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Home My WebLink AboutDAQ-2024-0073251 DAQC-289-24 Site ID 10958 (B1) MEMORANDUM TO: FILE – CERROWIRE THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: March 22, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County INSPECTION DATE: January 5, 2023 SOURCE LOCATION: 1160 West 2150 North Ogden, UT 84404 SOURCE CONTACTS: Carrie Scott; Inspection Contact cscott@cerrowire.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Cerrowire operates a wire manufacturing facility in Ogden. High purity copper rod is extruded to a desired gauge by drawing the metal through a series of dies. The wire is then made pliable by sending an electric current through the stretched wire. The stretched pliable wire is then drawn through a wire coating extruder. Palletized PVC pellets are used to cover and insulate the copper rod. Resins are forced into a heated extruder head by auger and melted at approximately 350 degrees F. The wire then passes through the heated coating extruder head at a specific speed according to coating thickness desired. Next, the wire passes through a trough full of water used for cooling and curing the insulation. The final product is then put on spools for storage, shipping, or for jacketing. The jacketing process entails bundling and wrapping the insulated wire into a PVC casing. A variety of jacketed wires are manufactured depending on the desired applications. Inks are used to print wire specifications on the wire insulation at regular intervals. The final coated wires are then trucked to the customer. Cerrowire is currently using PVC pellets for the insulation and jacketing processes, rather than resin powder. The silos that were once used to store resin powder are now used to store the pellets. The mixing compartments and chiller system have been ) 1 2 removed, as the company no longer use a powder process. Pressurized baghouses venting to the atmosphere are also no longer used as there are no powder emissions. The pellets are loaded into the silos pneumatically. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-672-97, dated August 4, 1997 SOURCE EVALUATION: General Conditions: 1. This AO applies to the following company: Cerrowire and Cable Company 1160 West 2150 North, Weber Industrial Park Ogden, UT 84404 Phone: (801) 782-4900 FAX: (801) 782-2641 Owner's Address: Cerrowire and Cable Company 1099 Thompson Road, S.E. P.O. Box 1049 Hartselle, AL 35640-1049 The equipment listed in condition number five of this AO shall be operated at the following location: 1160 West 2150 North, Weber Industrial Park Ogden, UT 84404 Universal Transverse Mercator (UTM) Coordinate System: (4,570,000) meters Northing, (416,000) meters Easting Status: In Compliance. The company name is now Cerrowire. 2. Definitions of terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Codes R307 (UAC R307), and Series 40 of the Code of Federal Regulations (40 CFR). These definitions take precedence unless specifically defined otherwise herein. Status: Not a compliance item. A statement of fact. 3. Cerro Wire and Cable Company, Inc. shall install and operate a jacketed wire manufacturing plant according to the terms and conditions of this AO as requested in the Notice of Intent dated February 9, 1996, and additional information submitted to the Executive Secretary dated June 28, 1996. Status: In Compliance. Cerrowire operates according to the conditions of this AO. 3 4. A copy of this AO shall be available on site. The AO shall be available to the employees who operate the air emission producing equipment. These employees shall receive instruction as to their responsibilities in operating the equipment according to all of the relevant conditions listed below. Status: In Compliance. A copy of the AO is available for employees to view. 5. This AO shall replace the AO dated October 12, 1993 (DAQE-0907-93). Status: In Compliance. This AO replaces the AO (DAQE-0907-93) dated October 12, 1993. 6. The approved installations shall consist of the following equipment or equivalent (5-A through 5-H refer to equipment used in the wire-jacketing process; 5-1 refers to equipment used in the wire insulating process): A. Three silos for storing resins used in the wire-jacketing process. B. *A blower transport system (544 cfm air) to load resins from rail cars into the storage silos. C. *Resin storage silo baghouse (three to be used), manufactured by the Ducon Company, Inc., Bin Vent Filter, Type UFV, MOD II, Size 80. Dimensions of these filters are as follows: 80 square feet filter area; 544 dscfm airflow rate; 6.8 fpm A/C ratio; 24 filter tubes (woven cotton sateen); 29.5" x 31.88" x 16.5" overall physical dimensions. D. An enclosed mixing compartment for mixing resins with stearic acid, calcium carbonate, plasticizer, and stabilizer. E. A chiller system to cool the mix; a blower transport system (200 cfm) to move the mix into a holding bin and hopper system; a holding bin and hopper system to contain the mix; and a forklift transport to move the mix to a melting compartment. F. *Holding bin baghouse (two to be used), manufactured by Young Industries, Inc., Model H42-6. Dimensions of these filters are as follows: 27.3 square feet filter area; 200 dscfm airflow rate; 7.33 fpm A/C ratio; six 42-inch filter tubes (13 to 15-ounce Dacron felt material); 100" x 48" x 48" overall physical dimensions. G. A melting compartment to re-melt the mix; a die to form the melting mix around the insulated wire; and a water trough cooling system. H. *PVC Blending area baghouse manufactured by Young Industries, Inc. Model YM96-54. Dimensions of these filters are as follows: 892 acfm airflow rate; 1.57:1 A/C ratio; Dacron Felt material. I. A forklift to move PVC pellets contained in Gaylord boxes; a nylon vacuum feed and a PVC pellet vacuum feed; a nylon extruder melt and a PVC extruder melt; a die to form the melt around the wire; and a water trough cooling system to cool the insulated wire. * Equivalency shall be determined by the Executive Secretary. Status: Not in Compliance. One 26kW natural gas-fired emergency generator to backup critical computer systems was installed and operational at the time of inspection. 4 Additional equipment and process information gathered at the time of inspection: • A. The three silos are located inside the building on the north side and are now used to store resin pellets which are transferred pneumatically to the melting compartments/extruders. • C. This piece of equipment is no longer in use. The resin used at the source location is now a pellet rather than a powder and there are no emissions to be controlled. • D. Previous inspection memos have indicated this equipment has been permanently removed. This was confirmed at the time of inspection. • E. Previous inspection memos have indicated this equipment has been permanently removed. This was confirmed at the time of inspection. • F. Previous inspection memos have indicated one baghouse has been permanently removed while the other is still on-site but no longer used as the source utilizes pellets rather than powder and there are no emissions to be controlled. This was confirmed at the time of inspection. • G. Previous inspections have referenced the number of melting compartments/extruders. There are no requirements in the AO limiting the number of these melting compartments/extruders. • H. Previous inspection memos have indicated this equipment has been permanently removed. This was confirmed at the time of inspection. • I. The pellets are moved pneumatically from the silos to the melting/compartments/extruders through a closed-system of pressurized tubes. The system providing the pressurized air is located on the exterior of the north side of the building in a fenced-in area. 7. The Executive Secretary shall be notified in writing upon start-up of the installation, as an initial compliance inspection is required. Eighteen months from the date of this AO the Executive Secretary shall be notified in writing of the status of construction/installation if construction/installation is not completed. At that time the Executive Secretary shall require documentation of the continuous construction/installation of the operation and may revoke the AO in accordance with R307-1-3.1.5, UAC. If construction is complete and operation has commenced a notice is not required on the status of the construction/installation. Status: In Compliance. Previous inspection memos indicate notification was submitted to the DAQ on August 25, 1997. 5 Limitations and Tests Procedures 8. Visible emissions from the following emission points shall not exceed the following values: A. All baghouses - 10% opacity B. All other points - 20% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Status: In Compliance. No visible emissions were observed at the time of inspection. There are no externally-venting baghouses or process operations currently in use at the source location as all powder-related operations have been replaced with pellets that generate no emissions. See attached VEO Form for additional information. 9. The following production limits shall not be exceeded without prior approval in accordance with R307-1-3.1, UAC: All wire products: 48,000 tons per 12-month period Compliance with the annual limitations shall be determined on a rolling 12-month total. The owner/operator shall calculate a new 12-month total based on the first day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Records of production, including rolling 12-month totals shall be made available to the Executive Secretary or her representative upon request and shall include a period of two years ending with the date of the request. The records shall be kept on a monthly basis. Status: In Compliance. Wire manufacturing activities for the rolling 12-month period through December 31, 2022, were reported at 40,249,427 lbs. (20,125 tons). See attached records for additional information. Volatile Organic Compound (VOC) and Hazardous Air Pollutants (HAPs) Limitations 10. The plant-wide emissions of VOCs from the ink and solvents used at the Cerro facility shall not exceed: 4 tons per rolling 12-month period for VOCs This value shall not be exceeded without prior approval in accordance with R307-1-3.1, UAC. Compliance with the limitation shall be determined on a rolling 12-month total. Based on the first day of each month a new 12-month total shall be calculated using data from the previous 12 months. The plant-wide emissions of VOCs emitted to the atmosphere shall be determined by maintaining a record of VOC potential contained in materials used each month. The record shall include the following data for each item used: 6 A. Name of the VOC emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, isocyanates, etc. B. The weight and use location (name of paint booth or plant facility) of the VOC potential and HAP potential of the material(s) listed in A in pounds per gallon. C. Percent by weight of all VOC potential for each individual material listed in A. The percent by weight of the VOC potentials can be obtained from the manufacturers' MSDSs. The owner/operator can obtain MSDS data from the manufacturers of the materials and retain the information on-site. D. Amount and location of materials containing VOCs used on a daily basis and summed for every location and for the entire plant each month. E. To calculate the above potentials contained in the material listed in D use the following procedure: VOC = % Volatile by Weight x [Density (lb. )] x Gal Consumed x 1 ton (100) (gal) 2000 lb. F. The amount of VOCs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above. This is done to provide the monthly total of VOC emissions. G. The cumulative total of the 12 previous months VOC emissions shall not exceed the amount specified above. H. Records of consumption of VOCs shall be kept for all periods when the plant is in operation. Records of consumption shall be made available to the Executive Secretary upon request, and shall include a period of two years ending with the date of the request. Status: In Compliance. VOC emissions from ink and solvent use were reported at 0.31 tons for the rolling 12-month reporting period through December 2022. Records of all VOC emitting materials are maintained per the requirements of this condition. Records & Miscellaneous 11. All installations and facilities authorized by this AO shall be adequately and properly maintained. Maintenance records shall be maintained while the plant is in operation. All pollution control vendor recommended equipment shall be installed, maintained, and operated. Instructions from the vendor or established maintenance practices that maximize pollution control shall be used. All necessary equipment control and operating devices, such as pressure gauges, amp meters, volt meters, flow rate indicators, temperature gauges, CEMS, etc., shall be installed and operated properly and easily accessible to compliance inspectors. A copy of all manufacturers' operating instructions for pollution control equipment and pollution emitting equipment shall be kept on site. These instructions shall be available to all employees who operate the equipment and shall be made available to compliance inspectors upon their request. Status: In Compliance. All equipment appeared to be properly operated and maintained. 7 12. The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses unavoidable breakdown reporting requirements. Any breakdown lasting longer than two hours shall be reported to the Executive Secretary within three hours of the breakdown if reasonable, but in no case longer than 18 hours after the beginning of the breakdown. During times other than normal office hours, breakdowns for any period longer than two hours shall be initially reported to the Environmental Health Emergency Response Coordinator. Within seven calendar days of the beginning of any breakdown lasting longer than two hours, a written report shall be submitted to the Executive Secretary. The owner/operator shall calculate/estimate the excess emissions (amount above AO limits) whenever a breakdown occurs. The total of excess emissions per calendar year shall be reported to the Executive Secretary as directed. Status: Not Applicable. There are no externally venting source processes capable of producing emissions associated with an unavoidable breakdown. 13. All records referenced in this AO, which are required to be kept by the owner/operator, shall be made available to the Executive Secretary or her representative upon request and shall include a period of two years ending with the date of the request. All records shall be kept for a period of two years (used oil records are to be kept for a period of three years). Examples of records to be kept at this source shall include the following as applicable: A. Production rate (Condition number 7) B. VOC emission Records (Condition number 8) C. Maintenance records (Condition number 11) D. Upset, breakdown episodes (Condition number 12) Status: In Compliance. All required records are maintained and were provided following the inspection. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-325. Ozone Nonattainment and Maintenance Areas: General Requirements Status: In Compliance. No material containing VOCs were observed to be spilled, discarded, or stored in open containers. R307-351. Graphic Arts Status: Not Applicable. The source used a combined 198 gallons of VOC-containing materials for the past 12 months. This is under the 450-gallon threshold to trigger this rule according to R307-451-3. The source maintains spreadsheets to track usage in gallons and VOC density. 8 EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions from Cerrowire on the Approval Order (AO) DAQE-672-97, dated August 4, 1997. The following information was supplied for supplemental purposes only. Estimated Criteria Pollutant Potential Emissions TSP 0.175 tons/yr PM10 0.175 tons/yr SO2 0.001 tons/yr NOx 0.428 tons/yr CO 0.031 tons/yr VOC 4.000 tons/yr The source is not currently required to submit an emissions inventory. PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Not in Compliance with the conditions of Approval Order (AO) DAQE-672-97. The source installed and operates an unpermitted 26kW natural gas-fired generator. A Compliance Advisory was issued February 1, 2023 (DAQC-081-23). The source applied for, and received, a Small Source Exemption (DAQE-EN1095004-24) and the existing AO has been revoked (DAQE-GN109580003-24). A No Further Action Letter was issued March 20, 2024 (DAQC-260-24). RECOMMENDATION FOR NEXT INSPECTION: The AO has been revoked and this source should be removed from the inspection list. ATTACHMENTS: VEO forms, Production Records January February March April May June July August September October November December Total Lbs Produced 3,428,469 3,697,265 2,636,525 2,770,797 3,987,039 3,027,066 3,420,749 3,726,399 3,124,298 4,015,466 3,496,932 2,918,422 40,249,427 Total Tons 20,125 5400FL Formula Density (lb/gal) VOC Density (lb/gal) Methyl Ethyl Ketone / Butanone Cyclohexanone n-Butyl Acetate Acetone Ethanol Isopropyl Alcohol 7- Oxabicyclo[4.1.0] heptane-3- carboxylic acid, 7- oxabicyclo[4.1.0] hept-3-yl methyl ester Titanium Dioxide 1 CLG4060 LE 6.72 6.72 3.00%95.00% 2 BKG4361 LE 7.20 6.27 83.00%8.00%3.00% 3 CLG4000 G 6.71 6.71 95.00% 4 CLG4361 LE 6.71 6.71 85.00%18.00% 5 WTG4260 LE 8.80 5.64 63.00%8.00%1% 6 EX100-G 6.59 95.00% 7 7200BR-G 7.08 0.00 83.00% 8 7200OR-G 7.06 6.03 83.00% 9 7200RD-G 7.00 0.00 83.00% 10 7200BL-G 7.02 0.00 83.00% 11 7200YL-G 6.95 6.12 83.00% 12 7200BK-G 7.04 0.00 83.00% 13 7200WT-G 7.43 5.95 83.00% 14 7200VI-G 7.06 6.06 85.00%3% 15 5410FL-G 7.80 7.51 3.00%94.00%3.00% 2022 Lbs Produced (% by Wt)