 3form Material Solutions, Inc. - Plastic Laminate Plant 2300 South 2300 West Suite B 2300 South 2300 West West Valley City, UT 84119 West Valley City, UT 84119 SIC Code: 3083: (Laminated Plastics Plate, Sheet, & Profile Shapes) 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] 3 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. 3Form Material has not exceeded any limits set forth in this Approval Order. 3Form Material maintains records for at least two years, and maintains records of maintenance activities performed on approved equipment. According to 3Form Material, 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 installations shall consist of the following equipment: II.A.1 3Form Plastic Laminate Plant II.A.2 VOC and HAP Emitting Processes Including solvent cleaning, wiping and other operations II.A.3 Various Boilers Rated Input: <5 MMBtu/hr Each Fuel: Natural gas II.A.4 Plastic Cutting Operations Miscellaneous panel and table saws, the sanding booth and the laser machine II.A.5 Plastic Cutting Operations Baghouse One (1) baghouse to control emissions from panel and table saws, the sanding booth, and the laser machine used in plastic cutting operations II.A.6 Fulfillment Panel Saws One (1) 5,000 ACFM baghouse vented to atmosphere to control cutting emissions II.A.7 Glass Shop 4 II.A.8 One (1) Emergency Generator Engine Rating: 78 kW (105 hp) Fuel: Natural gas Manufacture Date: 2010 NSPS/MACT Applicability: 40 CFR 60 Subpart JJJJ/40 CFR 63 Subpart ZZZZ Status: In Compliance. There was no new or unauthorized equipment identified onsite. 3Form was provided information and the link to the new boiler rules which will be subject to the 9 ppm NOx limit going forward. 3Form was able to identify the boilers and their associated ratings in AO Condition II.A.3 as follows: 3Form was able to identify the boilers and their associated ratings in AO Condition II.A.3 as follows: Autoclave Boiler 1 = 4.2 MMBtu/hr Autoclave Boiler 2 = 4.2 MMBtu/hr Oil Boiler 3 = 4.99 MMBtu/hr Oil Boiler 4 = 4.99 MMBtu/hr See the email attachment for additional information. II.B REQUIREMENTS AND LIMITATIONS II.B.1.a Visible emissions from the following emission points shall not exceed the following opacity values: A. All baghouses - 10% B. All natural gas exhaust points - 10% C. All other points - 20%. [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. [R307-305-3] Status: In Compliance. There were no visible emissions observed from the baghouses, all the natural gas exhaust points, and all other points. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment for additional information. II.B.1.b The owner/operator shall only use natural gas as fuel in the boilers. [R307-401-8] Status: In Compliance. 3Form Material only uses natural gas in the boilers as required by this AO Condition. II.B.2 Baghouse Conditions II.B.2.a The owner/operator shall use the fulfillment saw baghouse to control particulate emissions from the panel saws. The owner/operator shall use plastic cutting operations baghouse to control particulate emissions from the panel and table saws, the sanding booth, and the laser machine. [R307-401-8] Status: In Compliance. 3Form Material uses the Fulfillment Panel Saw baghouse to control particulate emissions from the panel saws, and the Plastic Cutting Operations baghouse to control particulate emissions from the panel, table saws, sanding booth, and the laser machine as required by this AO Condition. 5 II.B.2.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across each baghouse. [R307-401-8] II.B.2.b.1 Each pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.2.b.2 Each pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.2.c During operation of the fulfillment saw baghouse, the owner/operator shall maintain the static pressure differential across the fulfillment saw baghouse between 1.0 and 4.0 inches of water column. During operation of the plastic cutting operations baghouse, the owner/operator shall maintain the static pressure differential across the plastic cutting operations baghouse between 1.0 and 9.0 inches of water column. [R307-401-8] II.B.2.c.1 The owner/operator shall record the static pressure differential at least once per operating day while each baghouse is operating. [R307-401-8] II.B.2.c.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Daily static pressure differential readings; C. Date of reading. [R307-401-8] Status: In Compliance. 3Form Material has installed two maghelic gauges to measure the differential pressure across the baghouses. During this inspection the magnehelic gauge connected to the Plastic Cutting Operations Baghouse indicated 1.6 inches of water column, and the magnehelic gauge connected to the Fulfillment Panel Saw Baghouse indicated 1.8 inches of water column. The differential pressure of the gauges are recorded at least once a day when each baghouse is operating. See differential pressure records in the attachment. II.B.2.d At least once every 12 months, the owner/operator shall calibrate the pressure gauge in accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8] II.B.2.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] Status: In Compliance. The magnehelic gauges were calibrated by Western States Calibration on October 29, 2024. 3Form Material maintains records of the pressure gauge calibrations and replacements. See the attachment for additional information. II.B.3 VOC & HAP Requirements II.B.3.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 24.05 tons per rolling 12-month period of VOCs 0.85 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.3.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] 6 II.B.3.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.3.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. The rolling 12-month for VOCs from December 2023 to November 2024, indicated 5.6 tons, and 0.256 tons for HAPs. According to the email attachment HQ represents this facility, and FAB represents the other facility - Site ID 14197. See the attachment for additional information. II.B.3.b The owner/operator shall store VOC-containing materials and VOC-laden rags and wipes in sealed containers (except when in use). [R307-401-8] Status: In Compliance. All VOC-containing materials and used rags are kept in closed containers. 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. [R307-401-8, 40 CFR 63 Subpart ZZZZ] 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] Status: In Compliance. 3Form operates a 2010, 78 kW natural gas emergency generator engine equipped with a non-resettable hour meter. The rolling 12-month hours of operation from December 2023 to November 2024, indicated 23 hours. See the attachment for additional information. 7 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 R307. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Status: In Compliance. 3Form operates a 2010, 78 kW natural gas emergency generator engine equipped with a non-resettable hour meter. 3Form conducts regular preventive maintenance of the emergency generator. NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. Status: In Compliance. The rolling 12-month hours of operation from December 2023 to November 2024, indicated 23 hours. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-335 – Degreasing Status: In Compliance. 3Form uses Simple Green, an all-purpose cleaner and degreaser. R307-315: NOx and CO Emission Controls for Natural Gas-Fired Boilers 2.0-5.0 MMBtu Status: In Compliance. 3Form was provided information and the link to the new boiler rules which will be subject to the 9 ppm NOx limit going forward. 3Form was able to identify the boilers and their associated ratings in AO Condition II.A.3 as follows: Autoclave Boiler 1 = 4.2 MMBtu/hr Autoclave Boiler 2 = 4.2 MMBtu/hr Oil Boiler 3 = 4.99 MMBtu/hr Oil Boiler 4 = 4.99 MMBtu/hr See the email attachment for additional information. 8 EMISSION INVENTORY: Status: In Compliance. According to the 2023 Emissions Inventory, the emissions indicated compliance with the PTEs of this AO. Listed below are the Actual Emissions Inventory provided from 3form Material Solutions, Inc. - Plastic Laminate Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN140630007-22, dated March 11, 2022 is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 4007.50 --- Carbon Monoxide 14.23 0.69 Nitrogen Oxides 4.98 0.84 Particulate Matter - PM10 2.21 1.57 Particulate Matter - PM2.5 2.21 1.57 Sulfur Dioxide 0.04 0.004 Volatile Organic Compounds 24.50 3.87 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Dimethyl Phthalate (CAS #131113) 118 Ethyl Benzene (CAS #100414) 14 Ethylene Glycol (CAS #107211) 26 Formaldehyde (CAS #50000) 36 Hexamethylene-1,6-Diisocyanate (CAS #822060) 80 Hexane (CAS #110543) 2 Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 144 Hydroquinone (CAS #123319) 2 Methanol (CAS #67561) 8 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 2 Methyl Methacrylate (CAS #80626) 10 Methylene Chloride (Dichloromethane) (CAS #75092) 32 Naphthalene (CAS #91203) 10 Phenol (CAS #108952) 342 Styrene (CAS #100425) 656 Toluene (CAS #108883) 256 Trichloroethylene (CAS #79016) 6 Xylenes (Isomers And Mixture) (CAS #1330207) 42 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: 3Form Material is in compliance with the conditions in Approval Order (AO) DAQE-AN140630007-22, dated March 11, 2022. 3Form Material maintains good housekeeping practices. HPV STATUS: Not Applicable. 9 RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Required PPE includes safety glasses. This is a secure facility. It is important notify contact for access into the facility. NSR RECOMMENDATIONS: Consider including the following boilers and the associated ratings in the next AO: Autoclave Boiler 1 = 4.2 MMBtu/hr Autoclave Boiler 2 = 4.2 MMBtu/hr Oil Boiler 3 = 4.99 MMBtu/hr Oil Boiler 4 = 4.99 MMBtu/hr ATTACHMENTS: Applicable Supporting Documentation Included