DAQ-2024-004921

1
DAQC-CI117940001-24
Site ID 11794 (B1)

MEMORANDUM

TO: FILE – PETERSEN INC. - Steel Fabrication Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: January 25, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County

INSPECTION DATE: December 21, 2023

SOURCE LOCATION: 1527 North 2000 West
Farr West, UT 84404
SOURCE CONTACTS: John Rasband, EHS Manager
801-732-205 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Job shop. Large pieces of steel, aluminum, and stainless steel
are delivered to the site. Specialty type items are made through
the basic steel fabrication process of flame cutting, plasma
cutting, and welding into various shapes. After washing, the
steel items are blasted in the abrasive blast booth, painted, and/or
heat treated in the heat treat oven. The heat treat oven heats the
steel items uniformly to relief any stress created in the metal
from the fabrication and welding processes. Work shifts are
dependent on the work orders received. To control emissions,
filter banks were installed in each of the paint booths and along
the south wall of the abrasive blasting booth. Filters in the paint
booths and blasting booths are changed on a routine basis. In
addition, the stream from the blasting material is vented to one of
two baghouses. The west baghouse returns exhaust air back into
the building.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN117940005-20, dated April 21,
2020
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines,
MACT (Part 63) XXXXXX: National Emission Standards for
Hazardous Air Pollutants Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories,
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

2

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Petersen Inc. - Steel Fabrication Plant
1527 North 2000 West 1527 North 2000 West
Farr West, UT 84404 Farr West, UT 84404

SIC Code: 3443: (Fabricated Plate Work (Boiler Shop))

Section I: GENERAL PROVISIONS

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

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

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

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

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

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

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

Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. An emissions
inventory was submitted for 2022, and emissions data are reported below.

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]

Status: In Compliance. The source had submitted notification by the previous inspection,
see DAQC-911-21.
3

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Petersen Incorporated
A steel fabrication plant

II.A.2 Abrasive Blasting Operation
Media type: Steel shot inside and garnet and glass beads outside
Controlled by baghouses (II.A.3 and II.A.4)

II.A.3 Steel Shot Booth Baghouses
Capacity: 12,000 acfm
Number of units: Two (2)
One (1) unit vents internally from the steel shot booth and the other unit vents externally

II.A.4 Garnet Blast Booth Baghouse (New Equipment)
Capacity: 8,300 acfm
Number of Units: One (1)
Vents internally from the garnet blast booth.

II.A.5 Stress Oven
Burner type: Low NOx
Fuel type: Natural gas

II.A.6 Paint Booths*
Number of units: Six (6)
Control devices: Filters
*One paint booth is new equipment

II.A.7 Three (3) Emergency Generators
Capacities: 30 kW, 40 kW, 45kW (one each)
Fuel: Natural Gas

II.A.8 Miscellaneous Equipment
Associated equipment and functions for the steel fabrication business (fork lifts, space heaters,
grinding, welding, etc.).

Status: In Compliance. No unapproved equipment was observed at the time of inspection.
Additional information obtained from a previous inspection is included below:

·II.A.3 - Steel Shot Booth Baghouses - The west baghouse vents internally. The east
baghouse vents externally.
·II.A.5 - Stress Oven - is in a dome-shaped structure located outdoors on the west
side of the lot and equipped with three, 1.7 MMBtu/hr Webster Cyclonetic burners.
·II.A.6 - Paint Booths - A solvent recycler is also in use as part of the painting
operations.
·II.A.7 - Three (3) Emergency Generators - The 30 kW and 40 kW generator engines
were manufactured in 2005 and installed in 2006. The 45-kW generator was
manufactured in 2008 and installed in 2009.
·II.A.8 - Miscellaneous Equipment - Operations and emissions associated with hand
welding operations are vented as fugitives and applicable to 40 CFR 63 Subpart
XXXXXX.
·The source also operates two powder-coating booths, an electric burn-off oven, and
a 180,000 btu/hr used oil burner.

4
II.B Requirements and Limitations

II.B.1 Source-Wide Requirements.

II.B.1.a Visible emissions from the following emission points shall not exceed the following values:

A. Baghouses - 10% opacity

B. Paint spray booths - 10% opacity

C. Stress oven - 10% opacity

D. Natural gas fired emergency generators - 10% opacity

E. Any stationary point or fugitive emissions associated with the source, not listed here,
or with the control facilities - 20% opacity

[R307-206, 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. [R307-401-8]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

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

Status: In Compliance. Petersen Inc. confirmed that only natural gas is used as fuel at this
site.

II.B.1.c The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement
applicators, etc. and associated operations shall not exceed:

11.67 tons per rolling 12-month period for VOCs
7.5 tons per rolling 12-month period for a combination of xylene, toluene, and MIBK
7.0 tons per rolling 12-month period for each of xylene, toluene, and MIBK

[R307-401-8]

II.B.1.c.1 Compliance with the limitations shall be determined on a rolling 12-month total. No later than
20 days after the end of each month, a new 12-month total shall be calculated using data from the
previous 12 months. The VOC and HAP emissions shall be determined by maintaining a record
of VOC- and HAP- emitting materials used each month. The record shall include the following
data for each material used:

A. Name of the VOC- or HAPs-emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, toxics, isocyanates, and etc.

B. Density of each material used (pounds per gallon)

C. Percent by weight of all VOC or HAP in each material used

D. Gallons of each VOC- or HAP-emitting material used

E. The amount of VOC or HAP emitted monthly by each material used shall be
calculated by the following procedure:

5
VOC = (% VOC by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb)

HAP = (% HAP by Weight)/100 x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb)

F. The amount of VOC or HAP emitted monthly from all materials used

G. The amount of VOCs or HAPs reclaimed for the month shall be similarly
quantified and subtracted from the quantities calculated above to provide the
monthly total VOC or HAP emissions.

[R307-401-8]

Status: In Compliance. In compliance as follows for the rolling 12-month reporting period
from: December 2022 - November 2023:

2.71917 tons VOCs
1.28 tons for a combination of xylene, toluene, and MIBK
0.82 tons xylene
0.38 tons toluene
0.04 tons MIBK

II.B.2 Abrasive Blasting Operation Requirements.

II.B.2.a The baghouses shall control exhaust streams from all abrasive blasting operations. [R307-401-8]

Status: In Compliance. All abrasive blasting operations exhaust streams were observed to
be controlled by a baghouse.

II.B.2.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across each baghouse. The static pressure drop across the baghouses shall be
maintained between the following ranges:

A. Steel Shot Booth Baghouses: 1 - 8 iwc

B. Garnet Blast Booth Baghouse: 2 - 8 iwc. [R307-401-8]

II.B.2.b.1 Static pressure drop readings shall be recorded at least once during each week of operation while
each baghouse is operating. The monitoring gauge shall be located such that an
inspector/operator can safely read the output at any time. Records documenting the static
pressure drop shall be kept in a log and shall include the following:

A. Unit identification

B. Weekly static pressure drop readings

C. Date of reading. [R307-401-8]

Status: In Compliance. Readings were found to be between 1 and 8 inches of water column
for the steel shot booth baghouse and between 2 and 8 inches of water column for the
garnet blast booth baghouse. See attached log.

6
II.B.3 Paint Booth Requirements

II.B.3.a The paint spray booths shall each be equipped with paint arrestor particulate filters, or
equivalent, to control particulate emissions. All air exiting the booths shall pass through this
control system before being vented to the atmosphere (outside building/operation). Equivalency
determinations, when requested by the owner/operator, shall be submitted to the Director for
approval. [R307-401-8]

Status: In Compliance. All spray booths were observed to be equipped with particulate
filters.

II.B.4 Engine Requirements

II.B.4.a The owner/operator shall use only natural gas as a fuel source in the generator engines. [R307-
401-8]

Status: In Compliance. The source confirmed the three generator engines operate solely on
natural gas.

II.B.4.b The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.4.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

A. The date the emergency engine was used

B. The duration of operation in hours

C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]

II.B.4.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

Status: In Compliance. Each emergency generator is equipped with a non-resettable hour
meter. For the rolling 12-month period from January 2023 - December 2023, hours of
usage are as follows:

45kW: 14.9 hours
40 kW: 12.5 hours
30 kW: 15.9 hours

7
Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Status: In Compliance. Compliance with this subpart is satisfied by installing a certified engine,
maintaining and operating the engines in accordance with the manufacturer's instructions, installation
of a non-resettable hour meter, and maintaining records of use. All information provided at the time of
inspection indicate this engine is being properly maintained and operated in accordance with this
subpart.

MACT (Part 63) XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source
Standards for Nine Metal Fabrication and Finishing Source Categories

Status: Not in Compliance. With the previous inspection (see DAQC-911-21), the source was instructed
to submit annual summaries. These had not been submitted. The source maintained that they have
never observed visible emissions coming from hand welding operations. No emissions were observed at
the time of inspection either. Compliance assistance was provided to submit the annual reports and
these are attached below. No action is recommended at this time.

MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. This subpart applies to all emergency generators. Each generator was used for
less than 100 hours for maintenance and other non-emergency purposes. Maintenance occurs per
manufacturer recommendations, and the non-resettable hour meter is checked weekly. Only low-sulfur
diesel is used in all of the generators.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Standards of Performance for New Stationary Sources [R307-210]
Status: Compliance with this area source rule is satisfied by compliance with Federal Requirements
NSPS (Part 60) Subpart JJJJ. See Section III above for more information.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subpart ZZZZ and Subpart XXXXXX. See section III above for
more information.

Solvent Cleaning [R307-304]

Status: Not applicable per R307-304-3(1) as the source is subject to R307-350.

8
Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with
condition II.B.1.a of the AO.

PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with
conditions II.B.1.a and II.B.2.a of the AO and conducting all abrasive blasting in the enclosed
blasting units that are controlled by baghouses before being vented externally.

Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. No VOC containing materials were observed spilled, discarded, stored in
open containers or handled in any other way that would result in greater evaporation.

Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. Petersen Inc. is familiar with this area source rule. No products discussed at
the time of inspection exceed VOC lb/gal limits established by this rule. See the attached table for a
list of all products employed by the source. The only solvent cleaning that the source does is with
acetone, a VOC exempt product.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Petersen Inc. - Steel Fabrication Plant. A
comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN117940005-20, dated
April 21, 2020, is provided. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1345.00 N/A
Carbon Monoxide 0.18 0.08977
Nitrogen Oxides 0.61 0.079
Particulate Matter - PM10 6.50 0.08836
Particulate Matter - PM2.5 6.50 0.00452
Sulfur Oxides 0.20 0.00043
Volatile Organic Compounds 11.67 1.7775

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Ethyl Benzene (CAS #100414) 1500 120
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 14000 N/A
Toluene (CAS #108883) 14000 440
Xylenes (Isomers and Mixture) (CAS #1330207) 14000 1240

9
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS AND
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN117940005-20,
dated April 21, 2020: Not in compliance at the time of
inspection. Annual reports for MACT Part 63 Subpart
XXXXXX were not being submitted. Compliance assistance
was provided, and no action is recommended at this time.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at typical frequency. Ensure that annual reports for
MACT Part 63 Subpart XXXXXX have been submitted to the
DAQ each January.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO form, records, confirmation to send future XXXXXX
reports, XXXXXX annual reports, list of coatings
Month Tons Used Month Tons Used Month
Jan-23 0.0315 Jan-23 0.090000 Jan-23
Feb-23 0.0633 Feb-23 0.075700 Feb-23
Mar-23 0.0457 Mar-23 0.032700 Mar-23
Apr-23 0.0406 Apr-23 0.004800 Apr-23
May-23 0.1416 May-23 0.008700 May-23
Jun-23 0.1281 Jun-23 0.020600 Jun-23
Jul-23 0.0778 Jul-23 0.012200 Jul-23
Aug-23 0.1050 Aug-23 0.021000 Aug-23
Sep-23 0.0749 Sep-23 0.040200 Sep-23
Oct-32 0.0220 Oct-23 0.018900 Oct-23
Nov-23 0.0286 Nov-23 0.008900 Nov-23
Dec-22 0.0563 Dec-22 0.043000 Dec-22
Tons 0.82 Tons 0.38 Tons
Month Tons Used Jan-23 0.2055
Jan-23 0.00000 Feb-23 0.15723
Feb-23 0.00000 Mar-23 0.1854
Mar-23 0.00000 Apr-23 0.19213
Apr-23 0.03000 May-23 0.33297
May-23 0.00000 Jun-23 0.33379
Jun-23 0.00000 Jul-23 0.23805
Jul-23 0.01000 Aug-23 0.35116
Aug-23 0.00000 Sep-23 0.2477
Sep-23 0.00000 Oct-23 0.1683
Oct-23 0.00000 Nov-23 0.17094
Nov-23 0.00000 Dec-22 0.136
Dec-22 0.00000 Total 2.71917
Tons 0.04
Permitted
12 Month Rolling HAPS/VOC Emissions
Xylene Toluene Ethyl B
MIBK Rolling 12 mo. VOC
Tons Used
0.00233
0.00025
0.00273
0.00686
0.02199
0.02120
0.01094
0.00489
0.00955
0.00218
0.00068
0.00000
0.08
11.67 t
d Amount

Benzene
BAGHOUSE
1/2/2023 1/10/2023 1/19/2023 1/24/2023
STEEL EAST 7.4 7.4 7.6 7.6
STEEL WEST 4.2 4.2 4.4 4.6
GARNET 7.6 7.8 7.6 7.6
ACTIONS
3/7/2023 Asked maintenance to change filters
5/15/23 Garnite Hopper was full talked to Cameron about
keeping it cleaned out. Bart told Cameron he need to
enforce periodic cleaning and maintenance.
Steel shot filter change 9/8/2023
2/2/2023 2/7/2023 2/14/2023 2/21/2023 2/28/2023 3/2/2023 3/7/2023 3/13/2023 3/21/2023
7.8 7.6 4.4 4.6 4.4 4.2 4.2 4.4 4.3
4.2 4.4 7.8 7.6 7.8 7.8 7.6 7.8 7.6
7.6 7.8 7.6 7.4 7.8 7.6 7.5 7.5 7.6
3/27/2023 4/3/2023 4/10/2023 4/17/2023 4/24/2023 5/1/2023 5/8/2023 5/15/2023 5/22/2023
4.4 4.2 4.4 4.8 4.8 5.2 5.6 5.6 6.7
7.8 7.8 7.9 7.9 7.9 7.9 7.97.9 7.8 7.8
7.5 7.8 7.6 7.4 7.4 7.8 7.6 7.6 7.8
6/1/2023 6/5/20223 6/12/2023 6/19/2023 6/26/2023 7/5/2023 7/10/2023 7/17/2023
6.7 6.7 6.4 5.8 6.7 3.4 3.4 3.4
7.8 7.8 7.8 7.9 7.8 7.8 7.8 7.6
7.6 7.8 7.8 7.6 7.5 7.6 7.8 2.4
7/24/2023 8/1/2023 8/7/2023 8/17/2023 8/21/2023 8/28/203 9/4/2023 9/14/2023 9/19/2023
3.2 3.0 3.8 4.6 4.6 4.6 4.4 0.2 0.4
7.8 7.8 7.9 7.9 7.9 7.6 7.5 2.6 2.2
2.2 2.4 2.6 2.6 2.6 2.4 2.6 2.6 2.8
9/25/2023 10/2/2023 10/9/2023 10/17/2023 10/23/2023 10/31/2023 11/6/2023 11/14/2023
0.4 1.0 1.0 1.2 1.4 1.4 1.4 1.4
2.2 2.8 3.0 3.2 3.2 4.0 3.5 3.5
2.8 2.8 2.8 2.8 3.0 3.0 2.8 3.0
11/21/2023 11/27/2023 12/6/2023 12/11/2023 12/18/2023
1.4 1.6 1.6 1.6 1.5
3.6 3.8 3.0 3.0 3.4
3.2 3.0 3.0 3.2 3.2
Generator Hours
Jan. 5, 2021 Feb. 1, 2021
Total Hours Rolling 12
mos Total Hours
BLDG 6 South 45kW 62.7 12.6 63.8
BLDG 1 East 40kW 63.5 16.5 64.7
BLDG 1 West 30kW 70.3 13.9 73.6
Jan. 3, 2021 Feb. 2, 2022
Generator Total Hours Rolling 12
mos Total Hours
BLDG 6 South 45kW 75.6 12.9 79.6
BLDG 1 East 40kW 90.5 27.0 91.3
BLDG 1 West 30kW 100.3 30.0 101.7
January 1, 2023 February 1, 2023
Generator Total Hours Rolling 12
mos Total Hours
BLDG 6 South 45kW 86.5 10.9 87.7
BLDG 1 East 40kW 101.4 10.9 103.5
BLDG 1 West 30kW 114 13.7 115.3
10 min pwr outage Bldg. 1
1/26/2022
Mar. 1, 2021 Apr. 5, 2021 May. 3, 2021
Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos
12.6 65.2 12.1 66.5 12.1 67.2 12.2
12.7 65.7 11.8 67.1 11.3 77.2 21.0
16.0 75.4 15.4 76.4 14.8 86.6 24.6
Mar. 2, 2022 Apr. 4, 2022 May 3, 2022
Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos
15.8 77.6 12.4 78.8 12.3 79.6 12.4
26.6 92.2 26.5 93.6 26.5 94.4 17.2
28.1 103 27.6 104.6 28.2 105.4 18.8
March 2, 2023 April 3, 2023 May 1, 2023
Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos
8.1 88.6 11.0 89.6 10.8 91.2 11.6
12.2 104.2 12.0 104.7 11.1 106.3 11.9
13.6 116.2 13.2 117.8 13.2 119.7 14.3
June. 1, 2021 July 6, 2021 August 2, 2021
Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos
68.5 13.3 69.5 13.5 70.5 13.2
81.7 25.1 82.7 25.3 83.9 25.5
89.9 27.5 91 27.8 92 27.5
June 1, 2022 July 6, 2022 August 1, 2022
Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos
80.6 12.1 81.5 12.0 81.7 11.2
95.9 14.2 96.6 13.9 97.8 13.9
106.6 16.7 107.8 16.8 109 17.0
June 1, 2023 July 5, 2023 August 1, 2023
Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours Rolling 12
mos
92.4 11.8 94.1 12.6 95.2 13.5
107.5 11.6 109 12.4 110.1 12.3
121.1 14.5 121.1 13.3 122.1 13.1
September 1, 2021 October 5, 2021 November 1, 2021
Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours
71.3 13.0 72.3 13.0 73.4
84.7 25.1 85.7 24.7 86.6
92.8 27.2 93.8 26.1 94.9
September 1, 2022 October 4, 2022 November 2, 2022
Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours
82.5 11.2 83.7 11.4 84.5
98.1 13.4 99.4 13.7 99.4
109.8 17.0 111.1 17.3 112
September 5, 2023 October 2, 2023 November 6, 2023
Total Hours Rolling 12
mos Total Hours Rolling 12
mos Total Hours
95.8 13.3 96.9 13.2 96.9
110.7 12.6 111.8 12.4 113.3
124.7 14.9 125.8 14.7 127.9
December 1, 2021
Rolling 12
mos Total Hours Rolling 12
mos
12.8 74.4 13.0
24.5 87.9 25.6
25.8 96.1 27.0
December 1, 2022
Rolling 12
mos Total Hours Rolling 12
mos
11.1 85.5 11.1
12.8 101.4 13.5
17.1 113 16.9
December 6, 2023
Rolling 12
mos Total Hours Rolling 12
mos
12.4 100.4 14.9
13.9 113.9 12.5
15.9 128.9 15.9
2/5/24, 9:35 AM State of Utah Mail - Subpart XXXXXX
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-2927072369373807363&simpl=msg-a:r54628950726347…1/2
Daniel Riddle <[e-mail]>
Subpart XXXXXX
3 messages
Daniel Riddle <[e-mail]>Mon, Feb 5, 2024 at 9:32 AM
To: John Rasband <[e-mail]>
John,
I'm finishing up the inspection report from my inspection last month, and I just wanted to get confirmation from you that you will submit those annual
reports for MACT Part 63 Subpart XXXXXX every January going forward. You can either send in a hard copy to the DAQ or email it to my manager
Chad Gilgen at [e-mail].
Let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
John Rasband <[e-mail]>Mon, Feb 5, 2024 at 9:35 AM
To: Daniel Riddle <[e-mail]>
Yes sir will do.

Regards,

John Rasband CSP COHC • EH&S Manager
Direct [phone] | Mobile [phone]
1527 North 2000 West, Ogden, UT 84404
[e-mail] | www.peterseninc.com

“A family of precision machining & fabrication companies”

From: Daniel Riddle <[e-mail]>
Sent: Monday, February 5, 2024 9:33 AM
2/5/24, 9:35 AM State of Utah Mail - Subpart XXXXXX
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-2927072369373807363&simpl=msg-a:r54628950726347…2/2
To: John Rasband <[e-mail]>
Subject: Subpart XXXXXX

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and
know the content is safe.
[Quoted text hidden]
WARNING: The informaon contained in this electronic mail message is confidenal informaon and intended only for the use of the individual or enty named above, and may be privileged. If the
reader of this message is not the intended recipient, you are hereby nofied that any disseminaon, distribuon or copying of this communicaon is strictly prohibited. If you have received this
transmission in error, please contact the sender immediately, delete this material from your computer and destroy all related paper media. Documents that can be viewed, printed or retrieved from
this electronic mail message may contain technical data whose export is restricted by Internaonal Traffic in Arms Regulaons (ITAR). Such technical data is considered ITAR and/or EAR controlled
pursuant to 22 CFR Part 120-130 and 15 CFR Parts 730-774 respecvely. Transfer of this data by any means to a Non-US Person, whether in the United States or abroad, without the proper U.S.
Government authorizaon (e.g.,License, exempon, NLR, etc.), is strictly prohibited. Violaons of these export laws are subject to severe civil, criminal and administrave penales.
Daniel Riddle <[e-mail]>Mon, Feb 5, 2024 at 9:35 AM
To: John Rasband <[e-mail]>
Thank you.
[Quoted text hidden]
Coating/Solvent Gallons Density
lbs/gal
Lbs
VOC/gal Tons VOC Tons
Xylenes
Tons
Toluene Tons MIBK Tons Ethyl
Benzene
PPG Dimetcote 9 HS 9.85 3.4 0 0 0 0 0
PPG Americoat 68HS Part A,B Zinc Powder 26.7 2.4 0 0 0 0 0
PPG Amercoat 450 H 9.76 2.1 0 0 0 0 0
PPG Amercoat 450 H Cure 8.68 0.3 0 0 0 0 0
Amercoat 385 Mixed 11.7 2.6 0 0 0 0 0
PPG PITT Tech 8.93 0.8 0 0 0 0 0
PPG Alk-200 9.43 3.15 0 0 0 0 0
PPG Amershield PT A 11.18 2.2 0 0 0 0 0
PPG Amershield PT B 9.3 1.2 0 0 0 0 0
PPG Delfleet Primer 10.84 1.41 0 0 0 0 0
PPG Delfleet Finish 10.06 2.79 0 0 0 0 0
PPG Interthane Hi-Temp 900 PT A 15.36 2.0 0 0 0 0 0
PPG Interthane Hi-Temp 900 PT B 10.93 0.32 0 0 0 0 0
PPG PSX 805 12.43 0.6 0 0 0 0 0
PPG PSX 805 Hardner 9.18 0 0 0 0 0 0
PPG Performance CRE-321 12.02 2.1 0 0 0 0 0
PPG Performance AUE-300 10 2.7 0 0 0 0 0
Axalta Imron 3.5 10.9 3.4 0 0 0 0 0
Mathews Paint Company MAP-LVU100 13.27 0.11 0 0 0 0 0
Kelly Alkyd Enamel 9.11 3.02 0 0 0 0 0
Valley Safety Yellow 9.1 2.467 0 0 0 0 0
Valley Gray Primer V-006 11.54 3.2 0 0 0 0 0
Valley Gray Copolymer Primer V-003 11.26 3.4 0 0 0 0 0
Valley Buff Primer V-303 10.8 1.42 0 0 0 0 0
Carboline Carbocoat 8239 11.4 2.8 0 0 0 0 0
Carboline Carbcoat 8215 10 3.5 0 0 0 0 0
Carboline Carboguard 60 A&B 11.6 2 0 0 0 0 0
Carboline Carboguard 890 Pt A 12.9 1.8 0 0 0 0 0
Carboline Carboguard 890 Pt B 13.3 1.8 0 0 0 0 0
Carboline Carboguard 893 Pt A 13 1.6 0 0 0 0 0
Carboline Carboguard 893 Pt B 12.6 1.6 0 0 0 0 0
Carboline Carboguard 134 HG Pt A&B 10.6 2.2 0 0 0 0 0
Carboline(Carbozinc) 859 PT A 10.85 2.72 0 0 0 0 0
Carboline (Carbozinc) 859 PT B 7.34 2.7 0 0 0 0 0
Carboline Carbothane HB PT A 12.5 3.1 0 0 0 0 0
Carboline Carbothane HB PT B 8.8 0 0 0 0 0 0
Carboline Carbothane 133 Base 13.3 1.76 0 0 0 0 0
Carboline Phenoline 1205 12.1 2.1 0 0 0 0 0
Carboline Carbomastic 94 Pt A&B 13.9 2 0 0 0 0 0
Carboline Carboquick 200 12.1 2.05 0 0 0 0 0
Valley New Cat Yellow V-362 9.2 1.2 0 0 0 0 0
Hentzen 22750 G A&B 9.2 2.3 0 0 0 0 0
Rustoleum 3400 Primer Pt A & B 9.3 2.8 0 0 0 0 0
Rust-Oleum 9100 DTM Epoxy 12.6 2.84 0 0 0 0 0
Rust-Oleum 9100 ETM Activator 12.6 2.84 0 0 0 0 0
Monthly VOC/HAP's Emissions
Rustoleum HS9300 Primer 13.1 3.4 0 0 0 0 0
Rustoleum HS9300 Acivator 7.9 2.4 0 0 0 0 0
Rustoleum 9800 DTM Urethane A&B 11 3.1 0 0 0 0 0
Red Oxide Primer 11.02 2.75 0 0 0 0 0
Devflex 4020 White 11.73 2.3 0 0 0 0 0
Devflex 4020 Primer 11.82 0.01 0 0 0 0 0
Devoe Bar-Rust Primer 235 A&B 11 2.43 0 0 0 0 0
Devthane 379 A 11.2 0.36 0 0 0 0 0
Devthane 379 Converter 9.4 1.22 0 0 0 0 0
PPG Devguard 4308 8.35 3.5 0 0 0 0 0
Tnemec V140F Mixed/Thinned 13.02 2.08 0 0 0 0 0
Tnemec Hydrozinc H2O 94 24.9 0.744 0 0 0 0 0
Tnemec Series 90-97 Pt A & B 23.9 2.79 0 0 0 0 0
Tnemec Series 1075 Pt A 12.22 2.2 0 0 0 0 0
Tnemec Series 1075 PT B 9.35 0.935 0 0 0 0 0
Tnemec Series N69F A&B 13.34 2.76 0 0 0 0 0
Tnemec 66 HS 13.1 1.6 0 0 0 0 0
Tnemec 161HS A&B 13.9 2.9 0 0 0 0 0
Tnemec V69 High Build Epoxy A&B 15.2 1.95 0 0 0 0 0
Temperkote 1000 Primer Gray 16.2 3.2 0 0 0 0 0
Temperkote 1000 30 Black 13.4 3.4 0 0 0 0 0
Internthane 990 A&B 12.26 2.73 0 0 0 0 0
Intrepid Green Epoxy Primer (DOD)12.29 3.1 0 0 0 0 0
Intrepid Green Epoxy Primer Harener (DOD)10.4 3.2 0 0 0 0 0
International Intergard 345 A & B 41 12.1 2.67 0.054735 0.024805 0 0 0
Dudick Protecto-Coat 900 1.3 0.7 0 0 0 0 0
Dudick PH-1 Hardener (No VOC)8.6 0 0 0 0 0 0
Dudick Primer 27 8.6 0 0 0 0 0 0
Prime Coatings Aqualac 32 Series 10.4 0 0 0 0 0 0
Prime Coatings Aqualac 135 Series 9.36 0 0 0 0 0 0
Cardinal Epoxy Primer A&B 8.9 2.1 0 0 0 0 0
SW AquaKem P70 11.17 1.27 0 0 0 0 0
SW Polane 8880 A & B 78.5 11.41 2.8 0.1099 0 0.008949 0 0
SW Phenicon HS PTA 14.7 2.08 0 0 0 0 0
SW Phenicon HS PTB 8.5 2.08 0 0 0 0 0
SW Recoatable Epoxy PT G 14.59 2.5 0 0 0 0 0
SW Recoatable Epoxy PT H 12.7 2.1 0 0 0 0 0
SW High Build Epoxy Primer PTA 12.47 1.7 0 0 0 0 0
SW High Build Epoxy Primer PT B 10.68 2.6 0 0 0 0 0
SW Zinc Clad IV Pt A & B 4.5 28.3 2.8 0.0063 0.003825 0 0 0.000675
SW Zinc Clad XI 10 0.42 0 0 0 0 0
SW Formula 150 Green Primer PT A,B (DoD)11.7 2.8 0 0 0 0 0
SW Pro-Cryl Primer Pt A & B 10.8 0.39 0 0 0 0 0
SW Duraplate 235 PT A 11.83 2.07 0 0 0 0 0
SW Duraplate 235 PT B 7.83 2.82 0 0 0 0 0
SW Macropoxy 646 Pt A&B 13.46 2.5 0 0 0 0 0
SW Sher-Loxane 800 Pt A & Hardner 1.44 0.77 0 0 0 0 0
SW Acrolon Ultra Pt A 10.3 2.8 0 0 0 0 0
SW Acrolon Ultra Pt B 9.2 2.8 0 0 0 0 0
SW Kem Kromic Primer 12.7 2.5 0 0 0 0 0
PPG Keeler Long PSX700 9.43 0.7 0 0 0 0 0
PPG Keeler Long PSX700 Cure 8 0 0 0 0 0 0
PPG Performance Alkyd A&B 9.95 3.4 0 0 0 0 0
SW Tile Clad Pt A 11.47 3.04 0 0 0 0 0
SW Tile Clad Pt B 8.75 3.06 0 0 0 0 0
SW MIL-DTL-53022E A&B 10.9 2.7 0 0 0 0 0
Amerlock 400 Pt A&B 12.5 1.4 0 0 0 0 0
Totals 124 0.170935 0.02863 0.0089 0.00 0.000675
Total Tons of HAPs 0.038
Jan-23 0.2055
Feb-23 0.15723
Mar-23 0.1854
Apr-23 0.19213
May-23 0.33297
Jun-23 0.33379
Jul-23 0.23805
Aug-23 0.35116
Sep-23 0.2477
Oct-23 0.1683
Nov-23 0.17094
Dec-22 0.136
Total 2.71917
11.67 t
Rolling 12 mo. VOC
Permitted Amount
11.49854167