Loading...
HomeMy WebLinkAboutDAQ-2025-0046731 DAQC-CI118830002-25 Site ID 11883 (B1) MEMORANDUM TO: FILE – CAMBELT INTERNATIONAL CORP – Rubber Conveyor Systems Manufacture THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: June 12, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: November 26, 2024 SOURCE LOCATION: 2820 West 1100 South Salt Lake City, UT SOURCE CONTACTS: Cole Fox, Field Service Advisor 385-276-3815; colefox@cambelt.com Ethan Whitaker, Senior Accountant 385-276-3818; ethanwhitaker@cambelt.com OPERATING STATUS: Operating normally at time of inspection. PROCESS DESCRIPTION: Manufactures material handling equipment, such as conveyors, reclaimers, and other belting products. The east building contains a drill press, a fabricating area containing a shear, press brakes, machining equipment, steel cutting devises, welding and grinding booths, and a small spray-painting booth with particulate filters. The booth is currently used for storage. The north building contains a fabricating area, a large spray-painting booth with filters and air assisted airless sprayer, and a blasting booth that uses steel shot pellets for the blasting media with occasional nutshell usage. Blasting booth PM emissions are controlled by routing the blasting media through a triple compartment micro-pulse baghouse which is ducted back into the building. The north end of the north building is used for storage. The west building is used to process raw rubber rolls into rubber belting. The belting process equipment includes a press for forming the rubber. In the heating room oil is heated by a natural gas boiler and circulated through a closed system through Connor Kijowski 2 platters, which cures the rubber under pressure. Overhead vents remove air/smoke from over the belt press. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN118830001-12, dated September 12, 2012 SOURCE EVALUATION: Name of Permittee: Permitted Location: Cambelt International Corp- Rubber Conveyor Systems Manufacture 2820 West 1100 South 2820 West 1100 South Salt Lake City, UT 84104 Salt Lake City, UT SIC Code: 3535: (Conveyors & Conveying Equipment) 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. Each condition was reviewed with the source and appeared to be in compliance. The 2023 Emission Inventory was submitted the required date and the values can be viewed below. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Cambelt Conveyor, reclaimer and rubber belt manufacturer II.A.2 Two (2) Paint Booths Paint Booth #1 Size: 24'W x 23'H x 80'L Filter Medium: 20" x 25" x 1" fiberglass or paper Paint Booth #2 Size: 30'W x 10'H x 18'L Filter Medium: 20" x 20" x 1" fiberglass or paper II.A.3 One (1) Blasting Booth The booth is enclosed, venting back into the building Size: 24'W x 24'H x 80'L Baghouse: Mactiflo with fabric bags and grit recycle II.A.4 Natural Gas Combustion Devices One (1) Rubber Press Boiler rated at 5.2 MMBtu/hr; Approximately 90 office, shop, and water heaters rated between 0.6 to 2.0 MMBtu/hr II.A.5 Miscellaneous Ancillary Equipment and Activities Including traffic in the yard, rubber mill rubber extruder, two rubber presses, rubber flash removal, grinding, sanding, shell blasting, radial-arm saw, table saw, chop saw, oxy/acetylene-plasma cutting (wet-table and portable), degreasers, welding, etc. Status: In Compliance. No unapproved equipment was observed operating at the source location. Additional equipment and process information gathered at the time of inspection: II.A.2: Paint Booth #1 is equipped with two sets of filters and manometers that are monitored to ensure filters are changed when needed. Paint Booth #2 is still at the source location but has been out of service for several years. II.A.4 - Natural Gas Combustion Devices - The approved boiler Rubber Press Boiler was still in use at the time of inspection. It was manufactured in 1990. The source plans to replace the 5.2 MMBtu/hr heater with a Phoenix-brand thermal oil heater. The thermal oil heater was observed to be on-site but not connected. The source is currently working with New Source Review to update the AO and has locked out the new equipment until the AO has been updated. II.B Requirements and Limitations II.B.1 Plant-Wide Requirements and Limitations. II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. All natural gas combustion emission points and paint booths - 10% opacity B. All other emission points - 20% opacity. [R307-401-8] 4 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 at the time of inspection. Method 9 was utilized to verify opacity limits. See attached VEO form. II.B.1.b The following consumption limits shall not be exceeded: A. Welding Electrodes: 50,000 lb. per rolling 12-month period B. Natural Gas: 60,000 decatherms per rolling 12-month period [R307-401-8] II.B.1.b.1 Compliance with the limitations shall be determined on a rolling 12-month total. The owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. Consumption shall be determined by operator records. [R307-401-8] Status: In Compliance. Calculations are made according to this condition. Consumption totals for the January 2024 - December 2024 rolling 12-month reporting period are as follows: A. Welding Electrodes: 7,866 lbs B. Natural Gas: 5,441 decatherms II.B.2 Paint Booth Requirements and Limitations. II.B.2.a The VOC content of the paint as used in the booths shall not exceed 4.3 lbs/gal. High solids (low VOC content potential (low potential air emissions)) paints shall not be thinned or otherwise reduced beyond manufacturer's recommendations. The VOC content shall be tested if directed by the Director using the appropriate ASTM method or another method approved by the Director. [R307-340-9] Status: In Compliance. This rule has been superseded by R307-350. All paint VOC contents were reviewed during the inspection and were below the limits set forth in this condition. Refer to R307-350 in the Area Source Rules Evaluation section for more details. II.B.2.b VOC-containing materials and VOC-laden rags shall be stored in covered containers (except when in use). [R307-401-8] Status: Out of Compliance. VOC-laden rags were viewed outside of covered containers and several paint cans were open and exposed in Paint Booth #1 when it was not in use. The paint booth door was open and no site personnel were actively working in the area. A Compliance Advisory (DAQC-1269-24) and Early Settlement Agreement (DAQC-253-25) were submitted to address the issue. The source indicated they have implemented new training procedures to ensure proper work practices are followed accordingly. II.B.2.c The two paint spray booths shall each be equipped with a set of particulate filters or equivalent, to control particulate emissions. The filters shall be maintained and replaced according to manufacturer's recommendations. The date of each filter change shall be recorded. All air exiting the booth shall pass through this control system before being vented to the atmosphere. [R307-401-8] Status: In Compliance. The spray booths were observed to be properly equipped with particulate filters at the time of inspection. The booths are equipped with manometers that are monitored to ensure filters are changed when needed. Filters were last changed May 2024. Only Paint Booth #1 has been in use for the past several years. 5 II.B.2.d The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement applicators, etc. and associated operations shall not exceed: 27.52 tons per rolling 12-month period for VOCs including all HAPs 3.12 tons per rolling 12-month period for xylene 3.86 tons per rolling 12-month period for toluene 1.71 tons per rolling 12-month period for methylene chloride 2.60 tons per rolling 12-month period for methyl isobutyl ketone 0.01 tons per rolling 12-month period for glycol ethers 0.57 tons per rolling 12-month period for ethyl benzene 11.87 tons total per rolling 12-month period for all HAPs combined. [R307-401-8] Status: In Compliance. Plant-wide emissions for the January 2024 - December 2024 rolling 12-month period are as follows: 1.077 tons for VOCs including all HAPs 0.017 tons for xylene 0.108 tons for toluene 0.000 tons for methylene chloride 0.000 tons for methyl isobutyl ketone 0.000 tons for glycol ethers 0.003 tons for ethyl benzene 0.128 tons for all HAPs combined. II.B.2.d.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.d.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 x [Density ( lb )] x Gal Consumed x 1 ton 100 (gal) 2000 lb HAP = % HAP by Weight x [Density ( lb )] x Gal Consumed x 1 ton 100 (gal) 2000 lb F. The amount of VOC or HAP emitted monthly from all materials used. 6 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. Calculations are made according to this condition. The source maintains a database that tracks use of VOC and HAP-containing products in accordance with the requirements of this condition. Refer to this document in the attachments. Section III: APPLICABLE FEDERAL REQUIREMENTS No federal requirements apply at this time. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306] Status: In Compliance. All abrasive blasting is conducted in a fully enclosed blasting booth that vents internally to the building. Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: Out of Compliance. Paints were observed without closed lids and openly venting in the paint booth with the bay door open. VOC-laden rags were stored in open containers in the paint booth as well. A Compliance Advisory (DAQC-1269-24) and Early Settlement Agreement (DAQC-253-25) were submitted to address the issue. The source indicated they have implemented new training procedures to ensure proper work practices are followed accordingly. Degreasing [R307-335] Status: In Compliance. The small parts washer has a lid that is easily operated by one hand. The lid was closed at the time of inspection. Excess solvent and waste drains into a covered container. The waste tank and containers had no visible leaks and appeared to be in good operating condition. Adhesives and Sealants [R307-342] Status: In Compliance. Environmental Data Sheets were reviewed during the inspection and the applicable adhesive, sealants, and primers used at the source location are within the VOC content limits of Table 1 of this rule. Miscellaneous Metal Parts and Products Coatings [R307-350] Status: In Compliance. Environmental Data Sheets were reviewed and the applicable product coatings used at the source location are within the VOC content limits of Table 1 of this rule. 7 EMISSION INVENTORY: Listed below are the 2023 Actual Emissions Inventory provided from Cambelt International Corp - Rubber Conveyor Systems Manufacture. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AAN118830001-12-12, dated September 12, 2012, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 3706.00 N/A Carbon Monoxide 2.26 0.18 Nitrogen Oxides 3.54 0.21 Particulate Matter - PM10 4.95 0.01 Particulate Matter - PM2.5 4.95 0.01 Sulfur Dioxide 0.10 0.00 Volatile Organic Compounds 27.52 9.222 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Ethyl Benzene (CAS #100414) 1140 137.2 Glycol Ethers (CAS #EDF109) 20 N/A Methyl Isobutyl Ketone (Hexone) (CAS #108101) 5200 N/A Methylene Chloride (Dichloromethane) (CAS #75092) 3420 N/A Toluene (CAS #108883) 7720 52 Xylenes (Isomers And Mixture) (CAS #1330207) 6240 758 PREVIOUS ENFORCEMENT ACTIONS: Warning Letter (DAQC-405-22) for VOC-containing materials and rags not stored in covered containers. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN118830001-12, dated September 12, 2012, the overall status is: Out of Compliance. A Compliance Advisory (DAQC-253-25) and Early Settlement Agreement (DAQC-253-25) were issued to address noncompliance with Condition II.B.2.b and R307-325. The remaining conditions appeared to be in compliance. Records were current and made available during the inspection and via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Increase inspection frequency due to non-compliance. Safety glasses and steel-toe boots are required for the inspection. The source has still not begun to use the new Phoenix-brand heater. If it is in use, there should be an appropriate AO modification. Check for compliance with VOC-containing materials and VOC-laden rags. 8 NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form, Consumption Totals 2024, Emission Totals 2024 -STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY Page_ of_ DIVISION OF AIR QUALITY ( EPA METHOD 9-VISIBLE EMISSION OBSERVATION FORM C\ ~ ~~\ \-]:I\ \-c,~ t,O"Q , ~ , r r source Name:~ ~ 1 ~ -ru\.;,w&,f\vc.,or OBSERVATION DATE: I ?& '2-~ -SaailJil ' ~ ~1SkM.S ~reet Address: UZ-0 \)irec..\or,s &w Start time: ___ Stop time: --- _0.ty/County: Salt lart.. C{¼ I s~,+ ~k phone: Site ID: \ \~:, Equipment/Process: ~ y,Ai-fknMA I Bl~", f:oc¼ , e,.)JV Control Equipment: ~, \'\<rs 1 ~'j\.,,cysg_. Emission Point: S.\-,toc Sky Conditions: Clear I ] Partly Cloudy I ] Overcast I l Precipitation: No I ] Yes I ] Wind: Direction: ___ Speed: __ _ mph Ambient Temp: °F RH: ___ % Height Relative to Observer: --- Distance From Observer: --- Condensed Water Vapor Present: No I ] Yes [ ] Attached I l Detached [ l Length of Condensed Water Vapor Plume: _____ _ Background: ______________ _ Sketch process unit: indicate observer position relative to source; indicate potential emission points and/or actual emission points. 0 • observer ---- Sun i Wind ► Emission Point with Plume ~ Observer Position X Observer's Signature: Distrib: white-file; canary-inspector; pink-owner/operator ~c 0 15 30 45 mm 1 2 -- 3 l" j -✓ ~ 4 5 ~ .... 6 7 8 9 10 11 12 ~il,,"4:J \ '2 • Iv"" k.. P~, ,-.," NWU4~r V>'l3 -°'-.i {cry COMMENTS: tl {3./ .'9 '. Wddi11j ~lcd,"NS gry) Ne1h;,,,I G1;r G,~,Svaj ~r /!o11;,-J (i,,-~1-w) -r>o.11!V'7IL of Accc;;aflt,y,~7 U-.6.:z.,. 9 : \Joe C,.,\~qi~ oF 70,nJ.. o&d i'l bxrl½s Jt.13.z.cA ~ Pl(./1+-&,.J•c-~ tM;5s,·or,J a£ /;s~.A Ue<:...s ~ HAP1 6'r P-c11;,j 1"2-MM~( -/;'(~,,..zlc. o( A,,_,,~ ... r,'7 ~;P,-)tt 7,,: VC(, c>-.1.,,d-of ~"'"' A,tt-?.Slu. } &,.Jc..+ ~-?_:f() ~ voc (<A\-ql-;>C Cucl-\ Cd'Qr"') ~:Cl. ~QI·. Not ( Ne \,c, cf ..J nb~\ ~~11 lv.s ~( /\t.kl £Lil'"'•"'~ \Y'--u,.,<1lc,;11+uikr. N1u;I kt:-L(_ ')c'<.J ~~11 Racrtf<:. k O?r'~oa.vsb e vh"'• J¢V kx; _ _ t) u eM'i:>er l O I toz"j. : have received a copy of these observations: SIGNATURE t~tJ~ Plant Consumption of DAQ Reportable Mat. Description Jan-24 Feb-24 Mar-24 Apr-24 May-24 Jun-24 Jul-24 Aug-24 Sep-24 Oct-24 Nov-24 Dec-24 Dual Shield Weld Wire (lbs) FC (flux core) 356.4 0 534.6 0 356.4 0 356.4 0 356.4 0 713.43 0 2,674 Pounds Hard Weld Wire (lbs) 70S6 519.2 103.84 415.36 519.2 519.2 623.04 415.36 311.52 415.36 311.52 623.04 415.36 5,192 Pounds Stainless Steel Hard Wire Weld Wire (lbs) 0 0 0 0 0 0 0 0 0 0 0 0 0 Pounds Natural Gas (Decatherms) 1240.3 1252.3 947.5 608.2 304.2 17.4 160.2 167.7 184.7 185.2 373 5,441 Decath. Kerosene (Gal.) 0 0 0 0 0 0 0 0 0 0 0 0 0 Gallons Diesel Fuel (Gal.) 100 0 0 0 100 0 0 0 0 100 0 300 Gallons Propane (Gal.) 395 0 0 407.9 0 0 255.4 0 0 0 428 0 1,486 Gallons Hydraulic Oil (Gal.) 0 0 0 275 0 0 276 0 0 0 0 0 551 Gallons G50 Blast Media (LBS.) 0 0 0 0 0 0 0 0 0 0 0 0 0 Pounds Nutshell Blast Media (LBS.) 0 0 0 0 0 0 0 0 0 0 0 0 0 Pounds Rolling Totals for 2024 12 Mon. Totals Xylene 10 94 1 3 6 8 0 3 7 4 5 0 3 3 2 2 5 6 6 5 0 2 0 Toluene 0 72 0 0 0 0 0 0 0 0 0 0 0 0 0 180 0 0 0 36 0 0 0 Methylene Chloride 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 MIBK 0 51 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Glycol Ethers 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0Ethyl Benzene 2 17 0 1 2 2 0 1 2 1 1 0 0 1 0 0 1 1 1 1 0 0 0 Total HAPs 12 233 1 4 8 10 0 3 9 4 6 0 3 3 2 182 6 7 8 41 0 2 0 VOCs 0 1,222 3 110 341 521 0 59 322 379 276 0 0 274 73 568 94 464 292 334 1 53 0 Xylene 0.056 0.094 0.086 0.079 0.077 0.075 0.071 0.067 0.071 0.070 0.072 0.070 0.067 0.021 0.022 0.021 0.020 0.019 0.023 0.024 0.020 0.019 0.017Toluene0.023 0.059 0.059 0.058 0.058 0.058 0.054 0.054 0.036 0.036 0.036 0.036 0.036 0.000 0.000 0.090 0.090 0.090 0.090 0.108 0.108 0.108 0.108 Methylene Chloride 0.039 0.039 0.020 0.020 0.020 0.020 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 MIBK 0.000 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Glycol Ethers 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000Ethyl Benzene 0.006 0.013 0.013 0.012 0.012 0.013 0.013 0.013 0.013 0.013 0.014 0.013 0.013 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.003 Total HAPs 0.124 0.231 0.202 0.194 0.192 0.191 0.163 0.159 0.146 0.145 0.146 0.145 0.140 0.026 0.026 0.115 0.114 0.113 0.117 0.136 0.132 0.131 0.128 VOCs 1.379 1.837 1.574 1.476 1.491 1.619 1.581 1.364 1.507 1.515 1.617 1.617 1.617 1.143 1.178 1.407 1.283 1.255 1.401 1.539 1.379 1.215 1.077 1) The formula in the "pounds/month" cells work as follows: usage cell and corresponding product cell are muliplied for each separate Welding: 50,000 lbs per 12-month rolling period Hazardous Air Polutant (HAP), then the formula sums the entire column for each month.Nat Gas: 60,000 decatherms per rolling 12-month period Kerosene: Kerosene: 2,000 gallons per rolling 12-month period 2) The formula in the "rolling totals" cells work as follows: current month and previous 11 months for each HAP in the "Pounds/Month" Diesel: 5,000 gallons per rolling 12-month period table are sumed and divided by 2000 for total tons for each rolling 12 month period. Propane: 5,000 gallons per rolling 12-month period VOC limit 27.52 tons per rolling 12-month period 27.52 OK Xylene 3.12 tons per rolling 12-month period 3.120 OKToluene 3.86 tons per rolling 12-month period 3.86 OK Methylene Chloride 1.71 tons per rolling 12-month period 1.71 OK - enter these last values from last year spreadsheet MEK 3.15 tons per rolling 12-month period (delisted in 2007) MIBK 2.60 tons per rolling 12-month period 2.6 OK Glycol Eth .01 tons per rolling 12-month period 0.01 OK Ethyl Ben .57 tons per rolling 12-month period 0.57 OKTot HAP's 13.07 tons per rolling 12-month period 13.07 OK OCT23 CAMBELT INTERNATIONAL CORP. 2023 - 24 DEC24NOV24OCT24SEP24AUG24JUL24JUN24MAY24APR24MAR24FEB24JAN24DEC23NOV23MAR23FEB23POUNDS/MONTH . DEC24NOV24OCT24SEP24AUG24JUL24 SEP23AUG23JUL23JUN23MAY23APR23 MAY24APR24MAR24FEB24JAN24 12 MONTH ROLLING TOTALS - HAPs, TOTAL HAPs & VOCs (Pounds & Tons) CAMBELT'S AIR QUALITY PERMIT LIMITS JUN23MAY23APR23MAR23FEB23ROLLING TOTALS TONS/YEAR DEC23NOV23OCT23SEP23AUG23JUL23 JUN24