DAQ-2024-004986

DAQE-AN101810010-24

{{$d1 }}

Aaron Lee
Companion Systems Incorporated
645 West 200 North
P.O. Box 540636
North Salt Lake, UT 84054
[e-mail]

Dear Mr. Lee:

Re: Approval Order: Modification to Approval Order DAQE-AN101810009-17 to Update
Equipment
Project Number: N101810010

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on January
10, 2023. Companion Systems Incorporated must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Enqiang He, who can be contacted at [phone] or
[e-mail]. 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:EH:jg

cc: Davis County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

February 1, 2024

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-AN101810010-24
Modification to Approval Order DAQE-AN101810009-17
to Update Equipment

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Companion Systems Incorporated

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

February 1, 2024
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.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN101810010-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Companion Systems Incorporated Companion Systems Incorporated

Mailing Address Physical Address
645 West 200 North
P.O. Box 540636
North Salt Lake, UT 84054
645 West 200 North
North Salt Lake, UT 84054

Source Contact UTM Coordinates
Name: Aaron Lee 421,880 m Easting
Phone: [phone] Ext 364 4,522,035 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3578 (Calculating & Accounting Machines, Except Electronic Computers)

SOURCE INFORMATION
General Description
Companion Systems Incorporated produces enclosures for automatic bank teller machines in North Salt
Lake City in Davis County. The processes involved in the enclosure production include molding
fabrication, gelcoating, barrier coating/laminating, and painting. The company operates up to 20 hours
per day and 360 days per year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA,
Davis County
Airs Source Size: B

Applicable Federal Standards
None

Project Description
The source has requested to add a new paint booth. A new heating unit rated at 2.5 MMBtu/hr will
provide heated air to the paint booth. The paint booth will be equipped with filters with a control
DAQE-AN101810010-24
Page 4

efficiency of 98.9% to control particulate emissions from the painting operations. This new paint booth is
intended to allow the painted products more drying time and also allow larger parts to be painted. The
new paint booth will not increase paint consumption. There are no emission increases from the sitewide
painting operations. Emissions from the heating unit are added to the sitewide total emissions.

The source has also requested to remove the following processes and equipment from the
AO DAQE-AN101810009-17:

II.A.9, Acetone Recycling, and
II.A.13, One (1) Cut and Buff Booth (Back Shop). The booth did not vent to the atmosphere.

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 1290 1722.00
Carbon Monoxide 0.90 1.10
Nitrogen Oxides 1.08 1.36
Particulate Matter - PM10 0.08 3.24
Particulate Matter - PM2.5 0.08 0.12
Volatile Organic Compounds 0.06 15.06

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Cadmium Compounds (CAS #CAE750) 0 20
Chromium Compounds (CAS #CMJ500) 0 20
Dimethyl Phthalate (CAS #131113) 0 500
Ethyl Benzene (CAS #100414) 0 1000
Glycol Ethers (CAS #EDF109) 0 40
Hexane (CAS #110543) 40 40
Lead Chromate (CAS #18454121) 0 80
Methanol (CAS #67561) 0 40
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 600
Methyl Methacrylate (CAS #80626) 0 800
Methylene Chloride (Dichloromethane) (CAS #75092) 0 440
Styrene (CAS #100425) 0 15000
Toluene (CAS #108883) 0 1000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2500
Change (TPY) Total (TPY)
Total HAPs 0.02 11.04

DAQE-AN101810010-24
Page 5

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

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 Companion Systems Incorporated
Manufacturer of Enclosures of Bank Teller Machines

II.A.2 Tooling Gelcoat Booth
Equipment: Air, airless, air assist and HVLP spray guns; two (2) exhaust stacks

II.A.3 Tooling Laminating
Equipment: One (1) internal mix airless chop gun and one (1) spray gun; two (2) exhaust stacks

DAQE-AN101810010-24
Page 6

II.A.4 Gelcoat/Paint Booths
Gelcoat/paint booth
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack
Paint booth with 1 MMBtu/hr natural gas-fired roof-mounted heater
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.5 Production Fabrication Area
Barrier coat and lamination (Chop Booth)
Equipment: One (1) flow coat chop gun; one (1) internal mix gun, one (1) spray gun, and three
(3) exhaust stacks

II.A.6 Production Grinding
Two (2) booths, mold removal, clean up and assembly
Equipment: one (1) dust collector

II.A.7 Front Shop North Paint Booths (total 5 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.8 Back Shop South Paint Booths (total 2 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.9 Back Shop Enclosed Paint Booth
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.10 Back Shop Enclosed Paint Booth
Natural gas-fired heater rated at 1 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.11 Back Shop Enclosed Paint Spray Booth - new
Natural gas-fired heater rated at 2.5 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack

II.A.12 Eight (8) Closed Dip Tanks
Located at:
Tooling gelcoat booth (1)
Tooling laminating area (1)
Production gelcoating area (1)
Laminating area (2)
Chop booth (1)
North paint area (1)
Back shop paint area (1)

II.A.13 Dust Collectors (for information only)
One (1) Pattern Shop Torit dust collector (vents back into the building)
One (1) Tooling Dust Collector (vents back into the building)

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Companion Systems Incorporated shall comply with the following requirements
II.B.1.a The owner/operator shall vent the air streams from the Pattern Shop Torit back into the building.
[R307-401-8]

DAQE-AN101810010-24
Page 7

II.B.1.b The owner/operator shall vent the air streams from the Tooling Dust Collector back into the
building. [R307-401-8]

II.B.1.c The owner/operator shall install filters in the work areas in II.A.2 through II.A.5 and II.A.7
through II.A.11 to control process streams from their respective processes. All exhaust air from
the work areas shall be routed through their respective filters before being vented to the
atmosphere. The filters shall be maintained and replaced in accordance with manufacturer's
recommendations or instructions. [R307-401-8]

II.B.1.d The owner/operator shall not allow visible emissions from the following emission points to
exceed the following limits:

A. All filters and dust collectors - 10% opacity

B. All paint booths - 10% opacity

C. All-natural gas combustion units - 10% opacity.

[R307-401-8]

II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.e The owner/operator shall not exceed 20 hours per calendar day for each of the following
processes:

A. Mold fabrication

B. Production gelcoat

C. Barrier coat/ laminating

D. Painting.

[R307-401-8]

II.B.1.e.1 The owner/operator shall calculate total hours in a calendar day by adding all operating hours
from midnight to midnight. Hours of operation shall be kept in an operations log by a
supervisor. [R307-401-8]

II.B.1.f The owner/operator shall not exceed 360 operating days per rolling 12-month period for each of
the following processes:

A. Mold fabrication

B. Production gelcoat

C. Barrier coat/ laminating

D. Painting.

[R307-401-8]

DAQE-AN101810010-24
Page 8

II.B.1.f.1 The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from
the previous 12 months

B. Determine operating days by the supervisor monitoring and maintaining the
operations log

C. Keep the records of operation on a daily basis

D. Keep the records of operation for all periods when the plant is in operation.

[R307-401-8]

II.B.1.g The owner/operator shall only use natural gas as a fuel. [R307-401-8]

II.B.1.h The owner/operator shall comply with applicable requirements in R307-342, 350, and 353.
[R307-342, R307-350, R307-353]

II.B.2 VOC & HAP Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting,
coating, and/or cleaning) on site:

15.00 tons per rolling 12-month period for VOCs

0.25 tons per rolling 12-month period for dimethylphalate

0.50 tons per rolling 12-month period for ethyl benzene

0.02 tons per rolling 12-month period for glycol ether

0.02 tons per rolling 12-month period for methanol

0.40 tons per rolling 12-month period for methyl methacrylate

0.22 tons per rolling 12-month period for methylene chloride

0.30 tons per rolling 12-month period for methyl isobutyl ketone

7.50 tons per rolling 12-month period for styrene

0.50 tons per rolling 12-month period for toluene

1.25 tons per rolling 12-month period for xylene

0.01 tons per rolling 12-month period for cadmium compound

0.01 tons per rolling 12-month period for chromium compound

0.04 tons per rolling 12-month period for lead chromate, and

11.02 tons per rolling 12-month period for all HAPs combined.

[R307-401-8]

DAQE-AN101810010-24
Page 9

II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]

[R307-401-8]

II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs
reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the
quantities calculated above to provide the monthly total emissions of VOCs and HAPs.
[R307-401-8]

II.B.2.a.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used

C. The density of each material used

D. The volume of each VOC- and HAP-emitting material used

E. The amount of VOCs and the amount of each HAP emitted from each material

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled
from each material

G. The total amount of VOCs, the total amount of each HAP, and the total amount
of all HAPs combined emitted from all materials (in tons).

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN101810009-17 dated December 6, 2017
Incorporates NOI dated January 10, 2023
Incorporates additional information dated September 13, 2023
Incorporates additional information dated November 20, 2023
Incorporates additional information dated November 24, 2023

DAQE-AN101810010-24
Page 10

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-IN101810010-23

December 21, 2023

Aaron Lee
Companion Systems Incorporated
645 West 200 North
P.O. Box 540636
North Salt Lake, UT 84054
[e-mail]

Dear Mr. Lee:

Re: Intent to Approve: Modification to Approval Order DAQE-AN101810009-17 to Update
Equipment
Project Number: N101810010

The attached document is the Intent to Approve (ITA) for the above-referenced project. The Intent to
Approve 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 Intent to Approve should include the engineer's name, Mr. Enqiang He, as
well as the DAQE number as shown on the upper right-hand corner of this letter. Mr. Enqiang He, can be
reached at [phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:EH:jg

cc: Davis County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN101810010-23
Modification to Approval Order DAQE-AN101810009-17 to Update
Equipment

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Companion Systems Incorporated

Issued On
December 21, 2023

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

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.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-IN101810010-23
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Companion Systems Incorporated Companion Systems Incorporated

Mailing Address Physical Address
645 West 200 North
P.O. Box 540636
645 West 200 North
North Salt Lake, UT 84054
North Salt Lake, UT 84054

Source Contact UTM Coordinates
Name Aaron Lee 421,880 m Easting
Phone [phone] Ext 364 4,522,035 m Northing
Email [e-mail] Datum NAD83
UTM Zone 12

SIC code 3578 (Calculating & Accounting Machines, Except Electronic Computers)

SOURCE INFORMATION
General Description
Companion Systems Incorporated produces enclosures for automatic bank teller machines in North Salt
Lake City in Davis County. The processes involved in the enclosure production include molding
fabrication, gelcoating, barrier coating/laminating, and painting. The company operates up to 20 hours
per day and 360 days per year.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT Particulate matter less than 2.5 microns
in size NAA
Davis County
Airs Source Size: B

Applicable Federal Standards
None
Project Description
The source has requested to add a new paint booth. A new heating unit rated at 2.5 MMBtu/hr will
provide heated air to the paint booth. The paint booth will be equipped with filters with a control
efficiency of 98.9% to control particulate emissions from the painting operations. This new paint booth is
intended to allow the painted products more drying time and also allow larger parts to be painted. The
new paint booth will not increase paint consumption. There are no emission increases from the sitewide
painting operations. Emissions from the heating unit are added to the sitewide total emissions.
DAQE-IN101810010-23
Page 4

The source has also requested to remove the following processes and equipment from the Approval Order
DAQE-AN101810009-17:

- II.A.9, Acetone Recycling, and
- II.A.13, One (1) Cut and Buff Booth (Back Shop). The booth did not vent to the atmosphere.

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 (Tons
per year)
Total (Tons
per year)
CO2 Equivalent 1290 1722.00
Carbon Monoxide 0.90 1.10
Nitrogen Oxides 1.08 1.36
Particulate Matter - Particulate matter less than 10 microns in size 0.08 3.24
Particulate Matter - PM2.5 0.08 0.12
Volatile Organic Compounds 0.06 15.06

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Cadmium Compounds (CAS #CAE750) 0 20
Chromium Compounds (CAS #CMJ500) 0 20
Dimethyl Phthalate (CAS #131113) 0 500
Ethyl Benzene (CAS #100414) 0 1000
Glycol Ethers (CAS #EDF109) 0 40
Hexane (CAS #110543) 40 40
Lead Chromate (CAS #18454121) 0 80
Methanol (CAS #67561) 0 40
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 600
Methyl Methacrylate (CAS #80626) 0 800
Methylene Chloride (Dichloromethane) (CAS #75092) 0 440
Styrene (CAS #100425) 0 15000
Toluene (CAS #108883) 0 1000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2500
Change (Tons
per year)
Total (Tons
per year)
Total HAPs 0.02 11.04

PUBLIC NOTICE STATEMENT

The Notice of Intent for the above-referenced project has been evaluated and has been found to be
consistent with the requirements of Utah Administrative Code 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 Approval Order by the Director.

DAQE-IN101810010-23
Page 5

A 30-day public comment period will be held in accordance with Utah Administrative Code R307-401-7.
A notification of the intent to approve will be published in the Ogden Standard Examiner on December
23, 2023. 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 comment. If anyone so requests a public hearing
within 15 days of publication, it will be held in accordance with Utah Administrative Code 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
Approval Order may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality Approval Order 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 Approval Order conform to
those used in the Utah Administrative Code R307 and 40 CFR. Unless noted otherwise,
references cited in these Approval Order conditions refer to those rules. [R307-101]

I.2 The limits set forth in this Approval Order shall not be exceeded without prior approval.
[R307-401]

I.3 Modifications to the equipment or processes approved by this Approval Order that could affect
the emissions covered by this Approval Order must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this Approval Order 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 Approval Order 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 Approval Order shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with Utah Administrative Code R307-107. General
Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with Utah Administrative Code 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 Approval Order may become
invalid if construction is not commenced within 18 months from the date of this Approval
Order 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.: New Source Review
Section. [R307-401-18]

DAQE-IN101810010-23
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality Approval Order 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 Companion Systems Inc.
Manufacturer of Enclosures of Bank Teller Machines

II.A.2 Tooling Gelcoat Booth
Equipment: Air, airless, air assist and HVLP spray guns; two (2) exhaust stacks

II.A.3 Tooling Laminating
Equipment: One (1) internal mix airless chop gun and one (1) spray gun; two (2) exhaust stacks

II.A.4 Gelcoat/Paint Booths
Gelcoat/paint booth
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack
Paint booth with 1 MMBtu/hr natural gas-fired roof-mounted heater
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.5 Production Fabrication Area
Barrier coat and lamination (Chop Booth)
Equipment: One (1) flow coat chop gun; one (1) internal mix gun, one (1) spray gun, and three
(3) exhaust stacks

II.A.6 Production Grinding
Two (2) booths, mold removal, clean up and assembly
Equipment: one (1) dust collector

II.A.7 Front Shop North Paint Booths (total 5 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.8 Back Shop South Paint Booths (total 2 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.9 Back Shop Enclosed Paint Booth
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.10 Back Shop Enclosed Paint Booth
Natural gas-fired heater rated at 1 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.11 Back Shop Enclosed Paint Spray Booth - new
Natural gas-fired heater rated at 2.5 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack

DAQE-IN101810010-23
Page 7

II.A.12 Eight (8) Closed Dip Tanks
Located at:
Tooling gelcoat booth (1)
Tooling laminating area (1)
Production gelcoating area (1)
Laminating area (2)
Chop booth (1)
North paint area (1)
Back shop paint area (1)

II.A.13 Dust Collectors (for information only)
One (1) Pattern Shop Torit dust collector (vents back into the building)
One (1) Tooling Dust Collector (vents back into the building)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality Approval Order 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 Companion Systems Incorporated shall comply with the following requirements
II.B.1.a The owner/operator shall vent the air streams from the Pattern Shop Torit back into the building.
[R307-401-8]

II.B.1.b The owner/operator shall vent the air streams from the Tooling Dust Collector back into the
building. [R307-401-8]

II.B.1.c The owner/operator shall install filters in the work areas in II.A.2 through II.A.5 and II.A.7
through II.A.11 to control process streams from their respective processes. All exhaust air from
the work areas shall be routed through their respective filters before being vented to the
atmosphere. The filters shall be maintained and replaced in accordance with manufacturer's
recommendations or instructions. [R307-401-8]

II.B.1.d The owner/operator shall not allow visible emissions from the following emission points to
exceed the following limits:

A. All filters and dust collectors - 10% opacity

B. All paint booths - 10% opacity

C. All-natural gas combustion units - 10% opacity.

[R307-401-8]

II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted according to Title
40 of the Code of Federal Regulations 60, Appendix A, Method 9. [R307-401-8]

DAQE-IN101810010-23
Page 8

II.B.1.e The owner/operator shall not exceed 20 hours per calendar day for each of the following
processes:

A. Mold fabrication

B. Production gelcoat

C. Barrier coat/ laminating

D. Painting.

[R307-401-8]

II.B.1.e.1 The owner/operator shall calculate total hours in a calendar day by adding all operating hours
from midnight to midnight. Hours of operation shall be kept in an operations log by a
supervisor. [R307-401-8]

II.B.1.f The owner/operator shall not exceed 360 operating days per rolling 12-month period for each of
the following processes:

A. Mold fabrication

B. Production gelcoat

C. Barrier coat/ laminating

D. Painting.

[R307-401-8]

II.B.1.f.1 The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from
the previous 12 months

B. Determine operating days by the supervisor monitoring and maintaining the
operations log

C. Keep the records of operation on a daily basis

D. Keep the records of operation for all periods when the plant is in operation.

[R307-401-8]

II.B.1.g The owner/operator shall only use natural gas as a fuel. [R307-401-8]

II.B.1.h The owner/operator shall comply with applicable requirements in R307-342, 350, and 353.
[R307-342, R307-350, R307-353]

DAQE-IN101810010-23
Page 9

II.B.2 VOC & Hazardous air pollutant(s) Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting,
coating, and/or cleaning) on site:

15.00 tons per rolling 12-month period for VOCs

0.25 tons per rolling 12-month period for dimethylphalate

0.50 tons per rolling 12-month period for ethyl benzene

0.02 tons per rolling 12-month period for glycol ether

0.02 tons per rolling 12-month period for methanol

0.40 tons per rolling 12-month period for methyl methacrylate

0.22 tons per rolling 12-month period for methylene chloride

0.30 tons per rolling 12-month period for methyl isobutyl ketone

7.50 tons per rolling 12-month period for styrene

0.50 tons per rolling 12-month period for toluene

1.25 tons per rolling 12-month period for xylene

0.01 tons per rolling 12-month period for cadmium compound

0.01 tons per rolling 12-month period for chromium compound

0.04 tons per rolling 12-month period for lead chromate, and

11.02 tons per rolling 12-month period for all Hazardous air pollutant(s) combined.

[R307-401-8]

II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% Hazardous air pollutant(s) by Weight/100] x [Density] x [Volume Consumed]

[R307-401-8]

II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and
Hazardous air pollutant(s) reclaimed. The owner/operator shall subtract the amount of VOCs
and Hazardous air pollutant(s) reclaimed from the quantities calculated above to provide the
monthly total emissions of VOCs and HAPs. [R307-401-8]

DAQE-IN101810010-23
Page 10

II.B.2.a.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each Hazardous air pollutant(s)
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 Hazardous air pollutant(s) emitted
from each material

F. The amount of VOCs and the amount of each Hazardous air pollutant(s)
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]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN101810009-17 dated December 6, 2017
Incorporates NOI dated January 10, 2023
Incorporates additional information dated September 13, 2023
Incorporates additional information dated November 20, 2023
Incorporates additional information dated November 24, 2023

DAQE-IN101810010-23
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
National
Ambient Air
Quality
Standards
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
Particulate
matter less than
10 microns in
size
Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
Potential to emit 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
Tons per year Tons per year
UAC Utah Administrative Code
DAQE-IN101810010-23
Page 12

VOC Volatile organic compounds

Companion Systems Incorporated 10181 0010 - Page 1 of 2
FILER
Jeree Greenwood
[e-mail]
[phone]
FILING FOR
Standard-Examiner
Columns Wide:1 Ad Class:Legals
INTERIM AD DRAFT
T h i s is t he p r oo f o f yo ur ad sc he du l e d to r u n in S t an d a rd -E xa m i n e r o n t he d a te s in dic ate d be l ow. If
c h a n ge s a r e ne ed ed , p l ea se co nt a ct us pr i o r to d ea dlin e a t (8 01 ) 6 25 -4 30 2.
Notice ID: vqRKnlzvL101uLlDyVLj | Proof Updated: Dec. 20, 2023 at 02:02pm MST
Notice Name: Companion Systems Incorporated 10181 0010
This is not an invoice. Below is an estimated price, and it is
subject to change. You will receive an invoice with the final
price upon invoice creation by the publisher.
12/23/2023: Custom 295.72
Base Affidavit Fee 12.00
Subtotal $307.72
Tax $0.00
Processing Fee $30.77
Total $338.49
See Proof on Next Page
Companion Systems Incorporated 10181 0010 - Page 2 of 2
Companion Systems Incorporated 10181 0010 - Page 1 of 1
[def:$signername|printname|req|signer1] [def:$signersig|sig|req|signer1] [def:$notarysig|sig|req|notary] [def:$date|date|req|notary] [def:$state|state|req|notary] [def:$county|county|req|notary] [def:$disclosure|disclosure|req|notary] [def:$seal|seal|req|notary]
AFFIDAVIT OF PUBLICATION
ACCOUNT #DESCRIPTION TIMES PROOF TOTAL CHARGES
vqRKnlzvL101uLlDyVLj 1 .00 338.49
State of New Jersey, County of Hudson, ss:
Ayesha Carletta M Cochran-Worthen, being first duly sworn,
deposes and says: That (s)he is a duly authorized signatory of
Column Software, PBC, duly authorized agent of Standard-
Examiner, a newspaper printed and published in the City of Ogden,
County of Weber, Davis, Box Elder and Morgan, State of Utah, and
that this affidavit is Page 1 of 1 with the full text of the sworn-to
notice set forth on the pages that follow, and the hereto attached.
That said newspaper was regularly issued and circulated on those
dates. Same was also published online at utahlegals.com,
according to Section 45-1-101 -Utah Code Annotated, beginning on
the first date of publication, for at least 30 days thereafter and a
minimum of 30 days prior to the date of scheduled.
PUBLICATION DATES:
Dec. 23, 2023
NOTICE ID: vqRKnlzvL101uLlDyVLj
PUBLISHER ID: UC0085
NOTICE NAME: Companion Systems Incorporated 10181 0010
Publication Fee: 338.49
[$signersig ]
(Signed)______________________________________ [$seal]
VERIFICATION
State of New Jersey
County of Hudson
Subscribed in my presence and sworn to before me on this: [$date]
[$notarysig ]
______________________________
Notary Public
[$disclosure]

12/27/2023
This notarial act involved the use of communication technology

DAQE-NN101810010-23

December 21, 2023

Ogden Standard Examiner
Legal Advertising Department
332 Standard Way
P.O. Box 12790
Ogden, Utah 84412

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard
Examiner (Account Number: 100331) on December 23, 2023.

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 [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council
cc: Davis County

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN101810010-23
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: Companion Systems Incorporated
Location: Companion Systems Incorporated – North Salt Lake, UT
Project Description: Companion Systems Incorporated produces enclosures for automatic bank teller
machines in North Salt Lake City, Davis County, Utah. The processes involved
in the enclosure production include molding fabrication, gelcoating, barrier
coating/laminating, and painting. The company conducts up to 20 hours per day
and 360 days per year of operations of these manufacturing processes. The
company has requested to add a new paint booth and an associated air heating
unit. Particulate emissions from the booth will be controlled by filters. In
addition, the facility will remove acetone recycling process and the cut and buff
booth from its operations. Site-wide emissions will be adjusted to reflect natural
gas combustion emissions from the air heating unit.

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 January 22, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. 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: December 23, 2023

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN101810010
November 29, 2023

Aaron Lee
Companion Systems Incorporated
645 West 200 North
P.O. Box 540636
North Salt Lake, UT 84054
[e-mail]

Dear Eston Kimber,

Re: Engineer Review:
Modification to AO DAQE-AN101810009-17 to Update Equipment
Project Number: N101810010

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. Companion
Systems Incorporated should complete this review within 10 business days of receipt.

Companion Systems Incorporated should contact Mr. Enqiang He at [phone] if there are
questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Mr. Enqiang He at [e-mail] 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 Companion Systems Incorporated does not respond to this letter within 10 business days, the project
will move forward without source concurrence. If Companion Systems Incorporated has concerns that
cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.

Approval Signature _____________________________________________________________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N101810010
Owner Name Companion Systems Incorporated
Mailing Address 645 West 200 North
P.O. Box 540636
North Salt Lake, UT, 84054

Source Name Companion Systems Incorporated
Source Location 645 West 200 North
North Salt Lake, UT 84054

UTM Projection 421,880 m Easting, 4,522,035 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3578 (Calculating & Accounting Machines, Except Electronic
Computers)

Source Contact Aaron Lee
Phone Number [phone] Ext. 364
Email [e-mail]

Billing Contact Aaron Lee
Phone Number [phone] Ext. 364
Email [e-mail]

Project Engineer Mr. Enqiang He, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted January 10, 2023
Date of Accepted Application November 28, 2023

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 2
SOURCE DESCRIPTION

General Description
Companion Systems Incorporated produces enclosures for automatic bank teller machines in
North Salt Lake City in Davis County. The processes involved in the enclosure production
include molding fabrication, gelcoating, barrier coating/laminating, and painting. The company
operates up to 20 hours per day and 360 days per year.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA and Northern Wasatch Front O3 NAA
Davis County
Airs Source Size: B

Applicable Federal Standards
None

Project Proposal
Modification to AO DAQE-AN101810009-17 to Update Equipment

Project Description
The source has requested to add a new paint booth. A new heating unit rated at 2.5 MMBtu/hr
will provide heated air to the paint booth. The paint booth will be equipped with filters with a
control efficiency of 98.9% to control particulate emissions from the painting operations. This
new paint booth is intended to allow the painted products more drying time and also allow larger
parts to be painted. The new paint booth will not increase paint consumption. There are no
emission increases from the sitewide painting operations. Emissions from the heating unit are
added to the sitewide total emissions.

The source has also requested to remove the following processes and equipment from the AO
DAQE-AN101810009-17:
II.A.9, Acetone Recycling, and
II.A.13, One (1) Cut and Buff Booth (Back Shop). The booth did not vent to the atmosphere.

EMISSION IMPACT ANALYSIS
All criteria pollutant emissions are either below their respective modeling thresholds, or the area is
nonattainment for PM2.5; therefore, modeling is not required for the modification. [Last updated November 29,
2023]

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
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)
CO2 Equivalent 1290 1722.00
Carbon Monoxide 0.90 1.10
Nitrogen Oxides 1.08 1.36
Particulate Matter - PM10 0.08 3.24
Particulate Matter - PM2.5 0.08 0.12
Volatile Organic Compounds 0.06 15.06

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Cadmium Compounds (CAS #CAE750) 0 20
Chromium Compounds (CAS #CMJ500) 0 20
Dimethyl Phthalate (CAS #131113) 0 500
Ethyl Benzene (CAS #100414) 0 1000
Glycol Ethers (CAS #EDF109) 0 40
Hexane (CAS #110543) 40 40
Lead Chromate (CAS #18454121) 0 80
Methanol (CAS #67561) 0 40
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 600
Methyl Methacrylate (CAS #80626) 0 800
Methylene Chloride (Dichloromethane) (CAS #75092) 0 440
Styrene (CAS #100425) 0 15000
Toluene (CAS #108883) 0 1000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2500
Change (TPY) Total (TPY)
Total HAPs 0.02 11.04

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding new spray booth
The new paint booth will be equipped with filters to control particulate emissions from the painting
operations. Exhaust from the spray booth will be limited to 10% opacity. The associated air heater
rated at 2.5 MMBtu/hr is fired with natural gas, and is exempt per R307-401-10. The Minor NSR
Section recommends the filters and opacity limit as BACT for controlling PM from the paint
booth.

This new paint booth is intended to allow the painted products more drying time and also allow
larger parts to be painted. The proposed paint booth will share the current painting loads with the
ten (10) existing paint booths; therefore, adding the new paint booth will not increase paint
consumption or emissions. VOC emissions from the paint booth would average at 1.36 tpy. For
such a small amount of emissions, the available control technologies for paint booths, such as
thermal or catalytic oxidizers, would not be economically feasible. The source is located in a
nonattainment area for ozone. Like the ten (10) existing booths, the proposed paint booth will be
subject to applicable requirements in UAC R307-342, 350, and 353. The Minor NSR Section
recommends the RACTs as BACT for controlling VOCs from the paint booth. [Last updated
November 29, 2023]

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):

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]

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
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
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 THE APPROVED EQUIPMENT

II.A.1 Companion Systems Inc.
Manufacturer of Enclosures of Bank Teller Machines

II.A.2 Tooling Gelcoat Booth
Equipment: Air, airless, air assist and HVLP spray guns; two (2) exhaust stacks

II.A.3 Tooling Laminating
Equipment: One (1) internal mix airless chop gun and one (1) spray gun; two (2) exhaust
stacks

II.A.4 Gelcoat/Paint Booths
Gelcoat/paint booth
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack
Paint booth with 1 MMBtu/hr natural gas-fired roof-mounted heater
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 6
II.A.5 Production Fabrication Area
Barrier coat and lamination (Chop Booth)
Equipment: One (1) flow coat chop gun; one (1) internal mix gun, one (1) spray gun, and
three (3) exhaust stacks

II.A.6 Production Grinding
Two (2) booths, mold removal, clean up and assembly
Equipment: one (1) dust collector

II.A.7 Front Shop North Paint Booths (total 5 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.8 Back Shop South Paint Booths (total 2 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.9 Back Shop Enclosed Paint Booth
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.10 Back Shop Enclosed Paint Booth
Natural gas-fired heater rated at 1 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.11
NEW
Back Shop Enclosed Paint Spray Booth - new
Natural gas-fired heater rated at 2.5 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack

II.A.12 Eight (8) Closed Dip Tanks
Located at:
Tooling gelcoat booth (1)
Tooling laminating area (1)
Production gelcoating area (1)
Laminating area (2)
Chop booth (1)
North paint area (1)
Back shop paint area (1)

II.A.13 Dust Collectors (for information only)
One (1) Pattern Shop Torit dust collector (vents back into the building)
One (1) Tooling Dust Collector (vents back into the building)

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 REQUIREMENTS AND LIMITATIONS

II.B.1 Companion Systems Incorporated shall comply with the following requirements

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 7
II.B.1.a
NEW
The owner/operator shall vent the air streams from the Pattern Shop Torit back into the
building. [R307-401-8]

II.B.1.b
NEW
The owner/operator shall vent the air streams from the Tooling Dust Collector back into the
building. [R307-401-8]

II.B.1.c
NEW
The owner/operator shall install filters in the work areas in II.A.2 through II.A.5 and II.A.7
through II.A.11 to control process streams from their respective processes. All exhaust air
from the work areas shall be routed through their respective filters before being vented to the
atmosphere. The filters shall be maintained and replaced in accordance with manufacturer's
recommendations or instructions. [R307-401-8]

II.B.1.d
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following limits:

A. All filters and dust collectors - 10% opacity

B. All paint booths - 10% opacity

C. All natural gas combustion units - 10% opacity

[R307-401-8]

II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.e
NEW
The owner/operator shall not exceed 20 hours per calendar day for each of the following
processes:

A. Mold fabrication

B. Production gelcoat

C. Barrier coat/ laminating

D. Painting

[R307-401-8]

II.B.1.e.1
NEW
The owner/operator shall calculate total hours in a calendar day by adding all operating hours
from midnight to midnight. Hours of operation shall be kept in an operations log by a
supervisor. [R307-401-8]

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 8
II.B.1.f
NEW
The owner/operator shall not exceed 360 operating days per rolling 12-month period for each
of the following processes:

A. Mold fabrication

B. Production gelcoat

C. Barrier coat/ laminating

D. Painting

[R307-401-8]

II.B.1.f.1
NEW
The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months

B. Determine operating days by the supervisor monitoring and maintaining the
operations log

C. Keep the records of operation on a daily basis

D. Keep the records of operation for all periods when the plant is in operation

[R307-401-8]

II.B.1.g The owner/operator shall only use natural gas as a fuel. [R307-401-8]

II.B.1.h
NEW
The owner/operator shall comply with applicable requirements in R307-342, 350, and 353.
[R307-342, R307-350, R307-353]

II.B.2
NEW
VOC & HAP Requirements

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 9
II.B.2.a
NEW
The owner/operator shall not emit more than the following from evaporative sources
(painting, coating, and/or cleaning) on site:

15.00 tons per rolling 12-month period for VOCs
0.25 tons per rolling 12-month period for dimethyl phalate
0.50 tons per rolling 12-month period for ethyl benzene
0.02 tons per rolling 12-month period for glycol ether
0.02 tons per rolling 12-month period for methanol
0.40 tons per rolling 12-month period for methyl methacrylate
0.22 tons per rolling 12-month period for methylene chloride
0.30 tons per rolling 12-month period for methyl isobutyl ketone
7.50 tons per rolling 12-month period for styrene
0.50 tons per rolling 12-month period for toluene
1.25 tons per rolling 12-month period for xylene
0.01 tons per rolling 12-month period for cadmium compound
0.01 tons per rolling 12-month period for chromium compound
0.04 tons per rolling 12-month period for lead chromate, and
11.02 tons per rolling 12-month period for all HAPs combined

[R307-401-8]

II.B.2.a.1
NEW
The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]

[R307-401-8]

II.B.2.a.2
NEW
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]

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 10
II.B.2.a.3
NEW
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]

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
Page 11
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN101810009-17 dated December 6, 2017
Incorporates NOI dated January 10, 2023
Incorporates additional information dated September 13, 2023
Incorporates additional information dated November 20, 2023
Incorporates additional information dated November 24, 2023

REVIEWER COMMENTS

1. Comment regarding emission calculations for the natural gas-fired heater:
Emission calculations were based on 2.5 MMBtu/hr heat input operating at 8,760 hrs per year.
Emission factors are from the AP-42 Chapter 1.4. [Last updated November 28, 2023]

2. Comment regarding R307-357 Consumer Products :
The source does not produce consumer products. Therefore, this rule does not apply to the source.
The reference to the rule has been removed. [Last updated November 29, 2023]

3. Comment regarding Federal Standards and Title V Applicability:
Companion Systems Inc. is not a major source, is not subject to any federal standards, and is not a
Title IV source; therefore, it is not a Title V source. [Last updated November 29, 2023]

Engineer Review N101810010: Companion Systems Incorporated
November 29, 2023
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 EPA 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 - 40 CFR 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 UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
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

11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…1/7
Enqiang He <[e-mail]>
Project Reassignment
12 messages
Enqiang He <[e-mail]>Tue, Mar 28, 2023 at 6:04 PM
To: Eston Kimber <[e-mail]>
Hi Eston,
Colby Johnson has left the DAQ. I have taken over your project. Let me know if you
have any questions. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
Eston Kimber <[e-mail]>Wed, Jul 19, 2023 at 10:02 AM
To: Enqiang He <[e-mail]>
Hello EQ , I'm finally geng back around to this project. It seems the process to add equipment has changed
from years past. Computers and I don't get a long...
What do we need to get to you so we can move forward with this paint booth?

From: Enqiang He <[e-mail]>
Sent: Tuesday, March 28, 2023 6:04 PM
To: Eston Kimber <[e-mail]>
Subject: Project Reassignment

[Quoted text hidden]
Enqiang He <[e-mail]>Wed, Jul 19, 2023 at 10:54 AM
To: Eston Kimber <[e-mail]>
Hello Eston,
Thanks for contacting me.
11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…2/7
Colby Johnson, the previous engineer who has left since, sent you an email requesting
more information in February. I'm attaching that email for your reference.
Have you responded to his email yet? Please advise. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
Email (2) - Request for More Information (1).pdf
116K
Eston Kimber <[e-mail]>Wed, Jul 19, 2023 at 1:14 PM
To: Enqiang He <[e-mail]>
I don't see any responses or discussions with him.
I'm leaving Companion Systems next week aer 36 years. I'd like to have as much of this completed as
possible. I'll sll be involved a bit from the sidelines.
I can be contacted via email at [e-mail]

From: Enqiang He <[e-mail]>
Sent: Wednesday, July 19, 2023 10:54 AM
To: Eston Kimber <[e-mail]>
Subject: Re: Project Reassignment

[Quoted text hidden]
Enqiang He <[e-mail]>Wed, Jul 19, 2023 at 1:42 PM
To: Eston Kimber <[e-mail]>
We are still waiting for your responses to Colby's email. Let me know when we can
receive the responses. Thank you.
11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…3/7
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
eston-kimber_e3424ce8-c09c-404d-b6a9-a1352d6ad03a.jpg
19K
Enqiang He <[e-mail]>Wed, Sep 6, 2023 at 12:10 PM
To: Eston Kimber <[e-mail]>, [e-mail]
Hello Eston,
I hope you are still involved with Companion's permitting responsibilities. If not, would
you forward this email to the one who is? Thanks.
I have conducted a technical review on the NOI you submitted early this year. As a
reminder, this project was assigned to Colby who left the DAQ after the assignment. I
took over the project in March. Here are a few questions I'd like to seek your input:
1. The new paint booth. Will the paint booth share the existing work loads with other
existing paint booths? Or will you increase painting activities (using more paints) which
will result in increases in emissions? If this is the case, you need to calculate VOC,
HAPs, PM10 and PM2.5 emissions from the new paint booth.
2. The new 2.5 MMBtu/hr natural gas-fired heat unit. You need to calculate emissions
from this heat unit.
3. The dust/chip collection system. Is this a new system, or does it replace another
similar system? If it is a new system, does it vent to the atmosphere? If yes, then
calculate emissions.
Please provide the information requested above ASAP, preferably within 2 weeks from
today. Let me know if you have any questions. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…4/7
[Quoted text hidden]
E Kimber <[e-mail]>Wed, Sep 13, 2023 at 8:37 PM
To: Enqiang He <[e-mail]>, [e-mail]
Hello, EQ,
Sorry it's taken this long to get back to you. Being semi-retired takes more of my time
than my full time job did... I think I'm doing it wrong. I have put my responses in red
behind your questions. Feel free to contact me if you still have questions.
I have conducted a technical review on the NOI you submitted early this year. As a
reminder, this project was assigned to Colby who left the DAQ after the assignment. I
took over the project in March. Here are a few questions I'd like to seek your input:
1. The new paint booth. Will the paint booth share the existing work loads with other
existing paint booths? Or will you increase painting activities (using more paints) which
will result in increases in emissions? If this is the case, you need to calculate VOC,
HAPs, PM10 and PM2.5 emissions from the new paint booth.
The plan for the new booth is to allow other freshly painted product time to cure prior to
moving it out of the booths. The new booth will not increase output or the quantity of
paint used. The new booth is intended to allow the painted product more dry time and
increase the quality of the product / paint job. The new booth is also much taller than
some of the other booths and will allow some of our larger units to be painted with less
spatial restrictions.
2. The new 2.5 MMBtu/hr natural gas-fired heat unit. You need to calculate emissions
from this heat unit.
Heat units under 5 Million BTU are exempt from air permitting. Refer to R307-401-10
3. The dust/chip collection system. Is this a new system, or does it replace another
similar system? If it is a new system, does it vent to the atmosphere? If yes, then
calculate emissions.
This is a new unit and it will be vented into the building. No calcs needed.
Please provide the information requested above ASAP, preferably within 2 weeks from
today. Let me know if you have any questions. Thanks,
Let me know if you have any questions and I'll do my best to get back to you much
quicker.
I have copied Ryan Nielson (plant manager) with Companion Systems to keep him in
the loop.
[Quoted text hidden]
--
Thank you,
11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…5/7
Eston Kimber
Enqiang He <[e-mail]>Mon, Sep 18, 2023 at 3:44 PM
To: E Kimber <[e-mail]>
Cc: [e-mail]
Hi Eston,
Thanks for answering my questions. I hope you enjoy your retirement!
I agree with you that natural gas equipment under 5 MMBtu/hr is exempt from the
permitting requirements. However, emissions from such equipment will need to be
accounted for in the plant-wide emission totals.
Please let me know if you have any questions. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
Enqiang He <[e-mail]>Wed, Nov 1, 2023 at 11:40 PM
To: E Kimber <[e-mail]>
Cc: [e-mail]
Hello Eston,
I replied to your email on 9/18/23, regarding additional emission information from
natural gas combustion equipment. The equipment may be exempted for being less
than 5 MMBtu/hr, however, the emissions still need to be accounted for in the sitewide
total emissions. Please calculate the emissions and email me the emission calculations
ASAP. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…6/7
E Kimber <[e-mail]>Mon, Nov 20, 2023 at 11:19 AM
To: Enqiang He <[e-mail]>, Ryan Hunsaker <[e-mail]>
EQ,
The following are the PTE calculations I have been able to come up with based on a 520 hour (4 month) operational
schedule of the heat unit on the new spray booth.
PM 10 - 0.16 TPY
PM 2.5 - 0.16 TPY
SOx - 0.01 TPY
NOx - 2.15 TPY
VOC - 0.12 TPY
CO - 1.80 TPY
Lead - 0 TPY
If you have any questions, feel free to contact me. I'm working from home all week.
Thank you,
Eston
[Quoted text hidden]
Enqiang He <[e-mail]>Mon, Nov 20, 2023 at 11:46 AM
To: E Kimber <[e-mail]>
Cc: Ryan Hunsaker <[e-mail]>
Eston,
Did you use a spreadsheet for the calculations? Can I have a copy for that? If not, I'd
like to have the parameters for the calculations. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
E Kimber <[e-mail]>Mon, Nov 20, 2023 at 2:19 PM
To: Enqiang He <[e-mail]>
Cc: Ryan Hunsaker <[e-mail]>
Here you go.
[Quoted text hidden]
11/24/23, 11:30 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…7/7
20231120_141728.jpg
2453K
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…1/7
Enqiang He <[e-mail]>
Project Reassignment
14 messages
Enqiang He <[e-mail]>Tue, Mar 28, 2023 at 6:04 PM
To: Eston Kimber <[e-mail]>
Hi Eston,
Colby Johnson has left the DAQ. I have taken over your project. Let me know if you
have any questions. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
Eston Kimber <[e-mail]>Wed, Jul 19, 2023 at 10:02 AM
To: Enqiang He <[e-mail]>
Hello EQ , I'm finally geng back around to this project. It seems the process to add equipment has changed
from years past. Computers and I don't get a long...
What do we need to get to you so we can move forward with this paint booth?

From: Enqiang He <[e-mail]>
Sent: Tuesday, March 28, 2023 6:04 PM
To: Eston Kimber <[e-mail]>
Subject: Project Reassignment

[Quoted text hidden]
Enqiang He <[e-mail]>Wed, Jul 19, 2023 at 10:54 AM
To: Eston Kimber <[e-mail]>
Hello Eston,
Thanks for contacting me.
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…2/7
Colby Johnson, the previous engineer who has left since, sent you an email requesting
more information in February. I'm attaching that email for your reference.
Have you responded to his email yet? Please advise. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
Email (2) - Request for More Information (1).pdf
116K
Eston Kimber <[e-mail]>Wed, Jul 19, 2023 at 1:14 PM
To: Enqiang He <[e-mail]>
I don't see any responses or discussions with him.
I'm leaving Companion Systems next week aer 36 years. I'd like to have as much of this completed as
possible. I'll sll be involved a bit from the sidelines.
I can be contacted via email at [e-mail]

From: Enqiang He <[e-mail]>
Sent: Wednesday, July 19, 2023 10:54 AM
To: Eston Kimber <[e-mail]>
Subject: Re: Project Reassignment

[Quoted text hidden]
Enqiang He <[e-mail]>Wed, Jul 19, 2023 at 1:42 PM
To: Eston Kimber <[e-mail]>
We are still waiting for your responses to Colby's email. Let me know when we can
receive the responses. Thank you.
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…3/7
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
eston-kimber_e3424ce8-c09c-404d-b6a9-a1352d6ad03a.jpg
19K
Enqiang He <[e-mail]>Wed, Sep 6, 2023 at 12:10 PM
To: Eston Kimber <[e-mail]>, [e-mail]
Hello Eston,
I hope you are still involved with Companion's permitting responsibilities. If not, would
you forward this email to the one who is? Thanks.
I have conducted a technical review on the NOI you submitted early this year. As a
reminder, this project was assigned to Colby who left the DAQ after the assignment. I
took over the project in March. Here are a few questions I'd like to seek your input:
1. The new paint booth. Will the paint booth share the existing work loads with other
existing paint booths? Or will you increase painting activities (using more paints) which
will result in increases in emissions? If this is the case, you need to calculate VOC,
HAPs, PM10 and PM2.5 emissions from the new paint booth.
2. The new 2.5 MMBtu/hr natural gas-fired heat unit. You need to calculate emissions
from this heat unit.
3. The dust/chip collection system. Is this a new system, or does it replace another
similar system? If it is a new system, does it vent to the atmosphere? If yes, then
calculate emissions.
Please provide the information requested above ASAP, preferably within 2 weeks from
today. Let me know if you have any questions. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…4/7
[Quoted text hidden]
E Kimber <[e-mail]>Wed, Sep 13, 2023 at 8:37 PM
To: Enqiang He <[e-mail]>, [e-mail]
Hello, EQ,
Sorry it's taken this long to get back to you. Being semi-retired takes more of my time
than my full time job did... I think I'm doing it wrong. I have put my responses in red
behind your questions. Feel free to contact me if you still have questions.
I have conducted a technical review on the NOI you submitted early this year. As a
reminder, this project was assigned to Colby who left the DAQ after the assignment. I
took over the project in March. Here are a few questions I'd like to seek your input:
1. The new paint booth. Will the paint booth share the existing work loads with other
existing paint booths? Or will you increase painting activities (using more paints) which
will result in increases in emissions? If this is the case, you need to calculate VOC,
HAPs, PM10 and PM2.5 emissions from the new paint booth.
The plan for the new booth is to allow other freshly painted product time to cure prior to
moving it out of the booths. The new booth will not increase output or the quantity of
paint used. The new booth is intended to allow the painted product more dry time and
increase the quality of the product / paint job. The new booth is also much taller than
some of the other booths and will allow some of our larger units to be painted with less
spatial restrictions.
2. The new 2.5 MMBtu/hr natural gas-fired heat unit. You need to calculate emissions
from this heat unit.
Heat units under 5 Million BTU are exempt from air permitting. Refer to R307-401-10
3. The dust/chip collection system. Is this a new system, or does it replace another
similar system? If it is a new system, does it vent to the atmosphere? If yes, then
calculate emissions.
This is a new unit and it will be vented into the building. No calcs needed.
Please provide the information requested above ASAP, preferably within 2 weeks from
today. Let me know if you have any questions. Thanks,
Let me know if you have any questions and I'll do my best to get back to you much
quicker.
I have copied Ryan Nielson (plant manager) with Companion Systems to keep him in
the loop.
[Quoted text hidden]
--
Thank you,
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…5/7
Eston Kimber
Enqiang He <[e-mail]>Mon, Sep 18, 2023 at 3:44 PM
To: E Kimber <[e-mail]>
Cc: [e-mail]
Hi Eston,
Thanks for answering my questions. I hope you enjoy your retirement!
I agree with you that natural gas equipment under 5 MMBtu/hr is exempt from the
permitting requirements. However, emissions from such equipment will need to be
accounted for in the plant-wide emission totals.
Please let me know if you have any questions. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
Enqiang He <[e-mail]>Wed, Nov 1, 2023 at 11:40 PM
To: E Kimber <[e-mail]>
Cc: [e-mail]
Hello Eston,
I replied to your email on 9/18/23, regarding additional emission information from
natural gas combustion equipment. The equipment may be exempted for being less
than 5 MMBtu/hr, however, the emissions still need to be accounted for in the sitewide
total emissions. Please calculate the emissions and email me the emission calculations
ASAP. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…6/7
E Kimber <[e-mail]>Mon, Nov 20, 2023 at 11:19 AM
To: Enqiang He <[e-mail]>, Ryan Hunsaker <[e-mail]>
EQ,
The following are the PTE calculations I have been able to come up with based on a 520 hour (4 month) operational
schedule of the heat unit on the new spray booth.
PM 10 - 0.16 TPY
PM 2.5 - 0.16 TPY
SOx - 0.01 TPY
NOx - 2.15 TPY
VOC - 0.12 TPY
CO - 1.80 TPY
Lead - 0 TPY
If you have any questions, feel free to contact me. I'm working from home all week.
Thank you,
Eston
[Quoted text hidden]
Enqiang He <[e-mail]>Mon, Nov 20, 2023 at 11:46 AM
To: E Kimber <[e-mail]>
Cc: Ryan Hunsaker <[e-mail]>
Eston,
Did you use a spreadsheet for the calculations? Can I have a copy for that? If not, I'd
like to have the parameters for the calculations. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
E Kimber <[e-mail]>Mon, Nov 20, 2023 at 2:19 PM
To: Enqiang He <[e-mail]>
Cc: Ryan Hunsaker <[e-mail]>
Here you go.
[Quoted text hidden]
11/28/23, 11:05 AM State of Utah Mail - Project Reassignment
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-a:r4219692609390248932&simpl=msg-a:r-543506808247036…7/7
20231120_141728.jpg
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Enqiang He <[e-mail]>Fri, Nov 24, 2023 at 11:59 AM
To: E Kimber <[e-mail]>
Cc: Ryan Hunsaker <[e-mail]>
Hi Eston,
I took a look at the emission calculations you sent me. In the NOI you sent early
this year, the natural gas combustion unit was listed at 2.5 MMBtu/hr. However, you
used 5 MMBtu/hr in the emission calculations. Which rated capacity is correct? Please
advise. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
E Kimber <[e-mail]>Fri, Nov 24, 2023 at 1:42 PM
To: Enqiang He <[e-mail]>
Cc: Ryan Hunsaker <[e-mail]>
Good catch! It's 2.5 mill BTU
[Quoted text hidden]
2/8/23, 3:50 PM State of Utah Mail - Utah DAQ Request for More Information
https://mail.google.com/mail/u/0/?ik=1e137a1c28&view=pt&search=all&permmsgid=msg-a%3Ar3580839823407860024&simpl=msg-a%3Ar35808398…1/1
Colby Johnson <[e-mail]>
Utah DAQ Request for More Information
Colby Johnson <[e-mail]>Thu, Jan 12, 2023 at 4:41 PM
To: [e-mail]
Dear Eston Kimber,
My name is Colby Johnson, I'll be the project engineer involved in the requested modifications to your Approval Order
DAQE-AN101810009-17.
We received your letter but before we begin, I'll need a bit more information from you. It appears you've been involved in
this process before, so you may already be familiar with the requirements.
First, below is a link to our Form #1, which is a checklist of the necessary information we'll need to proceed with
the request:
Utah Division of Air Quality Notice of Intent (NOI) Application Checklist (Form 1)
Next, on our main permitting forms page (below) a good deal of this information can be checked off by filling out
Forms 2-5 which are located under the "New Source Review" heading (middle of the page):
https://deq.utah.gov/air-quality/permitting-forms-air-quality
I've also included a link below to our Notice of Intent guide, which goes into more detail regarding this information and the
various data requirements. You'll primarily be concerned with Section IV (Data Requirements) as applicable:
Notice of Intent Guide
Please send these various forms and information directly to me via email and we can move forward in the process.
I'll begin with entering the project into our database, so you should be getting an automated message within a day or two
letting you know the process has started and that I'm the assigned engineer.
I'll be your primary point of contact, so feel free to reach out if you have any questions or concerns.
Thank you,
--
Colby Johnson
Environmental Engineer
Phone: [phone]
Email: [e-mail]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
2/8/23, 3:49 PM State of Utah Mail - Fwd: Companion - NOI Modification Request
https://mail.google.com/mail/u/0/?ik=1e137a1c28&view=pt&search=all&permmsgid=msg-f%3A1754735657941645390&simpl=msg-f%3A1754735657…1/1
Colby Johnson <[e-mail]>
Fwd: Companion - NOI Modification Request
Alan Humpherys <[e-mail]>Wed, Jan 11, 2023 at 7:11 AM
To: Colby Johnson <[e-mail]>
Cc: Jon Black <[e-mail]>
Colby,
Can you please process this project?
Site ID: 10181
Peer: EQ
Thanks,
Alan
---------- Forwarded message ---------
From: Melissa Yazhe <[e-mail]>
Date: Tue, Jan 10, 2023 at 2:51 PM
Subject: Companion - NOI Modification Request
To: Alan Humpherys <[e-mail]>, Jon Black <[e-mail]>
Hello,
This NOI modification request for DAQE-AN101810009-17 was received today.
Thanks, Melissa.
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
01-10-23_Companion_NOI Modification DAQE-AN101810009-17.pdf
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