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HomeMy WebLinkAboutDAQ-2025-005399 DAQE-AN118290017-25 {{$d1 }} Derek Terry Detroit Diesel Remanufacturing, LLC 100 Lodestone Way Tooele, UT 84074 derek.terry@daimlertruck.com Dear Mr. Terry: Re: Approval Order: Minor Modification to Approval Order DAQE-AN118290014-20 to Add Missing Equipment and a New Fuel Tank Manufacturing Line Project Number: N118290017 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on April 1, 2025. Detroit Diesel Remanufacturing, LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is John Persons, who can be contacted at (385) 306-6503 or jpersons@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:JP:jg cc: Tooele County Health Department EPA Region 8 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director October 21, 2025 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN118290017-25 Minor Modification to Approval Order DAQE-AN118290014-20 to Add Missing Equipment and a New Fuel Tank Manufacturing Line Prepared By John Persons, Engineer (385) 306-6503 jpersons@utah.gov Issued to Detroit Diesel Remanufacturing, LLC Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality October 21, 2025 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 10 ACRONYMS ............................................................................................................................... 11 DAQE-AN118290017-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Detroit Diesel Remanufacturing, LLC Detroit Diesel Remanufacturing, LLC Mailing Address Physical Address 100 Lodestone Way 100 Lodestone Way Tooele, UT 84074 Tooele, UT 84074 Source Contact UTM Coordinates Name: Derek Terry 385,700 m Easting Phone: (435) 843-6034 4,487,400 m Northing Email: derek.terry@daimlertruck.com Datum NAD83 UTM Zone 12 SIC code 3519 (Internal Combustion Engines, NEC) SOURCE INFORMATION General Description Detroit Diesel Remanufacturing, LLC (DDR) operates an engine remanufacturing and fuel tank manufacturing facility in Tooele. The engine remanufacturing facility receives, disassembles, cleans, and manufactures diesel engines and engine components. Some completed engines are tested before being shipped. The fuel tank manufacturing line assembles new fuel tanks. The facility operates paint booths and welding, sandblasting, grinding, and plasma cutting operations. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: SM Applicable Federal Standards MACT (Part 63), A: General Provisions MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities DAQE-AN118290017-25 Page 4 Project Description DDR has requested to add a new fuel tank manufacturing line consisting of six (6) welding stations and one (1) polishing station. Additionally, some missing equipment that was found onsite during a compliance inspection is being added to the permit. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 360 11158.00 Carbon Monoxide 0.26 10.84 Nitrogen Oxides 0.30 38.49 Particulate Matter - PM10 0.51 6.63 Particulate Matter - PM2.5 0.51 6.63 Sulfur Dioxide 0 1.09 Volatile Organic Compounds 0.02 17.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Chromium Compounds (CAS #CMJ500) 0 134 Ethyl Benzene (CAS #100414) 0 3140 Generic HAPs (CAS #GHAPS) 0 140 Manganese Compounds (CAS #MAR500) 0 30 Nickel Compounds (CAS #NDB000) 0 60 Change (TPY) Total (TPY) Total HAPs 0 1.75 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] DAQE-AN118290017-25 Page 5 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] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Detroit Diesel Remanufacturing, LLC II.A.2 Maintenance Cartridge Dust Collector Controls fumes from MIG welding II.A.3 Once Box Cartridge Dust Collector Controls fumes from plasma cutting II.A.4 Glass Beader Baghouse Controls emissions from six (6) glass bead abrasive blaster units II.A.5 Spinner/Hanger External Dust Collector II.A.6 Double Table Blaster External Dust Collector II.A.7 Two (2) Tumble Blasters Vent to internal dust collector II.A.8 Steel Shot Blaster Vents to internal dust collector II.A.9 Various Degreasing Tanks Contents: solvent-based cleaner II.A.10 Engine Test Cells Fourteen (14) total /six (6) operational DAQE-AN118290017-25 Page 6 II.A.11 Six (6) Thermal Cleaning Ovens Equipped with afterburners Maximum rating: 2.25 MMbtu/hr (each) Fuel: Natural Gas II.A.12 Two (2) Paint Booths II.A.13 Proceco Parts Washer II.A.14 Various Heaters Includes: Parts Washer heater Maximum rating: less than 5.00 MMBtu/hr (each) II.A.15 Various Non-volatile Degreasing Tanks For informational purposes only II.A.16 TAC Welding Operations For informational purposes only II.A.17 Waste Water Treatment For informational purposes only II.A.18 Cooling Tower Rating: 250 Gal/min Controls: High Efficiency Drift Eliminator II.A.19 Four (4) HVAC units Rating: 10 MMBtu/hr each Fuel: Natural Gas II.A.20 Two (2) Storage Tanks Storage Tank 1 Capacity: 7,000 gallons Contents: Diesel Fuel Storage Tank 2 Capacity: 150 Gallons Contents: Ultra Low Sulfur Diesel MACT Applicability: Subpart CCCCCC II.A.21 Five (5) Blow-off Tables II.A.22 Five (5) Dust Collectors Controls emissions from blow-off tables II.A.23 Miscellaneous Combustion Equipment Rating: <5MMBtu/hr *Included for informational purposes only II.A.24 Two (2) Robotic Weld Stations Control: Dust Collection System II.A.25 Four (4) Manual Weld Stations Control: Dust Collection System DAQE-AN118290017-25 Page 7 II.A.26 Polishing Station Control: Dust Collection System II.A.27 Two (2) Drying Ovens Rated at 0.35 MMBtu/hr each Fuel: Natural Gas II.A.28 One (1) Dust Collection System Control emissions from welding and polishing on the fuel tank manufacturing line II.A.29 Three (3) Dust Collection Systems Two (2) exhausted internally and one (1) externally SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary or fugitive emission source on site to exceed 10 percent 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. [R307-201-3] II.B.1.b The owner/operator shall use only natural gas as a primary fuel and propane as a backup fuel in the building space/process heating. Appropriate fuels may be used in equipment being tested and in small auxiliary mobile equipment associated with the facility. [R307-401-8(1)(a)] II.B.1.c The owner/operator shall not exceed the following site-wide fuel limitations per rolling 12-month period: A. Natural gas - 40 MMscf B. Propane -10,000 gallons. [R307-401-8] II.B.1.c.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 of consumption shall be kept for all periods when the plant is in operation. The consumption shall be determined by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis. [R307-401-8] II.B.1.d The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 17.08 tons per rolling 12-month period of VOCs 1.75 tons per rolling 12-month period of all HAPs combined. [R307-401-8] DAQE-AN118290017-25 Page 8 II.B.1.d.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] II.B.1.d.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.1.d.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] II.B.1.e The owner/operator shall cover solvent tanks when not in use. [R307-401-8] II.B.1.f The owner/operator shall conduct all degreasing operations in accordance with the requirements of R307-335. [R307-335] II.B.1.g The paint spray booths shall be equipped with a set of paint arrestor particulate filters, or equivalent, to control particulate emissions. Air exiting the booths shall pass through this control system before being vented to the atmosphere (outside the building/operation). [R307-401-8] II.B.1.h The owner/operator shall install all fuel storage tanks with submerged fill pipes. The owner/operator shall operate the storage tanks in a way that minimizes working and breathing losses from the tank. [R307-401-8] II.B.2 All blaster cleaners on site shall be subject to the following: II.B.2.a The owner/operator shall control particulate emissions with the applicable dust collection equipment indicated in the equipment list at all times when blasting is taking place. [R307-401] II.B.3 All engine test cells on site shall be subject to the following: II.B.3.a The approved engine test cells shall consist of four (4) 600 hp Dyno engines and two (2) 4,000 hp Dyno engines. Only one (1) of the 4,000 hp Dyno engines shall run at any one time. [R307-401] DAQE-AN118290017-25 Page 9 II.B.3.b The owner/operator shall use #1, #2, or a combination of #1 and #2 diesel fuel as fuel in the engine test cells. [R307-401] II.B.3.c The owner/operator shall not exceed the following diesel fuel limitations for engine testing per rolling 12-month period: A. 600 hp engines - 47,000 gallons (combined) B. 4,000 hp engines - 100,000 gallons (combined). [R307-401-8] II.B.3.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th of each month using data from the previous 12 months. Fuel consumption for the engine test cells shall be determined by the use of operations records. [R307-401-8] II.B.3.d The owner/operator shall not allow visible emissions from any stationary engine on site to exceed 20 percent opacity. [R307-201] II.B.4 All thermal cleaning ovens on site shall be subject to the following: II.B.4.a The thermal cleaning ovens shall operate up to a temperature of 1,100 degrees Fahrenheit as needed. Each oven shall be equipped with an afterburner. The operating temperature of the afterburner shall be no less than 1,400 degrees Fahrenheit. Each afterburner shall operate whenever parts are being baked. [R307-401] II.B.4.a.1 The temperatures cited in the above condition shall be monitored on all six (6) ovens with equipment located such that an inspector can, at any time, safely read the output. All readings shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated against the manufacturer's specification at least once every 12-month period. [R307-401] II.B.5 The Proceco parts washer shall be subject to the following: II.B.5.a The Proceco parts washer shall not exceed an operating temperature of 210 degrees Fahrenheit. [R307-401-8] II.B.5.a.1 The temperatures cited in the above condition shall be monitored with equipment located such that an inspector or operator can, at any time, safely read the output. All readings shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated against the manufacturer's specification at least once every 12-month period. [R307-401] II.B.6 Cooling Tower Requirements II.B.6.a The owner/operator shall install and operate high efficiency drift eliminators to control particulate matter from the cooling tower. [R307-401-8] II.B.7 Dust Collector Requirements II.B.7.a The owner/operator shall route all the emissions from the blow off tables, welding operations, and polishing operations to a baghouse or dust collection system before being vented to the atmosphere. [R307-401-8] II.B.7.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the baghouse and dust collection system. [R307-401-8] II.B.7.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] DAQE-AN118290017-25 Page 10 II.B.7.b.2 The pressure gauge shall measure the pressure drop in 1 inch water column increments or less. [R307-401-8] II.B.7.c During operation of the baghouse or dust collection system, the owner/operator shall maintain the static pressure drop across the baghouse or dust collection system between one (1) and four (4) inches of water column. [R307-401-8] II.B.7.c.1 The owner/operator shall record the pressure drop at least once per operating day while the baghouse or dust collection system is operating. [R307-401-8] II.B.7.c.2 The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification; B. Manufacturer recommended static pressure drop for the unit (if applicable); C. Date of reading; D. Daily static pressure drop readings. [R307-401-8] II.B.7.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8] II.B.7.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Replaces AO DAQE-AN118290014-20 dated December 24, 2020 Is Derived From NOI dated April 1, 2025 Incorporates Additional Information dated May 12, 2025 Incorporates Additional Information dated May 13, 2025 Incorporates Additional Information dated May 15, 2025 DAQE-AN118290017-25 Page 11 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds 1 DAQE-MN118290017-25 M E M O R A N D U M TO: 11829: Detroit Diesel Remanufacturing, LLC THROUGH: Jon Black, Major NSR Manager – Air Quality FROM: John Persons, Environmental Engineer – Air Quality DATE: October 10, 2025 SUBJECT: Intent to Approve DAQE-IN118290017-25 Project Description DAQ Error The Utah Division of Air Quality (DAQ) held a 30-day public comment period for the Intent to Approve (ITA) DAQE-IN118290017-25 for Detroit Diesel Remanufacturing, LLC’s minor modification at its engine remanufacturing facility. The “Project Description” and “General Description” sections had not been updated by the DAQ before the ITA went to public comment. This was realized internally after the public comment period. As a result, of this, the project description was updated to reflect the current minor modification. The updated project description reads as follows: “Detroit Diesel Remanufacturing, LLC has requested to add a new fuel tank manufacturing line consisting of six (6) welding stations and one (1) polishing station. Additionally, some missing equipment that was found onsite during a compliance inspection is being added to the permit. Additionally, the “General Description” was also updated to include a sentence about the new fuel tank manufacturing line. The updated general description reads: “Detroit Diesel Remanufacturing, LLC (DDR) operates an engine remanufacturing and fuel tank manufacturing facility in Tooele. The engine remanufacturing facility receives, disassembles, cleans, and manufactures diesel engines and engine components. Some completed engines are tested before being shipped. The fuel tank manufacturing line assembles new fuel tanks. The facility operates paint booths, welding, sandblasting, grinding, and plasma cutting operations.” All other elements of Detroit Diesel Remanufacturing, LLC’s permit were correctly updated in DAQE-IN118290017-25 to reflect the changes requested in the NOI. Because there were no emissions, equipment, or permit condition changes as a result of this error, the DAQ will finalize and approve the above-referenced ITA. 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director JP JP Jon Black Tooele Transcript-Bulletin Publication Name: Tooele Transcript-Bulletin Publication URL: www.tooeletranscript.com Publication City and State: Tooele, UT Publication County: Tooele Notice Popular Keyword Category: Notice Keywords: detroit Notice Authentication Number: 202508281010366303236 2273419277 Notice URL: Back Notice Publish Date: Wednesday, August 27, 2025 Notice Content PUBLIC NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Detroit Diesel Remanufacturing, LLC Location: Detroit Diesel Remanufacturing, LLC � 100 Lodestone Way, Tooele, UT Project Description: Detroit Diesel Remanufacturing, LLC (DDR) is requesting several changes to their permit. DDR has requested to add a new fuel tank manufacturing line consisting of a six (6) welding station and one (1) polishing station. Additionally, some missing equipment that was found onsite during a compliance inspection is going to be added to the permit. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before September 26, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at jpersons@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: August 27, 2025 (Published in the Tooele Transcript Bulletin August 27, 2025) Back 8/28/25, 9:10 AM utahlegals.com/(S(kwvblhblgddjrlvomqd51gzl))/DetailsPrint.aspx?SID=kwvblhblgddjrlvomqd51gzl&ID=221712 https://www.utahlegals.com/(S(kwvblhblgddjrlvomqd51gzl))/DetailsPrint.aspx?SID=kwvblhblgddjrlvomqd51gzl&ID=221712 1/1 DAQE-IN118290017-25 August 25, 2025 Derek Terry Detroit Diesel Remanufacturing, LLC 100 Lodestone Way Tooele, UT 84074 derek.terry@daimlertruck.com Dear Mr. Terry: Re: Intent to Approve: Minor Modification to Approval Order DAQE AN118290014-20 to Add Missing Equipment and a New Fuel Tank Manufacturing Line Project Number: N118290017 The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is subject to public review. Any comments received shall be considered before an Approval Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO. Future correspondence on this ITA should include the engineer's name, John Persons, as well as the DAQE number as shown on the upper right-hand corner of this letter. John Persons, can be reached at (385) 306-6503 or jpersons@utah.gov, if you have any questions. Sincerely, {{$s }} Jon L. Black, Manager New Source Review Section JLB:JP:jg cc: Tooele County Health Department EPA Region VIII 8 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director Jon Black (Aug 21, 2025 23:07:26 MDT) STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN118290017-25 Minor Modification to Approval Order DAQE AN118290014-20 to Add Missing Equipment and a New Fuel Tank Manufacturing Line Prepared By John Persons, Engineer (385) 306-6503 jpersons@utah.gov Issued to Detroit Diesel Remanufacturing, LLC Issued On August 25, 2025 {{$s }} New Source Review Section Manager Jon L. Black {{#s=Sig_es_:signer1:signature}} Jon Black (Aug 21, 2025 23:07:26 MDT) TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 PUBLIC NOTICE STATEMENT............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 8 PERMIT HISTORY ................................................................................................................... 11 ACRONYMS ............................................................................................................................... 12 DAQE-IN118290017-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Detroit Diesel Remanufacturing, LLC Detroit Diesel Remanufacturing, LLC Mailing Address Physical Address 100 Lodestone Way 100 Lodestone Way Tooele, UT 84074 Tooele, UT 84074 Source Contact UTM Coordinates Name: Derek Terry 385,700 m Easting Phone: (435) 843-6034 4,487,400 m Northing Email: derek.terry@daimlertruck.com Datum NAD83 UTM Zone 12 SIC code 3519 (Internal Combustion Engines, NEC) SOURCE INFORMATION General Description Detroit Diesel Remanufacturing, LLC (DDR) operates an engine remanufacturing plant in Tooele. The facility receives disassembles, cleans, and manufactures diesel engines and engine components. Some completed engines are tested before being shipped. The facility operates paint booths and welding, sandblasting, grinding, and plasma cutting operations as part of the remanufacturing process. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: B Applicable Federal Standards MACT (Part 63), A: General Provisions MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities DAQE-IN118290017-25 Page 4 Project Description DDR is requesting a modification to add equipment and a new production line, updating their emissions along with the new equipment. The following changes have been made to the equipment list: 1. Added a cooling tower. 2. Added four (4) HVAC units. 3. Added two (2) fuel storage tanks. 4. Added a dust collector. 5. Added a new Diesel Particulate Filter line, including associated three (3) burn-off ovens and two (2) drying ovens powered by natural gas. 6. Added four (4) blow-off tables with associated dust collectors. 7. Changed the equipment list to remove the number of solvent tanks allowed and altered equipment item to state "various degreasing tanks." The following changes were made to the facility’s permit requirements: 1. Decreased fuel limit in conditions II.B.3.c from 50,000 gallons to 47,000 gallons for 600 hp engines. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 360 11158.00 Carbon Monoxide 0.26 10.84 Nitrogen Oxides 0.30 38.49 Particulate Matter - PM10 0.51 6.63 Particulate Matter - PM2.5 0.51 6.63 Sulfur Dioxide 0 1.09 Volatile Organic Compounds 0.02 17.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Chromium Compounds (CAS #CMJ500) 0 134 Ethyl Benzene (CAS #100414) 0 3140 Generic HAPs (CAS #GHAPS) 0 140 Manganese Compounds (CAS #MAR500) 0 30 Nickel Compounds (CAS #NDB000) 0 60 Change (TPY) Total (TPY) Total HAPs 0 1.75 DAQE-IN118290017-25 Page 5 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Tooele Transcript on August 27, 2025. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comments. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period, and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. 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] DAQE-IN118290017-25 Page 6 I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT II.A.1 Detroit Diesel Remanufacturing, LLC II.A.2 Maintenance Cartridge Dust Collector Controls fumes from MIG welding II.A.3 Once Box Cartridge Dust Collector Controls fumes from plasma cutting II.A.4 Glass Beader Baghouse Controls emissions from six (6) glass bead abrasive blaster units II.A.5 Spinner/Hanger External Dust Collector II.A.6 Double Table Blaster External Dust Collector II.A.7 Two (2) Tumble Blasters vent to internal dust collector II.A.8 Steel Shot Blaster Vents to internal dust collector II.A.9 Various Degreasing Tanks Contents: solvent-based cleaner II.A.10 Engine Test Cells Fourteen (14) total /six (6) operational II.A.11 Six (6) Thermal Cleaning Ovens equipped with afterburners Maximum rating: 2.25 MMbtu/hr (each) Fuel: Natural Gas II.A.12 Two (2) Paint Booths II.A.13 Proceco Parts Washer II.A.14 Various Heaters Includes: Parts Washer heater Maximum rating: less than 5.00 MMBtu/hr (each) DAQE-IN118290017-25 Page 7 II.A.15 Various Non-volatile Degreasing Tanks For informational purposes only II.A.16 TAC Welding Operations For informational purposes only II.A.17 Wastewater Treatment For informational purposes only II.A.18 Cooling Tower Rating: 250 Gal/min Controls: High Efficiency Drift Eliminator II.A.19 Four (4) HVAC units Rating: 10 MMBtu/hr each Fuel: Natural Gas II.A.20 Two (2) Storage Tanks Storage Tank 1 Capacity: 7,000 gallons Contents: Diesel Fuel Storage Tank 2 Capacity: 150 Gallons Contents: Ultra Low Sulfur Diesel MACT Applicability: Subpart CCCCCC II.A.21 Five (5) Blow-off Tables II.A.22 Five (5) Dust Collectors Controls emissions from blow-off tables II.A.23 Miscellaneous Combustion Equipment Rating: <5MMBtu/hr *Included for informational purposes only II.A.24 Two (2) Robotic Weld Stations Control: Dust Collection System II.A.25 Four (4) Manual Weld Stations Control: Dust Collection System II.A.26 Polishing Station Control: Dust Collection System II.A.27 Two (2) Drying Ovens Rated at 0.35 MMBtu/hr each Fuel: Natural Gas II.A.28 One (1) Dust Collection System Control emissions from welding and polishing on the fuel tank manufacturing line II.A.29 Three (3) Dust Collection Systems Two exhausted internally and one externally DAQE-IN118290017-25 Page 8 SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary or fugitive emission source on site to exceed 10 percent 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. [R307-201-3] II.B.1.b The owner/operator shall use only natural gas as a primary fuel and propane as a backup fuel in the building space/process heating. Appropriate fuels may be used in equipment being tested and in small auxiliary mobile equipment associated with the facility. [R307-401-8(1)(a)] II.B.1.c The owner/operator shall not exceed the following site-wide fuel limitations per rolling 12-month period: A. Natural gas - 40 MMscf B. Propane -10,000 gallons. [R307-401-8] II.B.1.c.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 of consumption shall be kept for all periods when the plant is in operation. The consumption shall be determined by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis. [R307-401-8] II.B.1.d The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 17.08 tons per rolling 12-month period of VOCs 1.75 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.1.d.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] DAQE-IN118290017-25 Page 9 II.B.1.d.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.1.d.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] II.B.1.e The owner/operator shall cover solvent tanks when not in use. [R307-401-8] II.B.1.f The owner/operator shall conduct all degreasing operations in accordance with the requirements of R307-335. [R307-335] II.B.1.g The paint spray booths shall be equipped with a set of paint arrestor particulate filters, or equivalent, to control particulate emissions. Air exiting the booths shall pass through this control system before being vented to the atmosphere (outside the building/operation). [R307-401-8] II.B.1.h The owner/operator shall install all fuel storage tanks with submerged fill pipes. The owner/operator shall operate the storage tanks in a way that minimizes working and breathing losses from the tank. [R307-401-8] II.B.2 All blaster cleaners on site shall be subject to the following: II.B.2.a The owner/operator shall control particulate emissions with the applicable dust collection equipment indicated in the equipment list at all times when blasting is taking place. [R307-401] II.B.3 All engine test cells on site shall be subject to the following: II.B.3.a The approved engine test cells shall consist of four (4) 600 hp Dyno engines and two (2) 4,000 hp Dyno engines. Only one (1) of the 4,000 hp Dyno engines shall run at any one time. [R307-401] II.B.3.b The owner/operator shall use #1, #2, or a combination of #1 and #2 diesel fuel as fuel in the engine test cells. [R307-401] DAQE-IN118290017-25 Page 10 II.B.3.c The owner/operator shall not exceed the following diesel fuel limitations for engine testing per rolling 12-month period: A. 600 hp engines - 47,000 gallons (combined) B. 4,000 hp engines - 100,000 gallons (combined). [R307-401-8] II.B.3.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th of each month using data from the previous 12 months. Fuel consumption for the engine test cells shall be determined by the use of operations records. [R307-401-8] II.B.3.d The owner/operator shall not allow visible emissions from any stationary engine on site to exceed 20 percent opacity. [R307-201] II.B.4 All thermal cleaning ovens on site shall be subject to the following: II.B.4.a The thermal cleaning ovens shall operate up to a temperature of 1,100 degrees Fahrenheit as needed. Each oven shall be equipped with an afterburner. The operating temperature of the afterburner shall be no less than 1,400 degrees Fahrenheit. Each afterburner shall operate whenever parts are being baked. [R307-401] II.B.4.a.1 The temperatures cited in the above conditions shall be monitored on all six (6) ovens with equipment located such that an inspector can, at any time, safely read the output. All readings shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated against the manufacturer's specification at least once every 12-month period. [R307-401] II.B.5 The Proceco parts washer shall be subject to the following: II.B.5.a The Proceco parts washer shall not exceed an operating temperature of 210 degrees Fahrenheit. [R307-401-8] II.B.5.a.1 The temperatures cited in the above condition shall be monitored with equipment located such that an inspector or operator can, at any time, safely read the output. All readings shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated against the manufacturer's specification at least once every 12-month period. [R307-401] II.B.6 Cooling Tower Requirements II.B.6.a The owner/operator shall install and operate high-efficiency drift eliminators to control particulate matter from the cooling tower. [R307-401-8] II.B.7 Dust Collector Requirements II.B.7.a The owner/operator shall route all the emissions from the blow-off tables, welding operations, and polishing operations to a baghouse or dust collection system before being vented to the atmosphere. [R307-401-8] II.B.7.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the baghouse and dust collection system. [R307-401-8] II.B.7.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.7.b.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8] DAQE-IN118290017-25 Page 11 II.B.7.c During operation of the baghouse or dust collection system, the owner/operator shall maintain the static pressure drop across the baghouse or dust collection system between 1 and 4 inches of water column. [R307-401-8] II.B.7.c.1 The owner/operator shall record the pressure drop at least once per operating day while the baghouse or dust collection system is operating. [R307-401-8] II.B.7.c.2 The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification; B. Manufacturer-recommended static pressure drop for the unit (if applicable); C. Date of reading; D. Daily static pressure drop readings. [R307-401-8] II.B.7.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8] II.B.7.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Replaces AO DAQE AN118290014-20 dated December 24, 2020 Is Derived From NOI dated April 1, 2025 Incorporates Additional Information dated May 12, 2025 Incorporates Additional Information dated May 13, 2025 Incorporates Additional Information dated May 15, 2025 DAQE-IN118290017-25 Page 12 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE-NN118290017-25 August 25, 2025 Tooele Transcript Legal Advertising Dept. 58 North Main Tooele, UT 84074 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Tooele Transcript on August 27, 2025. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Tooele County cc: Wasatch Front Regional Council 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN118290017-25 Page 2 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Detroit Diesel Remanufacturing, LLC Location: Detroit Diesel Remanufacturing, LLC – 100 Lodestone Way, Tooele, UT Project Description: Detroit Diesel Remanufacturing, LLC (DDR) is requesting several changes to their permit. DDR has requested to add a new fuel tank manufacturing line consisting of a six (6) welding station and one (1) polishing station. Additionally, some missing equipment that was found onsite during a compliance inspection is going to be added to the permit. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before September 26, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at jpersons@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: August 27, 2025 {{#s=Sig_es_:signer1:signature}} DAQE- RN118290017 August 18, 2025 Derek Terry Detroit Diesel Remanufacturing, LLC 100 Lodestone Way Tooele, UT 84074 derek.terry@daimlertruck.com Dear Derek Terry, Re: Engineer Review: Minor Modification to Approval Order DAQE AN118290014-20 to Add Missing Equipment and a New Fuel Tank Manufacturing Line Project Number: N118290017 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Detroit Diesel Remanufacturing, LLC should complete this review within 10 business days of receipt. Detroit Diesel Remanufacturing, LLC should contact John Persons at (385) 306-6503 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email John Persons at jpersons@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Detroit Diesel Remanufacturing, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Detroit Diesel Remanufacturing, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N118290017 Owner Name Detroit Diesel Remanufacturing, LLC Mailing Address 100 Lodestone Way Tooele, UT, 84074 Source Name Detroit Diesel Remanufacturing, LLC Source Location 100 Lodestone Way Tooele, UT 84074 UTM Projection 385,700 m Easting, 4,487,400 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3519 (Internal Combustion Engines, NEC) Source Contact Derek Terry Phone Number (435) 843-6034 Email derek.terry@daimlertruck.com Billing Contact Derek Terry Phone Number 4358436034 Email derek.terry@daimlertruck.com Project Engineer John Persons, Engineer Phone Number (385) 306-6503 Email jpersons@utah.gov Notice of Intent (NOI) Submitted April 1, 2025 Date of Accepted Application May 12, 2025 Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 2 SOURCE DESCRIPTION General Description Detroit Diesel Remanufacturing, LLC (Detroit Reman) operates an engine remanufacturing plant in Tooele. The facility receives, disassembles, cleans, and manufactures diesel engines and engine components. Some completed engines are tested before being shipped. The facility operates paint booths, welding, sand blasting, grinding, and plasma cutting operations as part of the remanufacturing process. NSR Classification: Minor Modification at Minor Source Source Classification Located in the Northern Wasatch Front O3 NAA and Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: SM Applicable Federal Standards Project Proposal Minor Modification to Approval Order DAQE AN118290014-20 to Add Missing Equipment and a New Fuel Tank Manufacturing Line Project Description Detroit Diesel Remanufacturing is requesting a modification to add equipment and a new production line, updating their emissions along with the new equipment. The following changes have been made to the equipment list: 1. Added a cooling tower 2. Added 4 HVAC units 3. Added two fuel storage tanks 4. Added a dust collector 5. Added new Diesel Particulate Filter line, including associated 3 burn off ovens and 2 drying ovens powered by natural gas. 6. Added 4 blow off tables with associated dust collectors. 7. Changed equipment list to remove number of solvent tanks allowed and altered equipment item to state "various degreasing tanks" The following changes were made to the facilities permit requirements: 1. Decreased fuel limit in conditions II.B.3.c from 50,000 gallons to 47,000 gallons for 600 hp engines. EMISSION IMPACT ANALYSIS All potential emission increases of criteria pollutants and HAPs are below the respective modeling thresholds contained in R307-410-4 and R307-410-5. Therefore, modeling is not required at this time. [Last updated May Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 3 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Change (TPY) Total (TPY) Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 4 Review of BACT for New/Modified Emission Units BACT review regarding BACT Review BACT for Thermal Cleaning Ovens: The previous permit (AO DAQE-118290014-20) has listed three (3) thermal cleaning ovens with afterburning. Based on previous NOIs this is a typo and there should be six (6) thermal cleaning ovens with afterburners. The emissions and BACT for this equipment has already been included therefore there are no emissions increases from the addition of this equipment. BACT for Two (2) 0.35MMBtu/hr Natural Gas Fired Ovens The two (2) 0.35 MMBtu/hr ovens have the potential to emit NOx, SO2, CO, PM, and VOCs. However, most of these emissions are minimal, with NOx at 0.15 tpy being the highest. Therefore, no additional control technologies are necessary to further reduce these emissions. BACT for Fuel Tank Manufacturing Line The new fuel tank manufacturing line has the potential to emit PM and HAPs from welding and PM from polishing. The most effective way to control these emissions is through the use of a dust collection system. This control option is both technologically and economically feasible. The selected dust collection system will be 99% effective at controlling PM emissions and also significantly reduce the metal-based HAP emissions from the welding process. This system will be monitored by measuring inches of water column on magnehelic pressure gauge. BACT is selected as follows: The owner/operator shall route all welding and polishing emissions from the tank manufacturing line through a dust collection system that is 99% efficient at capturing PM emissions. [Last updated June 5, 2025] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] emissions covered by this AO must be reviewed and approved. [R307-401-1] Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 5 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] 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] [R307-107] 150] to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A.1 II.A.2 Controls fumes from MIG welding Once Box Cartridge Dust Collector Controls fumes from plasma cutting Glass Beader Baghouse Controls emissions from 6 glass bead abrasive blaster units Spinner/Hanger External Dust Collector Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 6 Double Table Blaster External Dust Collector Two (2) Tumble Blasters vent to internal dust collector Steel Shot Blaster Vents to internal dust collector Various Degreasing Tanks Contents: solvent based cleaner Engine Test Cells Fourteen (14) total /six (6) operational Six (6) Thermal Cleaning Ovens equipped with afterburners Maximum rating: 2.25 MMbtu/hr (each) Fuel: Natural Gas Two (2) Paint Booths Proceco Parts Washer Various Heaters Includes: Parts Washer heater Maximum rating: less than 5.00 MMBtu/hr (each) Various Non-volatile Degreasing Tanks For informational purposes only TAC Welding Operations For informational purposes only Waste Water Treatment For informational purposes only Cooling Tower Rating: 250 Gal/min Controls: High Efficiency Drift Eliminator Four (4) HVAC units Rating: 10 MMBtu/hr each Fuel: Natural Gas Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 7 Two (2) Storage Tanks Storage Tank 1 Capacity: 7,000 gallons Contents: Diesel Fuel Storage Tank 2 Capacity: 150 Gallons Contents: Ultra Low Sulfur Diesel MACT Applicability: Subpart CCCCCC Five (5) Blow off Tables Five (5) Dust Collectors Controls emissions from blow off tables Miscellaneous Combustion Equipment Rating: <5MMBtu/hr *Included for informational purposes only NEW Two (2) Robotic Weld Stations Control: Dust Collection System NEW Four (4) Manual Weld Stations Control: Dust Collection System NEW Polishing Station Control: Dust Collection System NEW Two (2) Drying Ovens Rated at 0.35 MMBtu/hr each Fuel: Natural Gas NEW One (1) Dust Collection System Control emissions from welding and polishing on the fuel tank manufacturing line NEW Three (3) Dust Collection Systems Two exhausted internally and one externally SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B.1 Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 8 from any stationary or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8] CFR 60, Appendix A, Method 9. [R307-201-3] in the building space/process heating. Appropriate fuels may be used in equipment being tested and in small auxiliary mobile equipment associated with the facility. [R307-401-8(1)(a)] month period: A. Natural gas - 40 MMscf B. Propane -10,000 gallons. [R307-401-8] new 12-month total by the 20th 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. The consumption shall be determined by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis. [R307-401-8] NEW (painting, printing, coating, and/or cleaning) on site: 17.08 tons per rolling 12-month period of VOCs 1.75 tons per rolling 12-month period of all HAPs combined. [R307-401-8] 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] 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] Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 9 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] requirements of R307-335. [R307-335] equivalent, to control particulate emissions. Air exiting the booths shall pass through this control system before being vented to the atmosphere (outside building/operation). [R307-401-8] owner/operator shall operate the storage tanks in a way that minimizes working and breathing losses from the tank. [R307-401-8] All blaster cleaners on site shall be subject to the following: equipment indicated in the equipment list at all times when blasting is taking place. [R307-401] All engine test cells on site shall be subject to the following: Dyno engines. Only one of the 4,000 hp Dyno engines shall run at any one time. [R307-401] engine test cells. [R307-401] rolling 12-month period: A. 600 hp engines - 47,000 gallons (combined) B. 4,000 hp engines - 100,000 gallons(combined). [R307-401-8] Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 10 new 12-month total by the 20th of each month using data from the previous 12 months. Fuel consumption for the engine test cells shall be determined by the use of operations records. [R307-401-8] exceed 20 percent opacity. [R307-201] All thermal cleaning ovens on site shall be subject to the following: needed. Each oven shall be equipped with an afterburner. The operating temperature of the afterburner shall be no less than 1,400 degrees Fahrenheit. Each afterburner shall operate whenever parts are being baked. [R307-401] NEW equipment located such that an inspector can, at any time, safely read the output. All readings shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated against the manufacturer's specification at least once every 12-month period. [R307-401] The Proceco parts washer shall be subject to the following: Fahrenheit. [R307-401-8] that an inspector or operator can, at any time, safely read the output. All readings shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated against the manufacturer's specification at least once every 12-month period. [R307-401] Cooling Tower Requirements particulate matter from the cooling tower. [R307-401-8] Dust Collector Requirements NEW and polishing operations to a baghouse or dust collection system before being vented to the atmosphere. [R307-401-8] NEW static pressure drop across the baghouse and dust collection system. [R307-401-8] NEW indicator at any time. [R307-401-8] NEW [R307-401-8] Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 11 NEW the static pressure drop across the baghouse or dust collection system between 1 and 4 inches of water column. [R307-401-8] NEW baghouse or dust collection system is operating. [R307-401-8] NEW A. Unit identification; B. Manufacturer recommended static pressure drop for the unit (if applicable); C. Date of reading; D. Daily static pressure drop readings. [R307-401-8] NEW accordance with the manufacturer's instructions or replace the gauges. [R307-401-8] NEW replacements. [R307-401-8] Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 12 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: REVIEWER COMMENTS 1. During this modification the following equipment was added to AO DAQE-118290014-20: - Two (2) Robotic Weld Stations - Four (4) Manual Weld Stations - One (1) Polishing Station - One (1) Dust Collection System for Fuel Tank Manufacturing Line - Two (2) 0.35 MMBtu/hr Natural Gas Fired Ovens - Changing Four (4) Blow off Tables to Five (5) - Changing Four (4) Blow off Table dust collectors to Five (5) - Changing Three (3) Thermal Cleaning Ovens with afterburners to Six (6) - [Last updated May 14, 2025] Comment regarding Emissions Estimates : The emissions from welding were estimated using emissions factors from AP-42 CH. 12.19 Tables 12.19-1 and 12.19-2. Emissions from the specific electrode were not accounted for in AP-42, therefore electrode type ER5356 was assumed during calculations. The emissions from the additional three (3) thermal cleaning ovens with afterburners were already include in the permit from the previous permit modification. Therefore, no new emissions were added here. The emissions from the two (2) 0.35. MMBtu/hr were estimated using natural gas burning emissions factors from AP-42 Table 1.4-1 and Table 1.4-2. [Last updated May 14, 2025] Comment regarding NSPS and MACT Applicability : NSPS subpart Kb applies to "each storage vessel with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984." The diesel storage tank has a capacity of 7,000 gallons, or about 26.5 cubic meters. The gasoline storage tank has a capacity of 150 gallons or about 0.57 cubic meters. As these capacities are below the volume specified in this subpart, this subpart does not apply to the facility. NSPS subparts IIII and JJJJ apply to owners and manufacturers of diesel and natural gas internal combustion engines respectively. This facility only operates diesel or natural gas engines at test cells, which are exempted from these subparts according to 40 CFR 60.4200 (b) and 40 CFR 60.4230 (b). Therefore, these subparts do not apply to the facility. MACT subpart ZZZZ states that "You are subject to this subpart if you own or operate a stationary RICE at a major or area source of HAP emissions, except if the stationary RICE is being tested at a stationary RICE test cell/stand." As this facility operates stationary RICE at an area source of HAPs, Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 13 MACT subpart PPPPP states that "You are subject to this subpart if you own or operate an engine test cell/stand that is located at a major source of HAP emissions." This facility is located at an area source of HAP emissions, and is not a major source of HAP emissions. Therefore, this subpart does not apply to the facility. MACT subpart CCCCCC applies to each 'gasoline dispensing facility' located at an area source of HAP emissions. The gasoline storage tank meets the definition of a gasoline dispensing facility, and has a monthly throughput of less than 10,000 gallons of gasoline. Therefore, the tank is subject to the requirements in 40 CFR 63.11116. MACT subpart XXXXXX states that "You are subject to this subpart if you own or operate an area source that is primarily engaged in the operations in one of the nine source categories listed in paragraphs (a)(1) through (9) of this section: Electrical and Electronic Equipment Finishing Operations; Fabricated Metal Products; Fabricated Plate Work (Boiler Shops); Fabricated Structural Metal Manufacturing; Heating Equipment, except Electric; Industrial Machinery and Equipment Finishing Operations; Iron and Steel Forging; Primary Metal Products Manufacturing; Valves and Pipe Fittings." While this source engages in metal fabrication of metal products (specifically fuel tanks), it is "primarily" engaged in the remanufacturer of engines and has an SIC code of 3519 (Internal Combustion Engines, NEC). Therefore Subpart XXXXXX does not apply to this source. [Last updated July 9, 2025] Comment regarding Title V Applicability : Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. It is subject to 40 CFR 63 (MACT) regulations. It is not subject to 40 CFR 60 (NSPS) or 40 CFR 61 (NESHAP) regulations. MACT subparts CCCCCC and XXXXXX exempt the source from Title V requirements in 40 CFR 63.11111(f). Therefore, the facility is exempt from Title V. [Last updated June 5, 2025] Engineer Review N118290017: Detroit Diesel Remanufacturing, LLC August 18, 2025 Page 14 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: Equipment to Add: New - Fuel Tank Manufacturing Line Welding Equipment New Equipment: 2 robotic weld stations 4 manual weld stations New - Fuel Tank Manufacturing Line Polishing Equipment New Equipment 1 polishing station II.A.11 3 units with afterburners to 6 units with afterburner These emissions were already accounted for in the last modification II.A.11 ADD two 0.35 MMTBU/hr drying ovens Emissions added in emissions spreadsheet II.A.21 4 blow off tables to 5 blow off tables II.A.22 4 blow off table dust collectors to 5 blow off table dust collectors II.A.20 150 gallon tank now has ultra low sulfur diesel instead of gasoline Changes to make: Changes requested old: ● Add three DPF line ovens with afterburner pollution control devices ○ The emissions from these ovens were already accounted for in the last AO modification under item #5 in the process description Additional changes requested (new): ● Addition of a Fuel Tank Manufacturing line ○ Will include argon tank, nitrogen tank, dust collector systems, Changes requested from compliance: ● Equipment list item in current permit II.A.11 currently states three (3) thermal cleaning ovens with afterburners however there are actually six (6) onsite ● Both storage tanks in II.A.20 now contain diesel so 40 cfr 63 (MACT) Subpart CCCCCC no longer applies ○ This also means I can remove II.B.1.h ● II.A.8 Steel shot blaster has been removed ● II.A.22 states four 4 dust collectors but there should be 5 Questions regarding the new changes: What additional equipment will the fuel tank manufacturing line consist of: What equipment will be dust collector systems be controlling emissions from If there will be coatings, or solvents, paints, or adhesives used there could be HAP or VOC emissions If there will be sanding, welding, grinding, or metal cutting there could be PM emissions (I’m assuming that this is where the dust collector system will be used to control emissions Three robotic weld stations running on argon One manual weld station Grinding process Polishing process - nitrogen (dust collector) Making aluminum tanks O2 tank 1500 gal Argon tank 7k gallons Large volume throughput 100 tanks a day 10% of tanks will be polished Emission Related Information Per UDAQ’s NOI Form 1 and R307-401-2(b), the NOI application should include controlled and uncontrolled emissions for criteria pollutants, greenhouse gases (GHG), and Hazardous Air Pollutants (HAPs) associated with each new or modified unit as well as designation of fugitive and non-fugative emissions. The following section describes the emission calculation methodologies used to calculate emissions for the propsed equipment. Cooling Tower Detroit Reman has a wet cooling tower to cool down our Dyno Cells. Annual emissions from the cooling tower was calculated per AP-42, Section 13.4.1 (Particulate emissions factors for wet cooling towers). Specifically, equations contained in Table 13.4-1 are utilized (Induced draft towers). Appendix A has the cooling tower calculations. NATURAL GAS COMBUSTION UNITS Detroit Remanufacturing has four HVAC units and five new ovens. The facility is using the 40 MMscf/yr natural gas limit to limit the emissions associated with natural gas combustion. The PTE emission were conservatively calculated by using the maximum annual emission rate for each pollutant that results from combusting all 40 MMscf/yr in the general natural gas units or in the ovens. Rooftop HVAC Units (4) Emissions calculations were performed for all rooftop HVAC units by using a the maximum annual emission rate for each pollutant that results from combusting 40 MMscf/yr of natural gas Steelman Natural Gas Burn off and Drying ovens Emissions calculations were performed for natural gas bakeoff and drying ovens by using a maximum annual emission rate for each pollutant that results from combusting 40 MMscf/yr of natural gas. The emissions factors that were used came from a combination of Steelman industries heat cleaning oven process description (Criteria Pollutants), AP 42 section 1.4 natural combustion (HAPS), and 40 CFR subpart 98 Table C-1 and table 1-2 (Green house gases). Appendix B has the emission calculations for natural gas combustion equipment and UDAQ Form 19 for the HVAC units and UDAQ Form 3 for the ovens. Fuel Storage Tanks one 7,000 gallon Diesel (AST 1) and one 150 gallon gasoline tank (AST 4) Annual emissions for the fuel tanks was calculated based on the AP-42 section 7.1.3.1 methodology. Annual VOC emissions from fixed roof storage tanks are calculated by summing the standing storage loss and working loss as from the fifth edition (2006) of AP-42 section 7.1.3.1. For informational purposes there is also one 7,000 gallon waste oil tank and one 7,000 gallon waste water tank but because of the low volatility of the material, there are no quantifiable emissions associated with it. Appendix C has the fuel tank calculations Torit Dust Collectors Emissions calculations were performed for all Donaldson Torit Dust collectors. With a proposed cap on annual hours of operation. Operating schedule of 3650 hr/yr based on 10 hours shifts 365 days a year. Each dust collector’s air flow rates came from the manufacture. The manufacturer states that the filters can achieve a grain loading of .002 grains/scf under ideal circumstances. Because many factors can result in reduced efficiencies Detroit Reman has conservatively assumed an emission rate of .005 grains/scf. The Torit spinner hanger, glass beader, double table, welding fumes, and plasma cutting are all on the current AO. Appendix D has Emission calculations for dust collectors and UDAQ Form 10 Baghouse. Solvent Tanks Solvent tanks are used intermittently throughout the facility to clean parts as needed. These tanks meet the requirements of R307-335 and remain closed when not is use. Additionally, annual emissions from these units are limited by the VOC limit established in the current AO DAQ-AN118290010-17 section II.A. Detroit Reman proposes that compliance with R307 -335 and R307-401 and the VOC limit established in the AO adequately limits the emissions from these units and that limiting the number of tanks on site does not provide additional control of emissions and unnecessarily restricts operational flexibility. For this reason, Detroit Reman. Request that condition AO DAQ-AN118290010-17 section II.A be revised to omit the number of units on site. Appendix E has the emissions calculations, UDAQ Form 21 and Tec Sol Safety Data Sheet. Appendix F has the facility emissions, Project Summary emissions, Emission totals TPY and Emission Totals Hourly. Appendix A: Cooling Tower  Cooling Tower Emissions Appendix B: Natural Gas Combustion  Natural Gas Combustion Emission Calculations  UDAQ Form 19 Natural Gas Boilers and Liquid Heaters (used for the HVAC Units)  Natural Gas Combustion Emission Calculations for Ovens  UDAQ Form 3 Afterburners Appendix C: Fuel Tank  Fuel Tank Emissions Appendix D: Dust Collectors  Baghouse Emission Calculations  UDAQ Form 10 Fabric Filter Baghouse Appendix E: Solvent Tanks  Solvent Tank Emissions  UDAQ Form 21  Tec Sol Safety Data Sheet Emission Impact Analysis  Project Summary Emissions  Emissions Totals (TPY)  Emission Totals (Hourly) EMISSION CALCULATIONS Source:One fuel tank welding operation ES-FTW Source:ES-FTW One fuel tank welding operation EPN:EP-FTW Controls:CD-BH1 One bagfilter (4,400 square feet of filter area) Calculation Assumptions: Estimated Emissions from Wire 1 5.3 lb PM / 100 lbs of wire used 0.13%Mn 0.13%Total chromium Estimated Emissions from Rod Less emissions Total Usage per year =20490.0 lbs Therefore at 5.3 lb PM/ 100 lbs used the PM generated is 1085.97 lb PM generated Pounds per day 2.98 lb PM per day= Pounds per year @ 365 days 1085.97 lb/yr PM Controlled Emissions: Uncontrolled Emission Rate * (1- Baghouse Eff.)= 2.98 lb PM per day= * (1- 0.99)=0.030 lb/day 1085.97 lb/yr * (1- 0.99)=10.86 lb/yr10.86 lb/yr /2000 lb/ton=0.005 tpy Manganese and Total Chromium Controlled Emissions:Uncontrolled Emission Rate * (1- Baghouse Eff.)= 1085.97 lb/yr * 0.0013 =0.014 lb/day 0.01 lb/day * 365 days=5.15 lb/yr 5.15 lb/yr /2000 lb/ton=0.003 tpy Pollutant lb/hr lb/yr ton/yr PM 0.002 10.9 0.005 PM-10 0.002 10.9 0.005PM-2.5 0.002 10.9 0.005Manganese0.001 5.2 0.003 Chromium 0.001 5.2 0.003 Short term lb/hr assumes 16 hours/dayAssumes PM-10 and PM-2.5 equal to PM NOTE: Current Fuel Tank Welding materials are: ER5356 MIG WIRE 3/64 ALMIGWELD 20LB SPL WIRE MIG ALUM ER5356 3/64 20LB SOROD TIG ALUM ER5356 1/8 X 36 10LB TB Page 10 of 14 Sheet:Fuel Tank Welding EMISSION CALCULATIONS Source:One fuel tank grinding operation ES-FTG Source:ES-FTG One fuel tank grinding operation EPN:EP-FTG Controls:CD-VSBH1 One bagfilter (1024 square feet of filter area) Fuel Tank Grinding Calculations Grain Loading 0.01 gr/dscf Baghouse Eff.99% Assume efficiency of 99% to be conservative Conversion 7000 gr/lb Hours of Operation 5840 hr/yr Assume that 1 acfm = 1dscfm since at ambient temperatures and pressures Calculation: Emissions: Exhaust Rate Emissions 2 Emissions 4 (Uncontrolled) Emissions 3 (Uncontrolled) Emissions 4 (acfm)(lb/hr)(TPY)(lb/hr)(TPY) Fuel Tank Grinding ES-FTW 1050 0.090 0.263 9.00 26.3 1) data from vendor specs 2) Output (lb/hr) = Exhaust rate (dscfm)* 0.01 (gr/dscf) * 60 (min/hr) * (1/7000 (gr/lb)) 3) Input (lb/hr)= Output (lb/hr) / (1-efficiency) 4)Input (TPY) = PM Input (lb/hr) * 8760 hr/yr * 1 ton/2000 lbs Controlled PM Emissions (lb/hr)(TPY) Grinding 0.090 0.263 Utah Division of Air Quality New Source Review Section Form 3 Company_Detroit Reman___________ Site/Source: Tooele ________________ Date: 7/8/2020___________________ Afterburners Equipment Information 1. Provide diagram of internal components:2. Manufacturer: _(Drying Oven 8)___ Model no.: ________________ 3. Combustion chamber dimensions: Length:__________________________ inches, Cross-sectional area:_______________ square inches 4.Burners per afterburner: ______ at BTU/hr each 5. Minimum operating temperature of combustion chamber:oF 6. Minimum retention time (seconds): 7. Heat exchanger used: □ No □ Yes: Describe heat exchanger: 8. Catalyst used: □ No □ Yes: Describe catalyst: 9. Stack dimensions: Height _____________ Diameter _____________ Waste Gases (At Maximum Continuous Production Rate) 10. Chemical composition 11. Afterburner exhaust temperature:__________ oF Flow rate:__________scfm Auxiliary Fuel 12.Type: x□ Natural gas □ Fuel oil □ Used oil* □ Coal □ Diesel □ Other:___________________ 13. Maximum sulfur content:_________________% by Wt 14. Fuel usage rate at maximum continuous production rate: Average Operation of Source Maximum Operation of Source 15. Gas flow rate:scfm 17. Gas flow rate:scfm 16. Efficiency of afterburner:% 18. Efficiency of afterburner:% Emissions Calculations (PTE) 19.Calculated emissions for this device: See attached PM2.5 _______Lbs/hr_.01_ Tons/yr SOx ______Lbs/hr_.00__ Tons/yr VOC __________ Lbs/hr _.01__ Tons/yr CH4 ____.001___ Tons/yr PM10 _________Lbs/hr_____.01_ Tons/yr NOx __________Lbs/hr_____.05_ Tons/yr CO __________Lbs/hr______.00_ Tons/yr CO2 ___75___Tons/yr N2O ___.0001______Tons/yr HAPs________ Lb s/hr (speciate)___.001____Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 1 of 2  677 GTC Steelman 96 6912 450 14400 N/A Page 2 of 2  Instructions - Form 3 Afterburners NOTE: 1. Submit this form in conjunction with Form 1 and Form 2. 2.Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions when completing this form. Ask for a New Source Review Section engineer. We will be glad to help! *For used oil see #12 of the instructions below. 1.Supply an assembly drawing, dimensioned and to scale of the interior dimensions and features of the equipment. 2. Specify the manufacturer, model number and serial number of the equipment. 3. Specify the dimensions of the combustion chamber. 4. Indicate the number of burners per afterburner and the BTU/hr for each burner. 5. Indicate the minimum operating temperature for the combustion chamber. 6.Supply the minimum retention time in the combustion chamber. 7. Indicate whether or not a heat exchanger is used and describe that equipment. 8. Indicate whether or not a catalyst is used in the process and describe it. 9. Supply the stack dimensions. 10.Supply the chemical composition of the waste gases at maximum production rate. 11.Specify the exhaust temperature and flow rate of the waste gases enter the afterburner. 12.Indicate what type of fuel in addition to the waste gases that is used. Used oil is any oil that has been refined from crude oil, used, and, as a result is contaminated with impurities. The concentration/parameters of contaminants in any used oil fuel cannot exceed the following levels: 1.Arsenic ..................................................5 ppm by weight 2.Cadmium...............................................2 ppm by weight 3.Chromium............................................10 ppm by weight 4.Lead ..................................................100 ppm by weight 5.Total halogens................................1,000 ppm by weight 6. Sulfur .....................................................0.5 percent by weight 7. Flash Point ........................................100°F 13. Indicate the sulfur content of the fuel in percentage by weight. 14.Supply how much of this fuel will be used at maximum continuous production. 15. Indicate the average gas flow rate through the afterburner during average operation. 16.Indicate the average efficiency of the afterburner during average operation. 17. Indicate the maximum gas flow rate through the afterburner during maximum operation. 18.Indicate the maximum efficiency of the afterburner during maximum operation. 19.Supply calculations for all criteria pollutants and HAPs. Use Manufacturers’ data or AP-42 to complete your calculations. f:\aq\ENGINEER\GENERIC\Forms 2010\Form03 Afterburners.doc Revised 12/20/10 Utah Division of Air Quality New Source Review Section Form 3 Company_Detroit Reman___________ Site/Source: Tooele ________________ Date: 7/8/2020___________________ Afterburners Equipment Information 1. Provide diagram of internal components:2. Manufacturer: Steelman _(Drying oven 7)___ Model no.: ________________ 3. Combustion chamber dimensions: Length:__________________________ inches, Cross-sectional area:_______________ square inches 4.Burners per afterburner: ______ at BTU/hr each 5. Minimum operating temperature of combustion chamber:oF 6. Minimum retention time (seconds): 7. Heat exchanger used: □ No □ Yes: Describe heat exchanger: 8. Catalyst used: □ No □ Yes: Describe catalyst: 9. Stack dimensions: Height _____________ Diameter _____________ Waste Gases (At Maximum Continuous Production Rate) 10. Chemical composition 11. Afterburner exhaust temperature:__________ oF Flow rate:__________scfm Auxiliary Fuel 12.Type: x□ Natural gas □ Fuel oil □ Used oil* □ Coal □ Diesel □ Other:___________________ 13. Maximum sulfur content:_________________% by Wt 14. Fuel usage rate at maximum continuous production rate: Average Operation of Source Maximum Operation of Source 15. Gas flow rate:scfm 17. Gas flow rate:scfm 16. Efficiency of afterburner:% 18. Efficiency of afterburner:% Emissions Calculations (PTE) 19.Calculated emissions for this device: See attached PM2.5 _______Lbs/hr_.01_ Tons/yr SOx ______Lbs/hr_.00__ Tons/yr VOC __________ Lbs/hr _.01__ Tons/yr CH4 ____.001___ Tons/yr PM10 _________Lbs/hr_____.01_ Tons/yr NOx __________Lbs/hr_____.05_ Tons/yr CO __________Lbs/hr______.00_ Tons/yr CO2 ___75___Tons/yr N2O ___.0001______Tons/yr HAPs________ Lb s/hr (speciate)___.001____Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 1 of 2  92 14400450 N/A 6912 677 GTC Page 2 of 2  Instructions - Form 3 Afterburners NOTE: 1. Submit this form in conjunction with Form 1 and Form 2. 2.Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions when completing this form. Ask for a New Source Review Section engineer. We will be glad to help! *For used oil see #12 of the instructions below. 1.Supply an assembly drawing, dimensioned and to scale of the interior dimensions and features of the equipment. 2. Specify the manufacturer, model number and serial number of the equipment. 3. Specify the dimensions of the combustion chamber. 4. Indicate the number of burners per afterburner and the BTU/hr for each burner. 5. Indicate the minimum operating temperature for the combustion chamber. 6.Supply the minimum retention time in the combustion chamber. 7. Indicate whether or not a heat exchanger is used and describe that equipment. 8. Indicate whether or not a catalyst is used in the process and describe it. 9. Supply the stack dimensions. 10.Supply the chemical composition of the waste gases at maximum production rate. 11.Specify the exhaust temperature and flow rate of the waste gases enter the afterburner. 12.Indicate what type of fuel in addition to the waste gases that is used. Used oil is any oil that has been refined from crude oil, used, and, as a result is contaminated with impurities. The concentration/parameters of contaminants in any used oil fuel cannot exceed the following levels: 1.Arsenic ..................................................5 ppm by weight 2.Cadmium...............................................2 ppm by weight 3.Chromium............................................10 ppm by weight 4.Lead ..................................................100 ppm by weight 5.Total halogens................................1,000 ppm by weight 6. Sulfur .....................................................0.5 percent by weight 7. Flash Point ........................................100°F 13. Indicate the sulfur content of the fuel in percentage by weight. 14.Supply how much of this fuel will be used at maximum continuous production. 15. Indicate the average gas flow rate through the afterburner during average operation. 16.Indicate the average efficiency of the afterburner during average operation. 17. Indicate the maximum gas flow rate through the afterburner during maximum operation. 18.Indicate the maximum efficiency of the afterburner during maximum operation. 19.Supply calculations for all criteria pollutants and HAPs. Use Manufacturers’ data or AP-42 to complete your calculations. f:\aq\ENGINEER\GENERIC\Forms 2010\Form03 Afterburners.doc Revised 12/20/10 Utah Division of Air Quality New Source Review Section Form 3 Company_Detroit Reman___________ Site/Source: Tooele ________________ Date: 7/8/2020___________________ Afterburners Equipment Information 1. Provide diagram of internal components:2. Manufacturer: Steelman _(Bakeoff oven 6)___ Model no.: 677 _________________ 3. Combustion chamber dimensions: Length:__________________________ inches, Cross-sectional area:_______________ square inches 4.Burners per afterburner: ______ at BTU/hr each 5. Minimum operating temperature of combustion chamber:oF 6. Minimum retention time (seconds): 7. Heat exchanger used: □ No □ Yes: Describe heat exchanger: 8. Catalyst used: □ No □ Yes: Describe catalyst: 9. Stack dimensions: Height _____________ Diameter _____________ Waste Gases (At Maximum Continuous Production Rate) 10. Chemical composition 11. Afterburner exhaust temperature:__________ oF Flow rate:__________scfm Auxiliary Fuel 12.Type: x□ Natural gas □ Fuel oil □ Used oil* □ Coal □ Diesel □ Other:___________________ 13. Maximum sulfur content:_________________% by Wt 14. Fuel usage rate at maximum continuous production rate: Average Operation of Source Maximum Operation of Source 15. Gas flow rate:scfm 17. Gas flow rate:scfm 16. Efficiency of afterburner:% 18. Efficiency of afterburner:% Emissions Calculations (PTE) 19.Calculated emissions for this device: See attached PM2.5 __________Lbs/hr_.04___ Tons/yr SOx ___________Lbs/hr_.02___ Tons/ yr VOC __________ Lbs/hr _.04__ Tons/ yr CH4 ____.005___ Tons/yr PM10 _________Lbs/hr_____.04_ Tons/yr NOx __________Lbs/hr_____.18_ Tons/yr CO __________Lbs/hr______.02_ Tons/yr CO2 ___282___Tons/yr N2O ___.0005______Tons/yr HAPs________ Lb s/hr (speciate)___.004____Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 1 of 2  72 1 1050 1800 6048 Page 2 of 2  Instructions - Form 3 Afterburners NOTE: 1. Submit this form in conjunction with Form 1 and Form 2. 2.Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions when completing this form. Ask for a New Source Review Section engineer. We will be glad to help! *For used oil see #12 of the instructions below. 1.Supply an assembly drawing, dimensioned and to scale of the interior dimensions and features of the equipment. 2. Specify the manufacturer, model number and serial number of the equipment. 3. Specify the dimensions of the combustion chamber. 4. Indicate the number of burners per afterburner and the BTU/hr for each burner. 5. Indicate the minimum operating temperature for the combustion chamber. 6.Supply the minimum retention time in the combustion chamber. 7. Indicate whether or not a heat exchanger is used and describe that equipment. 8. Indicate whether or not a catalyst is used in the process and describe it. 9. Supply the stack dimensions. 10.Supply the chemical composition of the waste gases at maximum production rate. 11.Specify the exhaust temperature and flow rate of the waste gases enter the afterburner. 12.Indicate what type of fuel in addition to the waste gases that is used. Used oil is any oil that has been refined from crude oil, used, and, as a result is contaminated with impurities. The concentration/parameters of contaminants in any used oil fuel cannot exceed the following levels: 1.Arsenic ..................................................5 ppm by weight 2.Cadmium...............................................2 ppm by weight 3.Chromium............................................10 ppm by weight 4.Lead ..................................................100 ppm by weight 5.Total halogens................................1,000 ppm by weight 6. Sulfur .....................................................0.5 percent by weight 7. Flash Point ........................................100°F 13. Indicate the sulfur content of the fuel in percentage by weight. 14.Supply how much of this fuel will be used at maximum continuous production. 15. Indicate the average gas flow rate through the afterburner during average operation. 16.Indicate the average efficiency of the afterburner during average operation. 17. Indicate the maximum gas flow rate through the afterburner during maximum operation. 18.Indicate the maximum efficiency of the afterburner during maximum operation. 19.Supply calculations for all criteria pollutants and HAPs. Use Manufacturers’ data or AP-42 to complete your calculations. f:\aq\ENGINEER\GENERIC\Forms 2010\Form03 Afterburners.doc Revised 12/20/10 Utah Division of Air Quality New Source Review Section Form 3 Company_Detroit Reman___________ Site/Source: Tooele ________________ Date: 7/8/2020___________________ Afterburners Equipment Information 1. Provide diagram of internal components:2. Manufacturer: Steelman _(Bakeoff oven 5)___ Model no.: 677 _________________ 3. Combustion chamber dimensions: Length:__________________________ inches, Cross-sectional area:_______________ square inches 4.Burners per afterburner: ______ at BTU/hr each 5. Minimum operating temperature of combustion chamber:oF 6. Minimum retention time (seconds): 7. Heat exchanger used: □ No □ Yes: Describe heat exchanger: 8. Catalyst used: □ No □ Yes: Describe catalyst: 9. Stack dimensions: Height _____________ Diameter _____________ Waste Gases (At Maximum Continuous Production Rate) 10. Chemical composition 11. Afterburner exhaust temperature:__________ oF Flow rate:__________scfm Auxiliary Fuel 12.Type: x□ Natural gas □ Fuel oil □ Used oil* □ Coal □ Diesel □ Other:___________________ 13. Maximum sulfur content:_________________% by Wt 14. Fuel usage rate at maximum continuous production rate: Average Operation of Source Maximum Operation of Source 15. Gas flow rate:scfm 17. Gas flow rate:scfm 16. Efficiency of afterburner:% 18. Efficiency of afterburner:% Emissions Calculations (PTE) 19.Calculated emissions for this device: See attached PM10 _________Lbs/hr_____.04_ Tons/yr NOx __________Lbs/hr_____.19_ Tons/yr CO __________Lbs/hr______.02_ Tons/yr PM2.5 __________Lbs/hr_.04___ Tons/yr SOx ___________Lbs/hr_.02___ Tons/yr VOC __________ Lbs/hr _.004__ Tons/yr CH4 ____.005___ Tons/yrCO2 ___294___Tons/yr N2O ___.0005______Tons/yr HAPs________ Lb s/hr (speciate)___.005____Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 1 of 2  72 1 1050 36000 1800 6048 Page 2 of 2  Instructions - Form 3 Afterburners NOTE: 1. Submit this form in conjunction with Form 1 and Form 2. 2.Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions when completing this form. Ask for a New Source Review Section engineer. We will be glad to help! *For used oil see #12 of the instructions below. 1.Supply an assembly drawing, dimensioned and to scale of the interior dimensions and features of the equipment. 2. Specify the manufacturer, model number and serial number of the equipment. 3. Specify the dimensions of the combustion chamber. 4. Indicate the number of burners per afterburner and the BTU/hr for each burner. 5. Indicate the minimum operating temperature for the combustion chamber. 6.Supply the minimum retention time in the combustion chamber. 7. Indicate whether or not a heat exchanger is used and describe that equipment. 8. Indicate whether or not a catalyst is used in the process and describe it. 9. Supply the stack dimensions. 10.Supply the chemical composition of the waste gases at maximum production rate. 11.Specify the exhaust temperature and flow rate of the waste gases enter the afterburner. 12.Indicate what type of fuel in addition to the waste gases that is used. Used oil is any oil that has been refined from crude oil, used, and, as a result is contaminated with impurities. The concentration/parameters of contaminants in any used oil fuel cannot exceed the following levels: 1.Arsenic ..................................................5 ppm by weight 2.Cadmium...............................................2 ppm by weight 3.Chromium............................................10 ppm by weight 4.Lead ..................................................100 ppm by weight 5.Total halogens................................1,000 ppm by weight 6. Sulfur .....................................................0.5 percent by weight 7. Flash Point ........................................100°F 13. Indicate the sulfur content of the fuel in percentage by weight. 14.Supply how much of this fuel will be used at maximum continuous production. 15. Indicate the average gas flow rate through the afterburner during average operation. 16.Indicate the average efficiency of the afterburner during average operation. 17. Indicate the maximum gas flow rate through the afterburner during maximum operation. 18.Indicate the maximum efficiency of the afterburner during maximum operation. 19.Supply calculations for all criteria pollutants and HAPs. Use Manufacturers’ data or AP-42 to complete your calculations. f:\aq\ENGINEER\GENERIC\Forms 2010\Form03 Afterburners.doc Revised 12/20/10 Utah Division of Air Quality New Source Review Section Form 3 Company_Detroit Reman___________ Site/Source: Tooele ________________ Date: 7/8/2020___________________ Afterburners Equipment Information 1. Provide diagram of internal components:2. Manufacturer: Steelman _(Bakeoff oven 4)___ Model no.: 677 BA-C-HT_________________ 3. Combustion chamber dimensions: Length:__________________________ inches, Cross-sectional area:_______________ square inches 4.Burners per afterburner: ______ at BTU/hr each 5. Minimum operating temperature of combustion chamber:oF 6. Minimum retention time (seconds): 7. Heat exchanger used: □ No □ Yes: Describe heat exchanger: 8. Catalyst used: □ No □ Yes: Describe catalyst: 9. Stack dimensions: Height _____________ Diameter _____________ Waste Gases (At Maximum Continuous Production Rate) 10. Chemical composition 11. Afterburner exhaust temperature:__________ oF Flow rate:__________scfm Auxiliary Fuel 12. Type: x□ Natural gas □ Fuel oil □ Used oil* □ Coal □ Diesel □ Other:___________________ 13. Maximum sulfur content:_________________% by Wt 14. Fuel usage rate at maximum continuous production rate: Average Operation of Source Maximum Operation of Source 15. Gas flow rate:scfm 17. Gas flow rate:scfm 16. Efficiency of afterburner:% 18. Efficiency of afterburner:% Emissions Calculations (PTE) 19. Calculated emissions for this device: See attached PM10 _________Lbs/hr_____.04_ Tons/yr NOx __________Lbs/hr_____.20_ Tons/yr CO __________Lbs/hr______.02_ Tons/yr CO2 ___303___Tons/yr PM2.5 __________Lbs/hr___.04___ Tons/yr SOx ___________Lbs/hr___.02___ Tons/yr VOC __________ Lbs/hr ___.04__ Tons/yr CH4 ____.005___ Tons/yr N2O ___.0005______Tons/yr HAPs________ Lb s/hr (speciate)___.005____Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 1 of 2  72 1 1420000 1050 1800 36000 6048 Page 2 of 2  Instructions - Form 3 Afterburners NOTE: 1. Submit this form in conjunction with Form 1 and Form 2. 2.Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions when completing this form. Ask for a New Source Review Section engineer. We will be glad to help! *For used oil see #12 of the instructions below. 1.Supply an assembly drawing, dimensioned and to scale of the interior dimensions and features of the equipment. 2. Specify the manufacturer, model number and serial number of the equipment. 3. Specify the dimensions of the combustion chamber. 4. Indicate the number of burners per afterburner and the BTU/hr for each burner. 5. Indicate the minimum operating temperature for the combustion chamber. 6.Supply the minimum retention time in the combustion chamber. 7. Indicate whether or not a heat exchanger is used and describe that equipment. 8. Indicate whether or not a catalyst is used in the process and describe it. 9. Supply the stack dimensions. 10.Supply the chemical composition of the waste gases at maximum production rate. 11.Specify the exhaust temperature and flow rate of the waste gases enter the afterburner. 12.Indicate what type of fuel in addition to the waste gases that is used. Used oil is any oil that has been refined from crude oil, used, and, as a result is contaminated with impurities. The concentration/parameters of contaminants in any used oil fuel cannot exceed the following levels: 1.Arsenic ..................................................5 ppm by weight 2.Cadmium...............................................2 ppm by weight 3.Chromium............................................10 ppm by weight 4.Lead ..................................................100 ppm by weight 5.Total halogens................................1,000 ppm by weight 6. Sulfur .....................................................0.5 percent by weight 7. Flash Point ........................................100°F 13. Indicate the sulfur content of the fuel in percentage by weight. 14.Supply how much of this fuel will be used at maximum continuous production. 15. Indicate the average gas flow rate through the afterburner during average operation. 16.Indicate the average efficiency of the afterburner during average operation. 17. Indicate the maximum gas flow rate through the afterburner during maximum operation. 18.Indicate the maximum efficiency of the afterburner during maximum operation. 19.Supply calculations for all criteria pollutants and HAPs. Use Manufacturers’ data or AP-42 to complete your calculations. f:\aq\ENGINEER\GENERIC\Forms 2010\Form03 Afterburners.doc Revised 12/20/10 PM, Filterable-d PM, Condensable PM, Total SO2-e Nox-f N2O-g CO2-hj CO TOC CH4-k Table Source= www3.epa.gov/ttnc Propane Emission Factor (lb/1000 gal)Proposed Increased (5000 Gallons) 0.20 1 0.50 2.5 0.70 3.5 0.10S 0.5 13.00 65 0.90 4.5 12,500.00 62500 7.50 37.5 1.00 5 0.20 1 chie1/ap42/ch01/final/c01s05.pdf BACT ANALYSIS Natural Gas Combustion All natural gas combustion is limited by the site-wide natural gas consumption limit of 40 MMscf/yr as stated in condition II.B.1.b of approval order DAQE-AN118290013-18. Detroit Reman. is not requesting to increase the natural gas limit which significantly limits the potential emission from natural gas combustion (e.g., assuming 10 hours of operation per day and 365 days a year for natural gas combustion units results in a NOX PTE of 9.5 tpy; the 40 MMscf/yr natural gas limit results in a reduced NOX PTE of 2.0 tpy). Bake and Drying Ovens The proposed bake and drying ovens are used to incinerate oils from engine components to prepare them for recycling. This process has natural gas combustion emissions associated them for heating the ovens and an afterburner, and potential VOC/HAP emissions associated with the incineration of the mentioned materials. Low NOX and Ultra-low NOX Burners Low NOX and Ultra-low NOX burners utilize a combination of air to fuel ratios and flame control to achieve cooler combustion temperatures and subsequently a relatively reduced formation of NOX. The manufacturer has experimented with implementing different techniques. The manufacturer’s efforts to implement different configurations resulted in unacceptable performance that jeopardized the effectiveness of the equipment. Because of this, the use of low-NOX and ultra low-NOX technology beyond what the manufacturer has installed is technically infeasible and not considered further. SCR and SNCR NOX and CO can also be controlled using add on controls. A proven technology for NOX control from natural gas combustion equipment is a selective catalytic reduction system, which uses a catalyst to convert NO and NOX to elemental nitrogen. The NOX reduction is effective only within a given temperature range, ranging from 480 to 800 degrees Fahrenheit for standard catalyst and up to 1,000 degrees Fahrenheit for zeolite catalyst.12 The afterburner of the ovens operates at a minimum temperature of 1,400 degrees Fahrenheit and therefore a SCR system is not technically feasible. Selective non-catalytic reduction (SNCR) is effective at controlling NOX at high temperatures, however they are most effective for sources with high NOX emissions above 200 ppm.3 For example inlet NOX emissions of 0.2 lb/MMBtu have a documented NOX reduction 1 EPA Air Pollution Control Technology Fact Sheet, Selective Catalytic Reduction, EPA-452/F-03-032 2 EPA Control Cost Manual, Chapter 2, Selective Catalytic Reduction 3 EPA Control Cost Manual, Chapter 1, Selective Noncatalytic Reduction ranging from 25 to 20%.4 The proposed ovens have a NOX emission rate of 0.076 lb/MMBtu; therefore the ovens are not a good candidate for SNCR and the control is not considered further. Good Operating Practices and Maintenance NOX and CO are formed from the combustion of natural gas. The formation of these pollutants can be minimized by practicing good operating practices and maintaining equipment properly to achieve optimal air to fuel ratios. Detroit Reman. proposes good operating practices, the use of natural gas as a primary fuel, and the site wide natural gas limit as being effective for minimizing the CO and NOX emission from the ovens. SO2 is a combustion product formed when sulfur containing fuel is combusted. The use of clean gaseous fuel, such as natural gas which has been desulfurized, minimizes the formation of SO2. Detroit Reman proposes the combustion of natural gas as the primary fuel in the ovens to be BACT for SO2 emissions. PM is formed from the combustion of fuels and from the incineration of the mentioned materials. The combustion of gaseous fuels minimizes particulate matter relative to combustion of liquid and solid fuels. Additionally, the ovens are equipped with afterburners which are demonstrated to have a thermal incineration PM10 destruction efficiency of up to 99%.5Detroit Reman proposes the combustion of natural gas as the primary fuel in the ovens and the operation of an afterburner to be BACT for PM emissions. Afterburners have been demonstrated to control VOC and HAP emissions with a control efficiency of 98 to 99.99%.6 The afterburners will operate at a minimum temperature of 1,400 degrees Fahrenheit to achieve optimal destruction of VOC and HAPs. Detroit Diesel proposes BACT for the bake and drying ovens to be the use of afterburners for VOC and HAPs. 4 Ibidat th 5 EPA Air Pollution Control Technology Fact Sheet, Thermal Incineration, EPA-452/F-03-022 6 Ibid Burn-Off Ovens - BACT Summary Table BACT Natural Gas Natural Gas Natural Gas Natural Gas -- -- BACT Condition Good Combustion Good Combustion Good Combustion Good Combustion -- -- BACT Condition Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption BACT -- -- -- Afterburner Afterburner Afterburner NOX CO SO2 PM10/PM2.5 VOC HAP Unit (lb/hr) Emission Rate 0.76 0.008 0.008 0.01515 0.015 -- Comfort HVAC Heating Units Up to four 10 MMBtu/hr direct-fired furnaces are proposed to be installed to provide comfort heating to the plant floor. Direct-fired heaters do not use a heat exchanger and instead use the combustion exhaust gas as the heated air that is directed into the building. The benefit of this design is more heat recovery and therefore, less fuel consumption. Additionally, these units are designed to meet the American National Standards Institute standards to ensure public health. These units are replacing existing units and the natural gas combusted in them is accounted for in the sites natural gas limit. Low NOX and Ultra-low NOX Burners Low-NOX and ultra-low NOX burner utilize various flame cooling and flame shaping designs to balance the generation of NOX and CO emissions. The unit burners have been designed to operate with staged combustion that results in flame cooling and therefore a reduction in NOX formation. The burner design must meet specific NOX and CO health standards required for direct-fired heating equipment and has been designed to minimize each pollutant while not elevating any one pollutant above the health standards. Modification beyond what has been designed by the manufacturer is considered technically infeasible and not considered further. Good Operating Practices and Maintenance NOX and CO are formed from the combustion of natural gas. The formation of these pollutants can be minimized by practicing good operating practices and maintaining equipment properly to achieve optimal air to fuel ratios. Detroit Reman. proposes good operating practices, the use of natural gas as a primary fuel, and the site wide natural gas limit as being effective for minimizing the CO and NOX emission from the HVAC heating units. SO2 Emissions SO2 is a combustion product formed when sulfur containing fuel is combusted. The use of clean gaseous fuel, such as natural gas which has been desulfurized, minimizes the formation of SO2. Detroit Reman proposes the combustion of natural gas as the primary fuel in the HVAC heaters to be BACT for SO2 emissions. VOC and HAP emissions from the comfort heating units are natural gas combustion products. The use of clean gaseous fuel, such as natural gas and proper maintenance and operation of the units minimize the formation of VOC and HAPs. Detroit Reman proposes the combustion of natural gas as the primary fuel in the HVAC units and proper maintenance and operation to be BACT for VOC and HAP emissions. HVAC Units - BACT Summary Table NOX 2 10 2.5 BACT Condition Natural Gas Natural Gas Natural Gas Natural Gas Natural Gas Natural Gas BACT Condition Good Combustion Good Combustion Good Combustion Good Combustion Good Combustion Good Combustion BACT Condition Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption Site-wide Natural Gas Consumption NOX CO SO2 PM10/PM2.5 VOC HAP Unit (lb/hr) Emission Rate 0.98 0.82 0.006 0.075 0.054 4.6 E-09 Blow-off Operations Following the bake and drying ovens and/or other blasting operations, equipment is blown off to remove residual particles. There are four blow-off stations that vent externally and each are controlled by a dust collector. The dust collector uses cartridge filters that have the capability of achieving a grain loading of 0.002 grains/scf.7 As stated by the manufacturer, many factors can affect the use and performance of the baghouses and does not the manufacturer does not guarantee the achievable grain loading.8 Detroit Reman. has conservatively assumed a grain loading of 0.005 grains/scf for estimating emissions. Detroit Reman. proposes that the use of particle filters as meeting BACT for the blow-off operations. 7 Donaldson, Emission Statement for Industrial Dust Collectors with Ultra Web Filter Media, DT 23032016 8 Ibid Fuel Tanks Detroit Reman. is requesting to include in their permit one gasoline tank and one diesel tank. The fuel tanks have the potential to emit VOC and HAP as standing and working losses. Standing losses are associated with temperature change in the tanks while working losses are associated with the level changes in the tank. Temperature changes in the tank can be minimize by keeping the tanks in good condition (e.g., keeping the tank surfaces clean and paint in good condition). Working losses can be minimized by submerged loading which minimizes the vapors formed in the tank during loading. Detroit Reman. proposes BACT for the fuel tanks to be proper maintenance and submerged loading. Form 1 Date __________________ Notice of Intent (NOI) Application Checklist Company __________________ Utah Division of Air Quality New Source Review Section Source Identification Information [R307-401-5] 1. Company name, mailing address, physical address and telephone number  2. Company contact (Name, mailing address, and telephone number) 3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates  5. Source Standard Industrial Classification (SIC) code  6.Area designation (attainment, maintenance, or nonattainment) 7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.) 8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers  NOI Application Information: [R307-401]           N/A  N/A  A.Air quality analysis (air model, met data, background data, source impact analysis) N/A  1.Detailed description of the project and source process 2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule 4.Description of changes to the process, production rates, etc. 5.Site plan of source with building dimensions, stack parameters, etc. 6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment 7.Emissions Related Information: [R307-401-2(b)] A.Emission calculations for each new/modified unit and site-wide (Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant C.All speciated HAP emissions (list in lbs/hr) 8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410] A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations) 9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403] A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements B.Alternative site analysis, Major source ownership compliance certification 10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] B.Visibility impact analysis, Class I area impact 11.Signature on Application N/A  Note: The Division of Air Quality will not accept documents containing confidential information or data. Documents containing confidential information will be returned to the Source submitting the application. iJoc.i-iirKji'il Dale:' (X!/AS,‘2C U DAQ 2018-002271 Page 1 of 1 Company___________________________ Site _____________________________ Form 5 Emissions Information Criteria/GHGs/ HAP’s Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e 2 CO2e 2 4 2 6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** ( Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Jccumonl Dcjlc: 02/28/2018 Page 1 of 1 Form 4 Company____________________________ Project Information Site ______________________________ Utah Division of Air Quality New Source Review Section Process Data - For Modification/Amendment ONLY 1. Permit Number_______________________________ If submitting a new permit, then use Form 3 Requested Changes 2. Name of process to be modified/added: _______________________________ End product of this process: _______________________________ 3. Permit Change Type: New Increase* Equipment Process Condition Change ____________________ Other ______________________________ Other ______________________________ Other ______________________________ 4. Does new emission unit affect existing permitted process limits? Yes No 5. Condition(s) Changing: 6. Description of Permit/Process Change** 7. New or modified materials and quantities used in process. ** Material Quantity Annually 8. New or modified process emitting units ** Emitting Unit(s) Capacity(s) Manufacture Date(s) *If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an emissions increase and a public comment period. **If additional space is required, please generate a document to accommodate and attach to form. Doc.uim:i'ii D^lc: 02/28/2018 DAQ 2018-002274 1 of 1 Form 2 Date ____________ Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: □ Initial Approval Order □Approval Order Modification 1.Company name and mailing address: ____________________________ ____________________________ ____________________________ Phone No.: ( ) Fax No.: ( ) 2.Company** contact for environmental matters: ____________________________ Phone no.: ( ) Email: _______________________ ** Company contact only; consultant or independent contractor contact 3.Source name and physical address (if different from above):____________________________ ____________________________ ____________________________ Phone no.: ( ) 4.Source Property Universal Transverse Mercator coordinates (UTM), including System and Datum: UTM:_________________________ X:____________________________ Y:____________________________ 5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC) 7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____ 8.Brief (50 words or less) description of process. 9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal □ Both Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. _______________________________________ Name (Type or print) Telephone Number: ( ) Email: Date: DAO 2018 002272