DAQ-2024-008190

1
DAQC-CI148480001-24
Site ID 14848 (B1)
MEMORANDUM

TO: FILE – INTERSTATE GRATINGS – Lindon Manufacturing Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: May 13, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: April 18, 2024

SOURCE LOCATION: 1820 West 200 South
Lindon, UT 84042

SOURCE CONTACTS: Kriss Sweat, Vice President of Operations
[e-mail]

Chris Clark, Purchasing Operations: Quality Safety/Control
[e-mail]

Susan Jew, BES Environmental
619-672-7400

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Interstate Gratings manufactures grating products by cutting,
welding, trimming, and dip-coating prefabricated steel. All
welding operations are conducted indoors. No more than 2% of
the welding occurs on stainless steel. Most of the wire used in
the grates consists of carbon steel.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN148480001-14, dated
April 30, 2014
MACT (Part 63) -A : General Provisions,
MACT (Part 63) -XXXXXX : National Emission Standards for
Hazardous Air Pollutants Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories

2
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Interstate Gratings
Lindon Manufacturing Plant

1820 West 200 South 1820 West 200 South
Lindon, UT 84042 Lindon, UT 84042

SIC Code: 3499: (Fabricated Metal Products, NEC)

Section I: GENERAL PROVISIONS

I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.2 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.3 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.4 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.5 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

I.7 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]

Status: In Compliance. No breakdowns have occurred since the previous inspection.
Source submitted their 2023 Emission Inventory by the April 15, 2024, deadline. The 2020
Emission Inventory is referenced below. See the attachments section for additional
information.

3
Section II: SPECIAL PROVISIONS

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

II.A.1 Interstate Gratings

II.A.2 Radiant Heaters
Natural gas-fired radiant heaters
Total capacity not to exceed 10.4 MMBtu/hr.

II.A.3 Coating Operations
Equipment includes: two dip tanks (31' x 4' 3")

II.A.4 Grating Fabrication
Equipment includes: steel slitter, edging machines, resistance welders, gas metal arc welding,
shielded metal arc welding, cutting table, and finishing processes.

II.A.5 Maintenance Area Cleaning Activities

II.A.6 Forklift
Propane-fired
*listed for informational purposes only

Status: In Compliance. No unapproved equipment was observed at the time of inspection.

II.B Requirements and Limitations

II.B.1 Source-Wide Requirements and Limitations.

II.B.1.a The plant-wide emissions of VOCs and HAPs from the coating and cleaning operations shall not
exceed:

19.91 tons per rolling 12-month total for VOCs
9.90 tons per rolling 12-month total for xylene
4.69 tons per rolling 12-month total for 2-butoxyethanol
14.59 tons per rolling 12-month period for combined HAPs. [R307-401-8]

II.B.1.a.1 Compliance with each limitation shall be determined on a rolling 12-month total. No later than
20 days after the end of each month, a new 12-month total shall be calculated using data from the
previous 12 months.

The VOC or HAP emissions shall be determined by maintaining a record of VOC- or HAP-
emitting materials used each month. The record shall include the following data for each
material used:

1) Name of the VOC- or HAP-emitting material, such as: paint, adhesive, solvent, thinner,
reducers, chemical compounds, toxics, isocyanates, etc.

2) Density of each material used (pounds per gallon)

3) Percent by weight of all VOC or HAP in each material used

4
4) Volume (in gallons) of each VOC- or HAP-containing material used

5) The amount of VOC or HAP emitted monthly by each material used, as calculated by the
following procedure:

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

6) The amounts of VOC and HAP emitted monthly from the facility. [R307-401-8]

Status: In Compliance. The rolling 12-month total for VOCs and HAPS from April
2023 to March 2024 are as follows:

1.95 tons for VOCs
1.42 tons for 2-Butoxyethanol
0 tons for xylene
1.42 tons for all combined HAPs

Records were provided by email. See the attachments section for additional
information.

II.B.1.b Natural gas consumption shall not exceed 10.67 MMscf per rolling 12-month period.
[R307-401-8]

II.B.1.b.1 Compliance with the limitations shall be determined with a rolling 12-month total. No later than
20 days after the end of the month, a new 12-month total shall be calculated using data from the
previous 12 months. Records of consumption shall be kept for all periods when the plant is in
operation and shall be kept on a monthly basis. Consumption shall be determined from the
natural gas bill. [R307-401-8]

Status: In Compliance. The rolling 12-month total from April 2023 to March 2024 for
natural gas usage is as follows:

2.75 MMscf of natural gas used onsite

Records were made available via email. See the attachments section for additional
information.

II.B.1.c The owner/operator shall not use any paints, solvents or other products containing greater than
3.5 pounds of VOC per gallon, minus water, as applied. [R307-401-8, R307-350]

Status: In Compliance. Source follows the rules established for coating products in
R307-350. The same products from the previous inspection are used currently and the SDS
for the products was viewed onsite.

II.B.1.d The owner/operator shall comply with UAC R307-350 for Miscellaneous Metal Parts and
Products Coatings. [R307-350]

Status: In Compliance. Source follows the rules established for coating products in
R307-350. The same products from the previous inspection are still used at the source. SDS
were viewed at the time of inspection.

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II.B.1.e The dip tanks shall be covered when not in use. [R307-350, R307-401-8]

Status: In Compliance. Dip tanks were observed to be covered and not in use at the time of
inspection.

II.B.1.f All VOC- and HAP-containing materials, including paint- or solvent-laden rags, shall be kept in
covered containers and stored in a designated area when not in use. [R307-350, R307-401-8]

Status: In Compliance. All VOC or HAP-laden rags were stored in closed containers and
containers were closed at the time of inspection.

II.B.1.g The owner/operator shall not allow visible emissions from natural gas combustion units or
welding activities to exceed 10 percent opacity. Opacity observations of emissions from
stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9.
[R307-401-8]

Status: In Compliance. No visible emissions were observed at the time of inspection. See
the attached VEO form for additional information.

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.

MACT (Part 63) - A: General Provisions

Status: Compliance with Subpart A is determined by compliance with applicable subparts. Out of
Compliance with Subpart XXXXXX.

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

Status: Out of Compliance. The source was inaccurately evaluated in their previous inspection in 2021
on what reporting was required from the source to satisfy compliance with Subpart XXXXXX. Source
had not been submitting annual compliance statements, and since they utilized over 2,000 pounds of
welding rod and wire within a calendar year, they also did not conduct VEOs as part of their annual
compliance statement. In phone conversations with Interstate Gratings' environmental lawyer, Susan
Jew, the source was conducting VEOs on the processes in the equipment in 2023, but not formally
written down in an annual compliance statement. The source submitted their XXXXXX annual
compliance statement on May 6, 2024. Going forward, the source was made aware of the reporting
requirements going forward. No further action is currently recommended.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: Compliance with R307-214 is determined by compliance with applicable federal subparts. See
Section III for additional information.

Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. See AO Condition II.B.1.d for additional information about compliance with
R307-350.

EMISSION INVENTORY:

Listed below are the Actual Emissions Inventory provided from Interstate Gratings- Lindon
Manufacturing Plant. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN148480001-14, dated April 30, 2014, is provided. The 2020 Emission Inventory is listed
below and can be found in the attachments section. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 645.00
Carbon Monoxide 0.15 10.29
Nitrogen Oxides 0.93 1.74
Particulate Matter - PM10 0.25 0.14
Particulate Matter - PM2.5 0.25 0.07
Sulfur Dioxide 0.03 0.01
Volatile Organic Compounds 19.94 2.27

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 20
Xylenes (Isomers And Mixture) (CAS #1330207) 19800

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN148480001-14,
dated April 30, 2014: Out of Compliance with 40 CFR 62
Subpart XXXXXX. During the previous inspection in 2021, the
source was incorrectly evaluated on their requirements for
compliance of Subpart XXXXXX. Source did not submit their
annual compliance statement for 2023 on time and did not
conduct VEOs on their processes since they utilized over 2,000
pounds of welding rod and wire within a calendar year. In phone
conversations with Interstate Gratings lawyer, Susan Jew, the
determination was made that the source had to submit their
annual compliance statement for 2023 and note that they were
restarting the VEO schedule since they were over the pound limit
for welding rod and wire used. No further action is currently
recommended.

In compliance with conditions listed in the AO. The facility is
well maintained and records were made available upon request.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect in the next year to make sure Interstate Gratings has fully
completed their Subpart 6X compliance statement with the VEO
requirements.

NSR RECOMMENDATIONS:

ATTACHMENTS: Applicable Supporting Documentation Included
2020 Emissions Inventory Report
Interstate Gratings Lindon Manufacturing Plant (14848)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)0.09269 0.04831 0.141
PM10-FIL PM10 Filterable 0.00765 <.00001 0.00765
PM25-PRI PM2.5 Primary (Filt + Cond)0.02231 0.04831 0.07062
PM25-FIL PM2.5 Filterable 0.00558 <.00001 0.00558
PM-CON PM Condensible 0.01673 <.00001 0.01673
SO2 Sulfur Dioxide 0.00176 0.00907 0.01083
NOX Nitrogen Oxides 0.27684 1.47119 1.74803
VOC Volatile Organic Compounds 1.92559 0.34858 2.27417
CO Carbon Monoxide 0.11765 10.17574 10.29339
NH3 Ammonia 0.7776 <.00001 0.7776

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
SOX Sulfur Oxides (OTH)- 0.025
7440473 Chromium (HAP)PM 0.00035
7440484 Cobalt (HAP)PM 0.00001
7439965 Manganese (HAP)PM 0.00278
7440020 Nickel (HAP)PM 0.00016

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
2/2
Rolling 12-month material consumption records
Coatings and solvents
rev. 4/7/2021
Explanation of Use:
enter monthly consumption in light green boxes
boxes shaded dark gray are not allowed without modification to Approval Order
data for a new coating and thinner may be entered in green boxes in rows 23-40 if applicable; monthly calculations are in columns G-N
hide rows with data more than 12 months old to avoid clutter; only delete data that is more than 3 years old
Coating: 310 W/R Gloss Black (Valley Paint Manufacturing)
thinner/reducer = water
product density (from MSDS) 8.51 lbs/gal
VOC content (from MSDS) 1.11 lbs/gal
% VOC (calculated) 13.04%
% 2-butoxyethanol (from MSDS) 9.84%
% xylene (from MSDS) 0.00%
% other HAP n/a
Coating: TBD1
thinner/reducer = TBD2, see below
product density (from MSDS) 7 lbs/gal
VOC content (from MSDS) lbs/gal
% VOC (calculated) 0.00%
% 2-butoxyethanol (from MSDS)
% xylene (from MSDS)
% other HAP n/a
Thinner: TBD2
product density (from MSDS) 7 lbs/gal
VOC content (from MSDS) lbs/gal
% VOC (calculated) 0.00%
% 2-butoxyethanol (from MSDS)
% xylene (from MSDS)
% other HAP n/a
Solvent: TBD3 Note: this solvent is used for cleaning in the coating area
product density (from MSDS) 7 lbs/gal
VOC content (from MSDS) lbs/gal R317-350 limits coating solvent to 0.21 pounds/gal
% VOC (calculated) 0.00%
% 2-butoxyethanol (from MSDS)
% xylene (from MSDS)
% other HAP n/a
Solvent: Stoddard Solvent Note: this solvent is used in the parts washer in the maintenance area
product density (from MSDS) 6.59 lbs/gal
VOC content (from MSDS) 6.59 lbs/gal
% VOC (calculated) 100.00%
% 2-butoxyethanol (from MSDS) n/a
% xylene (from MSDS) n/a
% other HAP n/a
VOC 2-Butoxyethanol Xylene Combined HAP Nat. gas (MMscf)
19.91 4.69 9.9 14.59 10.67
Monthly Calculations VOC and HAP emissions in tons
Month Amount (gal) VOC Butoxyethanol Xylene Amount (gal) VOC Butoxyethanol Xylene Amount (gal) VOC Butoxyethanol Xylene Amount (gal) VOC Butoxyethanol Xylene Amount (gal) VOC 759008814 27201169 746001725 VOC Butoxyethanol Xylene Combined HAP Nat. gas (MMscf) VOC Butoxyethanol Xylene Combined HAP Nat. gas (MMscf)
Apr-23 400 0.2220 0.1675 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 311 2930 2040 0.2220 0.1675 0.0000 0.1675 0.53 0.22 0.17 0.00 0.17 0.53
May-23 200 0.1110 0.0837 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 91 777 625 0.1110 0.0837 0.0000 0.0837 0.15 0.33 0.25 0.00 0.25 0.68
Jun-23 400 0.2220 0.1675 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 32 31 204 0.2220 0.1675 0.0000 0.1675 0.03 0.56 0.42 0.00 0.42 0.70
Jul-23 400 0.2220 0.1675 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5 3 78 0.2220 0.1675 0.0000 0.1675 0.01 0.78 0.59 0.00 0.59 0.71
Aug-23 400 0.2220 0.1675 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1 0 14 0.2220 0.1675 0.0000 0.1675 0.00 1.00 0.75 0.00 0.75 0.71
Sep-23 400 0.2220 0.1675 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1 0 54 0.2220 0.1675 0.0000 0.1675 0.01 1.22 0.92 0.00 0.92 0.72
Oct-23 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 14 79 166 0.0000 0.0000 0.0000 0.0000 0.03 1.22 0.92 0.00 0.92 0.75
Nov-23 400 0.2220 0.1675 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 79 866 772 0.2220 0.1675 0.0000 0.1675 0.17 1.44 1.09 0.00 1.09 0.92
Dec-23 200 0.1110 0.0837 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 314 2455 1526 0.1110 0.0837 0.0000 0.0837 0.43 1.55 1.17 0.00 1.17 1.35
Jan-24 200 0.1110 0.0837 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 20 0.0659 363 3475 369 0.1769 0.0837 0.0000 0.0837 0.42 1.73 1.26 0.00 1.26 1.77
Feb-24 200 0.1110 0.0837 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3971 254 2045 0.1110 0.0837 0.0000 0.0837 0.63 1.84 1.34 0.00 1.34 2.39
Mar-24 200 0.1110 0.0837 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 254 2045 1249 0.1110 0.0837 0.0000 0.0837 0.35 1.95 1.42 0.00 1.42 2.75
Permit Limits (Rolling 12-Month Total)
Monthly Totals Rolling 12-Month Totals310 W/R Gloss Black Coating TBD1 Thinner/Reducer TBD2 Solvent TBD3 Stoddard Solvent Natural Gas (CCF)
Jordan Garahana <[e-mail]>
VOC and HAP emissions in tons
5 messages
Chris Clark <[e-mail]>Thu, Apr 18, 2024 at 2:18 PM
To: "[e-mail]" <[e-mail]>
Cc: Kriss Sweat <[e-mail]>

Hi Jordan, please see attached tracking report if you need anything else, please let me know.

Thanks

Chris
CHRIS CLARK
Purchasing
Operations: Quality Control/Safety
Direct Line: 801-922-9832
Web: InterstateGratings.com

5/13/24, 12:06 PM State of Utah Mail - VOC and HAP emissions in tons
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1796705140435842856&simpl=msg-f:17967051404358428…1/5
Copy of rolling 12s April 2023- March 2024.xlsx
18K
Jordan Garahana <[e-mail]>Mon, Apr 22, 2024 at 3:30 PM
To: Chris Clark <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Hey Chris and Kriss,
Thank you for getting me the information about the VOC and HAP usage within the last rolling 12-month period. I am still
waiting for the usage of natural gas for that same timeframe and the usage of welding rod in the calendar year of 2023.
I talked to my supervisor about the Federal Subpart XXXXXX that refers to the usage of welding rod used in a year and
he stated that your facility does apply to this subpart and wasn't properly evaluated on that rule when the previous
inspector was at your facility in 2021. What should have been stated during that inspection is that if you are under the
2,000 pounds of welding rod used in a reporting year, you need to submit annual compliance statements at the start of
every year to the DAQ. I have attached an example of that annual compliance statement. Please let me know if you have
any questions about the annual compliance statement or about the information I still require for my inspection.
Thanks,
Jordan Garahana
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
example-annual_report_6x-without_visibleemissiontesting_0.pdf
38K
Chris Clark <[e-mail]>Mon, Apr 22, 2024 at 4:30 PM
To: Jordan Garahana <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Hi Jordan, The Natural gas should be on the same spreadsheet that I had sent over last week? One
question we had are you only taking about our Welding Rod or is the Welding Wire included as well ?

Thanks
Chris
5/13/24, 12:06 PM State of Utah Mail - VOC and HAP emissions in tons
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1796705140435842856&simpl=msg-f:17967051404358428…2/5
CHRIS CLARK
Purchasing
Operations: Quality Control/Safety
Direct Line: 801-922-9832
Web: InterstateGratings.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, April 22, 2024 3:31 PM
To: Chris Clark <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Subject: Re: VOC and HAP emissions in tons

Hey Chris and Kriss, Thank you for getting me the information about the VOC and HAP usage within the last rolling 12-month period. I am still waiting for the usage of natural gas for that same timefra
sophospsmartbannerend
[Quoted text hidden]
Jordan Garahana <[e-mail]>Mon, Apr 22, 2024 at 4:38 PM
To: Chris Clark <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Hey Chris,
Yes I see that now about the natural gas usage, sorry I missed that when I went through the spreadsheet. For 6X it states
welding rod or wire used. I have attached a flowchart and on Chart 2 your facility would qualify under the welding section,
which is in yellow.
Thanks,
Jordan
[Quoted text hidden]
5/13/24, 12:06 PM State of Utah Mail - VOC and HAP emissions in tons
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1796705140435842856&simpl=msg-f:17967051404358428…3/5
6X - EPA_flowcharts (1).pdf
116K
Chris Clark <[e-mail]>Tue, Apr 30, 2024 at 1:46 PM
To: Jordan Garahana <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Hello Jordan, Attached is our 12 Month usage on the welding Rod/ Wire ( there are 3 Tabs on the bottom
of the page)

Thanks, please let me know if you need anything else.

Chris
CHRIS CLARK
Purchasing
Operations: Quality Control/Safety
Direct Line: 801-922-9832
Web: InterstateGratings.com

From: Jordan Garahana <[e-mail]>
Sent: Monday, April 22, 2024 3:31 PM
To: Chris Clark <[e-mail]>
5/13/24, 12:06 PM State of Utah Mail - VOC and HAP emissions in tons
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1796705140435842856&simpl=msg-f:17967051404358428…4/5
Cc: Kriss Sweat <[e-mail]>
Subject: Re: VOC and HAP emissions in tons

Hey Chris and Kriss, Thank you for getting me the information about the VOC and HAP usage within the last rolling 12-month period. I am still waiting for the usage of natural gas for that same timefra
sophospsmartbannerend
[Quoted text hidden]
Book2.xlsx
26K
5/13/24, 12:06 PM State of Utah Mail - VOC and HAP emissions in tons
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1796705140435842856&simpl=msg-f:17967051404358428…5/5
Jordan Garahana <[e-mail]>
FW: Welding Wire
1 message
Chris Clark <[e-mail]>Tue, May 7, 2024 at 11:03 AM
To: Jordan Garahana <[e-mail]>

Hi Jordan, Attached is the SDS Sheets for the Welding Wire that we Use.

Thanks

Chris

CHRIS CLARK
Purchasing
Operations: Quality Control/Safety
Direct Line: 801-922-9832
Web: InterstateGratings.com

5/13/24, 12:05 PM State of Utah Mail - FW: Welding Wire
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1798414180435332319&simpl=msg-f:1798414180435332319 1/2
3 attachments
SDS WASHINGTON S-6.pdf
287K
BOHLERER70S6WIRESDS.pdf
1446K
Avesta 316LSI.pdf
519K
5/13/24, 12:05 PM State of Utah Mail - FW: Welding Wire
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1798414180435332319&simpl=msg-f:1798414180435332319 2/2
SAFETY DATA SHEET (SDS)

~ 1 OF 4 ~

Zirconium & Carbon Steel SOLID WIRE AND RODS
REVISED 11-2019
SDS Number 702-ZR For Welding Consumables and Related Products
Conforms to the criteria of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS),
OSHA Hazard Communication Standard 29CFR 1910.1200
Standard Must Be Consulted for Specific Requirements

SECTION I – IDENTIFICATION of Product and Company
Manufacturer/Supplier: Washington Alloy Company Recommended use:
Arc and Gas Welding
Restriction on use:
Not Known
Telephone No: 704-598-1325
Address: 7010-G Reames Rd , Charlotte, NC 28216 Emergency No: 704-598-1325
Trade Name of Carbon Steel & Zirconium :
ER70S-2, ER70S-3,ER70S-4, ER70S-6, ER70S-7
R45, R60 Also known as RG-45, RG-60
Zr 702 (Zirconium 702) class ERZr2
Specification:
AWS A5.18 Carbon Steel Wire
AWS A5.2 Gas Welding Rod
AWS A5.24 Zirconium
SECTION II – COMPOSITION / INFORMATION ON INGREDIENTS

GHS Hazard Classification: Not Classified / Label Elements - Hazard symbol and Signal word = No symbol or signal word
Hazard statement and Precautionary statement = Not applicable
Other Hazards which do not result in GHS classification and Overview: Electric shock can kill. Wear approved head, hand and body protection,
which help to prevent injury from radiation, sparks and electrical shock. Welding arc and sparks can ignite combustibles or flammable materials. See
ANSI Z-49.1. This would include wearing welder’s gloves and a protective face shield and may include arm protectors, apron, hats, shoulder protection,
as well as dark substantial clothing. Welders should be trained not to allow electrically live parts to contract the skin or wet clothing and gloves. The
welders should insulate themselves from the work and ground. Arc Rays can injure eyes and burn skin. Read and understand the manufacturer’s
instructions and precautionary label on this product and your employer’s safety practices. See Section XIII.
As shipped, these are odorless, solid rods that are nonflammable, non-explosive, non-reactive and non-hazardous and may be copper coated.
Substance: Welding fumes and gases cannot be classified simply. The composition and quantity of these fumes and gases are dependent upon the metal
being welded, the procedures followed, and the electrodes used. Fumes may affect eyes, skin, respiratory system as well as pancreas and liver.
Workers should be aware that the composition and quantity of fumes and gases to which they may be exposed, are influenced by: coatings which may be
present on the metal being welded (such as paint, plating, or galvanizing), the number of welders in operation and the volume of the work area, the quality
and amount of ventilation, the position of the welder’s head with respect to the fume plume, as well as the presence of conta minants in the atmosphere
(such as chlorinated hydrocarbon vapors from cleaning and degreasing procedure). When the electrode is consumed, the fumes and gas decomposition
products generated are different in percent and form from the ingredients listed in Section II I, The composition of these fumes and gases are the
concerning matter and not the composition of the electrode itself. Decomposition products include those originating from the volatilization, reaction, or
oxidation of the ingredients shown in Section III, plus those from the base metal, coating and the other factors noted above.
Reasonable expected fume constituents of this product may include: Complex oxides or compounds of iron, manganese, silicon, copper, aluminum,
titanium, and zirconium. (Other complex oxides may be present when using fluxes).

Chemical Identity CAS No. EINECS#
Carbon dioxide 124-38-9 204-696-9
Carbon monoxide 630-8-0 211-128-3
Nitrogen dioxide 10102-44-0 -
Ozone 10028-15-6 233-069-2
Manganese (Mn) 7439-96-5 231-105-1
SECTION III – COMPOSITION / INFORMATION ON INGREDIENTS
*The term “HAZARDOUS MATERIALS” should be interpreted as a term required and defined in OSHA HAZARD COMMUNICATION STANDARD
29 CFR 1910.1200 however the use of this term does not necessarily imply the existence of any hazard.

Chemical Identity Ingredients CAS No. EINECS#
Composition percent in Weight (%)
Iron (Fe) (limits as oxide fume) 7439-89-6 231-096-4 Balance 0.2 max in Zr 702
Manganese (Mn) (limits as fume) (1) 7439-96-5 231-105-1 < 2.5
Silicon (Si) 7440-21-3 231-130-8 < 1.5
Copper (Cu) (1) 7440-50-8 231-159-6 < 0.5

Hafnium (2) 7440-58-6 231-166-4 < 5.0 In Zr 702 ONLY
Zirconium (2) 7440-67-7 231-176-9 >97.0 In Zr 702 ONLY

Other elements or ingredients may be present but in quantities much less than 1%.(1) Subject to reporting requirements of Section 302, 304, 311, 312, and 313 of the
Emergency Planning and Community Right-To-Know Act of 1986 and 40CFR 370 and 372; (Resp) = Respiratory/ Respiration: Welding and cutting of products that
contain Chromium may produce hexavalent chromium and YOU should read and follow OSHA’s final rules Fed Register #:71:10099-10385 dated 02-28-2006. Occupational
Safety and Health Administration 29 CFR 1910.1000 Permissible Exposure Limit (PEL). American Conference of Governmental Industrial Hygienists (ACGIH) Threshold
Limit Value (TLV[R]). *Ceiling Limit **Short Term Exposure Limit (2) Present in ZR 702 ONLY

SAFETY DATA SHEET (SDS)

~ 2 OF 4 ~

Zirconium & Carbon Steel SOLID WIRE AND RODS
REVISED 11-2019
SDS Number 702-ZR

SECTION IV – FIRST AID MEASURES

Contact with skin, eyes, ingestion or injection should not be a source for exposure with proper protection.
Ingestion: Avoid contact with metal fume or powers which may lead to ingestion
Inhalation: If breathing has stop or difficult move to fresh air and as needed perform artificial respiration. Call medical assistance or physician.
Skin Contact: Remove any contaminated clothing, gloves or other personnel equipment and promptly wash/flush with mild soap and water. For reddish
or blistered skin from thermal/arc radiation promptly wash/flush with water. Get medical assistance or physician help as needed.
Eye Contact: Arc radiation can injure eyes and also cause an arc flash – if this occurs, move to dark room removing lenses as required and get rest and
cover eyes with non-stick dressings (padded dressing) Removal of dust and fumes requires flushing with abundant amounts of clean water for at least 15
minutes. Get medical assistance or physician help as needed or if issues persist.
Most important symptoms/effects, acute and delayed:
Symptoms: Short-term(acute) overexposure to welding fumes may result in discomfort such as metal fume fever, dizziness, nausea, dryness or ir ritation
of nose, throat, or eyes. Pre-existing respiratory issues may be aggregated. Long-term (chronic) over-exposure to welding fumes can lead to siderosis (iron
deposits in lung) and is believed to affect pulmonary function. Manganese and Manganese compounds above safe exposure limits can affect or cause
irreversible damage to the central nervous system, including the brain: symptoms may result in impaired speech and movement, lack of energy , stiffness
in legs, feet, toes, muscular weakness as well as psychological disturbances. Reports of bronchitis and lung fibrosis have also been noted.
Hazards: Welding fumes and gases cannot be classified simply. Refer to Section II under Substance
SECTION V – FIRE-FIGHTING MEASURES
As shipped these are odorless, solid rods that are nonflammable, non -explosive, non-reactive and non –hazardous and may be copper coated. Welding arcs
and sparks can ignite combustibles or flammable materials Read and understand the manufacturer’s instructions and precautionary label on this product
and your employer’s safety practices. Read and understand: American National Standard ANSI Z49.1 Safety in Welding, Cutting and Allied Processes,
published by the AMERICAN WELDING SOCIETY, 550 N.W. LeJeune Road, Miami, Florida 33126 ; OSHA Safety and Health Standards are published
by the U.S. Government Printing Office, 732 North Capitol Street NW, Washington, DC 20401. Also, National Fire Protection Association NFPA 51B,
Standard for Fire Prevention During Welding, Cutting and other Hot Work
Suitable (and unsuitable) extinguishing media: As shipped these items will not burn however in the event use media recommended for the burning
materials and fire situation and surroundings. No unsuitable media known at this time. Carbon Dioxide is not effective on Zirconium
Specific hazards arising from the chemicals: Welding arcs and sparks can ignite combustibles or flammable materials
Specific protective equipment and precautions for firefighters: Wear self-contained breathing apparatus and full protective clothing in case of fire or
when fumes and vapors are present. Follow general fire-fighting precautions as in the workplace.
SECTION VI – ACCIDENTAL RELEASE MEASURES
Personal Precautions, protective equipment and emergency procedures: With airborne dust and fumes, be sure to use adequate engineering
ventilation controls and personal protection to prevent overexposure limits recommendations found in Section VIII.
Environment precautions: Control work practices to eliminate environmental release. These products are solid metal rods, with no spill or
leak hazards as shipped. If product becomes molten dam up with sand type media until it cools back to a solid and reuse/recycle as scrap.
Methods and Materials for containment and cleaning up: Solid rods can be picked up and placed back in the original container. Clea n up
immediately while following all safety guidelines as well as using all personal protection safety listed in section VIII. Avoid generating dust
and prevent materials from entering and drains, sewers or water sources. Disposal considerations found in S ection XIII.
When fumes and vapors are present. Follow general fire-fighting precautions as in the workplace.
SECTION VII – HANDLING AND STORAGE
Precautions for safe handling: Handle with care wearing gloves and keep formation of airborne dust and fumes to a minimum. If needed use adequate
engineering ventilation controls and personal protection to prevent overexposure limits recommendations found in Section VIII. Also read American
National Standard ANSI Z49.1 Safety in Welding, Cutting and Allied Processes, published by the AMERICAN WELDING SOCIETY, 550 N.W. LeJeune
Road, Miami, Florida 33126; OSHA Safety and Health Standards are published by the U.S. Government Printing Office, 732 North Capitol Street NW,
Washington, DC 20401. Do not eat or drink while using these products and ensure proper ventilation is used . Wash hands after use.
Conditions for safe storage, including any incompatibilities: All employees who handle these products should be trained to handle it safely. Open
packages of these products/containers on a safe stable surface and must be properly labeled at all times . Store products in original closed
packages, cool dry place, while avoiding extreme temperatures or incompatible items such as acids, oxidizers and halogens. Always follow all regulations
in accordance with local/regional/state/national guidelines.
SECTION VIII – EXPOSURE CONTOLS/PERSONAL PROTECTION
Control parameters
Flux or other ingredients CAS No. EINECS# Exposure Limit (mg/m3)
OSHA PEL ACGIH TLV
Iron (Fe) (limits as oxide fume) 7439-89-6 231-096-4 10 5 (Resp)
Manganese (Mn) (limits as fume) (1) 7439-96-5 231-105-1 1 , 3.0** , 5* 0.02 (Resp) 0.1***
Silicon (Si) 7440-21-3 231-130-8 15 (dust) 5 (Resp) WITHDRAWN
Copper (Cu) (1) 7440-50-8 231-159-6 1 (dust) 0.1(fume) 1 (dust) 0.2 (fume)

Hafnium (2) 7440-32-6 231-142-3 0.5 0.5
Zirconium (2) 7440-67-7 231-176-9 5 (as Zr) 10** 5 (as Zr)

SAFETY DATA SHEET (SDS)

~ 3 OF 4 ~

Zirconium & Carbon Steel SOLID WIRE AND RODS
REVISED 11-2019
SDS Number 702-ZR
Other elements or ingredients may be present but in quantities much less than 1%.(1) Subject to reporting requirements of Section 302, 304, 311, 312, and 313 of the
Emergency Planning and Community Right-To-Know Act of 1986 and 40CFR 370 and 372; (Resp) = Respiratory/ Respiration: Welding and cutting of products that
contain Chromium may produce hexavalent chromium and YOU should read and follow OSHA’s final rules Fed Register #:71:10099 -10385 dated 02-28-2006. Occupational
Safety and Health Administration 29 CFR 1910.1000 Permissible Exposure Limit (PEL). American Conference of Governmental Industrial Hygienists (ACGIH) Threshold
Limit Value (TLV[R]). *Ceiling Limit **Short Term Exposure Limit ***Inhalable fraction (2) Requirement on ZR 702 only
ACGIH - American Conference of Governmental Industrial Hygienists, a professional association which establishes exposure limits used a guideline in control for health
hazards but not an indication of safe and dangerous exposure limits TLV - Threshold Limit Value - an airborne concentration of a substance, which represents conditions
under which it is generally believed that nearly all workers, may be repeatedly exposed without adverse effect. The duration must be considered, including the 8-hour & BEI
- Biological Exposure Indices, represent the levels of determinants which are most likely to be observed in specimens collected from a healthy worker who has been exposed
to chemicals to the same extent as a worker with inhalation exposure to the TLV. OSHA - U.S. Occupational Safety and Health Administration. PEL - Permissible
Exposure Limit - this exposure value means the same as a TLV, except that it is limits guideline by OSHA.
Eye Protection: Wear a helmet or face shield with a filter lens shade number 12 -14 or darker for arc welding. Shield other workers by providing screens
and flash goggles. Use face-shield with filter lens of appropriate shade number (per ANSI Z49.1-1988, “Safety in Welding and Cutting”).
Protective Clothing: Wear approved head, hand and body protection, which help to prevent injury from radiation, sparks and electrical shock. See ANSI
Z-49.1. This would include wearing welder’s gloves and a protective face shield and may include arm protectors, apron, hats, shoulder protection, as well
as dark substantial clothing. Welders should be trained not to allow electrically live parts to contract the skin or wet clothing and gloves. The welders
should insulate themselves from the work and ground.
Ventilation: Use plenty of ventilation and/or local exhaust at the arc, to keep the fumes and gases below the threshold limit value within the worker’s
breathing zone and the general work area. Welders should be advised to keep their head out of the fumes.
Respiratory Protection: Use respirable fume respirator or air supplied respirator when welding in a confined space or general work area where local
exhaust and/or ventilation does not keep exposure below the threshold limit value.
HYGIENE/ WORK PRACTICES: With all chemicals/materials, avoid getting these products ON YOU or IN YOU. Wash hands after handling these
products. Do not eat or drink while handling these products. Use ventilation and other engineering controls to minimize potential ex posure to these
products.
SECTION IX – PHYSICAL AND CHEMICAL PROPERTIES
Appearance / Color / Odor / Physical state / Form: Gray, silver or copper coated round solid welding rods or wire that are odorless
Odor Threshold / pH / Flash Point / Evaporation Rate / Flammability (Solid, Gas) / Upper & Lower Flammability or Explosive Li mits: No data available
Vapor Pressure & Density / Relative Density / Solubility(water/other) / Partition coefficient (n-octanol/water) / Auto-ignition Decomposition temperature : No data available
SECTION X – STABILITY and REACTIVITY
Chemical stability: These products are considered stable as shipped and under normal conditions
Possibility of hazard reactions: No data and will not occur
Conditions to avoid: Avoid exposure to extreme temperatures, Incompatible materials
Incompatible materials: Incompatible items such as acids, oxidizers and halogens Strong acids, strong oxidizers, mineral acids, and halogens.
Hazardous decomposition products: Read Substance in Section II. Welding and cutting of products that contain Chromium may produce hexavalent
chromium and YOU should read and follow OSHA’s final rules Fed Register #:71:10099-10385 dated 02-28-2006. Occupational Safety and Health
Administration 29 CFR 1910.1000 Permissible Exposure Limit (PEL). The best method to determine the actual composition of generated fumes and gases
is to take an air sample from inside the welder’s helmet if worn or in breathing zone. For additional information, refer to t he American Welding Society
Publication, “Fumes and Gases in the Welding Environment”.
SECTION XI- TOXICOLOGICAL INFORMATION
Oral/Dermal/inhalation Iron: (Human-child); TDLo: 77 mg/kg. Oral (rat); LD50:30 gm/kg. Intraperitoneal (rabbit); LDLo: 20 mg/kg. Oral (guinea pig);
LD50:20 gm/kg. Oral (rat); TDLo: 63 gm/kg/6W-C. Inhalation (rat); 250 mg/m3/6H/4W-I. Intratracheal (rat); TDLo:450 mg/kg/15W-I. Silicon: Acute
oral toxicity (LD50): 3160 mg/kg [Rat]. Manganese: Acute oral toxicity (LD50): 9000 mg/kg [Rat]. Skin corrosion or irritation / Serious eye damage or
irritation / Respiratory or skin sensitization / Germ cell mutagenicity / Reproductive toxicity / Specific target organ toxicity – single exposure / Specific
target organ toxicity – repeated exposure: Not classified Carcinogenicity: Arc Rays can injure eyes and burn skin. Skin cancer has been reported
Information on the likely routes of exposures: Ingestion is not a likely route of exposure for this product or expected under normal use. If swallowed
call physician immediately! Do not induce vomiting unless directed by medical personnel. Rinse mouth with water if person is conscious. Never give
fluids or induce vomiting if person is unconscious, having convulsions, or not breathing. Inhalation of welding fumes and gases can be dangerous to your
health. Skin/Eye Contact: Arc Rays can injure eyes and burn skin. Skin cancer has been reported. IARC- has classified welding fumes as a possible
carcinogenic to humans (Group 2B)
Symptoms related to physical, chemical and toxicological characteristics: Inhalation: Short-term(acute) overexposure to welding fumes may result in
discomfort such as metal fume fever, dizziness, nausea, dryness or irritation of nose, throat, or eyes. Pre -existing respiratory issues may be aggregated.
Long-term (chronic) over-exposure to welding fumes can lead to siderosis (iron deposits in lung) and is believed to affect pulmonary function. Manganese
and Manganese compounds above safe exposure limits can affect or cause irreversible damage to the central nervous system, inc luding the brain:
symptoms may result in impaired speech and movement, lack of energy, stiffness in legs, feet, toes, muscular weakness as well as psychological
disturbances. Reports of bronchitis and lung fibrosis have also been noted.
Delayed and immediate effects and also chronic effects from short and long term exposure: There are no immediate health hazards associated with
the wire or rod form of this product. Skin, respiratory, pancreas, and liver disorders may be aggravated by prolonged over-exposures to the dusts or fumes
generated by these products. Pre-existing respiratory issues may be aggregated. Long-term (chronic) over-exposure to welding fumes can lead to siderosis
(iron deposits in lung) and is believed to affect pulmonary function. Manganese and Manganese compounds above safe exposure limits can affect or cause
irreversible damage to the central nervous system, including the brain: symptoms may result in impaired speech and movement, lack of energy, stiffness
in legs, feet, toes, muscular weakness as well as psychological disturbances. Reports of bronchitis and lung fibrosis have also been noted. Treat symptoms
and eliminate overexposure.
Other information during use: Inhalation acute toxicity: Carbon dioxide LC Lo (Human, 5 min): 90000 ppm Carbon monoxide LC 50 (Rat, 4 h): 1,300
mg/l Nitrogen dioxide LC 50 (Rat, 4 h): 88 ppm
SAFETY DATA SHEET (SDS)

~ 4 OF 4 ~

Zirconium & Carbon Steel SOLID WIRE AND RODS
REVISED 11-2019
SDS Number 702-ZR
SECTION XII- TOXICOLOGICAL INFORMATION
Ecotoxicity / Persistence and Degradability / Bioaccumulative Potential / Mobility in Soil: No data
Other Adverse Effects: Possibly harmful to aquatic life. Do not allow material to be released to the environment without proper governmental permits.
No further relevant information available.
SECTION XIII- DISPOSAL CONCIDERATIONS

Disposal Methods: Avoid or minimize generating waste. When possible collect scrap and by-products with proper id for recycling. Waste disposal must
be in accordance with appropriate Federal, National, Provincial, State, and local regulations. These products, if unaltered by use, may be disposed of by
treatment at a permitted facility or as advised by your local hazardous waste regulatory authority.
SECTION XIV- TRANSPORT INFORMATION
UN Number / UN Proper shipping name / Transport Hazard class (es)/ Packing group / Marine pollutant / Special Precautions: Not Regulated as
Dangerous Good or Not Regulated, No international regulations
SECTION XV- REGULATORY INFORMATION

United States: TSCA INVENTORY STATUS: The components of these products are listed on the TSCA Inventory
CERCLA REPORTABLE QUANTITY (RQ): Copper = 5000 lbs. (for particulates less than 100 micrometers in size). Manganese =
Reportable quantity: Included in the regulation but with no data values. See regulation (40 CFR 302.4).
EPCRA/SARA Title III 313 Toxic Chemicals The following metallic components are listed as SARA 313 “Toxic Chemicals” and potential
subject to annual SARA 313 reporting. See Section 3 for weight percent. Ingredient & Disclosure threshold: Copper 1.0% de minimis concentration;
Manganese 1.0% de minimis concentration
Section 311 Hazard Class: As shipped: Immediate (Acute) In use: Immediate & delayed (Acute)
California Proposition 65: WARNING: This product may expose you to chemicals including [Cobalt (II) Oxide, Titanium dioxide (airborne,
unbound particles of respirable size), Chromium (hexavalent compounds), Nickel, Lead and Lead Compounds, Carbon Black, Cadmium, Beryllium and
Beryllium Compounds] which are known to the State of California to cause cancer, and [Chromium (hexavalent compounds), Nickel, Lead and Lead
Compounds, Cadmium] which are known to the State of California to cause birth defects and/or other reproductive harm. For more informa tion go to
https://www.p65warnings.ca.gov/

US State Regulations list:
Alaska-Designated Toxic and Hazardous Substances: Aluminum Welding Fumes, Carbon Black, Manganese.
California-Hazardous Substances Listed substance: Aluminum, Aluminum oxide, Carbon Black, Copper, Manganese, Silicon, Titanium, Iron, Iron
oxide, Zirconium
Florida-Substance List: Aluminum, Manganese, and Zirconium.
Illinois-Toxic Substance List: Aluminum, Carbon Black, Copper, Manganese and Silicon.
Kansas-Section 302/313 List: Aluminum, Copper, and Manganese.
Massachusetts-Substance List: Aluminum, Carbon Black, Copper, Manganese, Silicon and Zirconium.
Michigan - Critical Materials Register: Copper.
Minnesota-List of Hazardous Substances: Aluminum Welding Fumes, Carbon Black, Manganese, and Silicon.
Missouri-Employer Information/Toxic Substance List: Aluminum, Carbon Black, Copper, Manganese, Molybdenum, Silicon, and Zirconium.
New Jersey-Right to Know Hazardous Substance List: Aluminum, Carbon Black, Copper, Iron, Iron oxide, Manganese, Silicon, Titanium, and
Zirconium.
North Dakota-List of Hazardous Chemicals, Reportable Quantities: Copper.
Pennsylvania-Hazardous Substance List: Aluminum, Carbon Black, Copper, Manganese, Silicon, Hafnium and Zirconium.
Rhode Island-Hazardous Substance List: Aluminum Welding Fumes, Carbon Black, Manganese, Silicon, and Zirconium.
Texas-Hazardous Substance List: Carbon Black, Manganese
West Virginia-Hazardous Substance List: Carbon Black, Manganese.
Wisconsin-Toxic and Hazardous Substances: Carbon Black, Manganese.
SECTION XVI- OTHER INFORMATION

Approval Date: 11-7-2019 NEW SDS Number : 702-ZR
HMIS® ratings Health: 2 Flammability: 0 Physical hazard: 0
NFPA CODES : FIRE: 0 HEALTH: 1 REACTIVITY: 0

U.S. DOT = Material is not hazardous and is not considered as a dangerous item.
Washington Alloy Co. Believes that the information contained in this (SDS) Safety Data Sheet is accurate. However,
Washington Alloy Co. does not express or implies any warranty with respect to this information.
Download the most current SDS and product information @ www.weldingwire.com

Page 1/13
Safety data sheet
according to 1907/2006/EC, Article 31
Printing date 17.02.2022 Revision: 11.11.2021Version number 86
54.0
SECTION 1: Identification of the substance/mixture and of the company/
undertaking
·1.1 Product identifier
·Trade name: Böhler EMK 6
·CAS Number:-
·EINECS Number:-
·1.2 Relevant identified uses of the substance or mixture and uses advised against
No further relevant information available.
·Application of the substance / the mixture
Rods and Wires for Welding
The product is a manufactured article in the sense of Article 3 No. 3, 1907/2006/EC (REACh). The purpose of the
present safety data sheet is therefore to provide instruction on safe usage of the product.
·1.3 Details of the supplier of the safety data sheet
·Manufacturer/Supplier:
voestalpine Böhler Welding Germany GmbH
Hafenstr. 21
59067 Hamm, Germany
www.voestalpine.com/welding
·Further information obtainable from:
Research and Development
Helena Stabel
[phone] - 578;
[e-mail]
-
·1.4 Emergency telephone number:
NCEC
[phone]
-
SECTION 2: Hazards identification
·2.1 Classification of the substance or mixture
·Classification according to Regulation (EC) No 1272/2008
The Product does not meet the criteria for classification in any hazard class according to Regulation (EC) No
1272/2008 on classification, labelling and packaging of substances and mixtures.
·2.2 Label elements
·Labelling according to Regulation (EC) No 1272/2008 Void
·Hazard pictograms Void
·Signal word Void
·Hazard statements Void
·2.3 Other hazards
·Results of PBT and vPvB assessment
·PBT:Not applicable.
·vPvB:Not applicable.
EU
(Contd. on page 2)
Page 2/13
Safety data sheet
according to 1907/2006/EC, Article 31
Printing date 17.02.2022 Revision: 11.11.2021Version number 86
Trade name: Böhler EMK 6
(Contd. of page 1)
54.0
SECTION 3: Composition/information on ingredients
·3.2 Chemical characterisation: Mixtures
·Description:Mixture of substances listed below with nonhazardous additions.
·Dangerous components:
CAS: 7439-96-5
EINECS: 231-105-1
Reg.nr.: 01-2119449803-34-XXXX
manganese
substance with a Community workplace exposure limit
0.1-2.5%
CAS: 7440-21-3
EINECS: 231-130-8
Reg.nr.: 01-2119480401-47-XXXX
silicon
Flam. Sol. 2, H228
0.1-2.5%
·Additional information:For the wording of the listed hazard phrases refer to section 16.
SECTION 4: First aid measures
·4.2 Most important symptoms and effects, both acute and delayed
No further relevant information available.
·General information:No special measures required.
·After inhalation:Supply fresh air; consult doctor in case of complaints.
·After skin contact:Generally the product does not irritate the skin.
·After eye contact:Rinse opened eye for several minutes under running water.
·After swallowing:Seek medical treatment.
·4.3 Indication of any immediate medical attention and special treatment needed
No further relevant information available.
SECTION 5: Firefighting measures
·5.1 Extinguishing media
·Suitable extinguishing agents:Suitable to surrounding conditions.
·5.2 Special hazards arising from the substance or mixture No further relevant information available.
·5.3 Advice for firefighters
For deletion of fire just use dry powders. Don't use any water or halogenated containing extinguishing agents
·Protective equipment:No special measures required.
SECTION 6: Accidental release measures
·6.1 Personal precautions, protective equipment and emergency procedures
Ensure adequate ventilation
Use respiratory protective device against the effects of fumes/dust/aerosol.
·6.2 Environmental precautions:No special measures required.
·6.3 Methods and material for containment and cleaning up:Pick up mechanically.
·6.4 Reference to other sections
See Section 7 for information on safe handling.
See Section 8 for information on personal protection equipment.
See Section 13 for disposal information.
EU
(Contd. on page 3)
Page 3/13
Safety data sheet
according to 1907/2006/EC, Article 31
Printing date 17.02.2022 Revision: 11.11.2021Version number 86
Trade name: Böhler EMK 6
(Contd. of page 2)
54.0
SECTION 7: Handling and storage
·7.1 Precautions for safe handling Ensure that suitable extractors are available on processing machines
·Information about fire - and explosion protection:No special measures required.
·7.2 Conditions for safe storage, including any incompatibilities
·Storage:
·Requirements to be met by storerooms and receptacles:No special requirements.
·Information about storage in one common storage facility:Not required.
·Further information about storage conditions:None.
·7.3 Specific end use(s)No further relevant information available.
SECTION 8: Exposure controls/personal protection
·8.1 Control parameters
·Ingredients with limit values that require monitoring at the workplace:
7439-96-5 manganese
IOELV Long-term value: 0.2* 0.05** mg/m³
as Mn; *inhalable, **respirable fraction
·Additional information:The lists valid during the making were used as basis.
·8.2 Exposure controls
·Personal protective equipment:
·General protective and hygienic measures:Wash hands before breaks and at the end of work.
·Respiratory protection:Filter P2
·Protection of hands:
EN 12477
Selection of the glove material on consideration of the penetration times, rates of diffusion and the degradation
·Material of gloves Leather gloves
·Penetration time of glove material
The exact break through time has to be found out by the manufacturer of the protective gloves and has to be
observed.
·Eye protection:Safety glasses
·Body protection:Protective work clothing
SECTION 9: Physical and chemical properties
·9.1 Information on basic physical and chemical properties
·General Information
·Appearance:
Form:Solid
Colour:Not determined.
·Odour:Odourless
·Odour threshold:Not determined.
·pH-value:Not applicable.
·Flash point:Not applicable.
·Flammability (solid, gas):Not determined.
(Contd. on page 4)
EU
Page 4/13
Safety data sheet
according to 1907/2006/EC, Article 31
Printing date 17.02.2022 Revision: 11.11.2021Version number 86
Trade name: Böhler EMK 6
(Contd. of page 3)
54.0
·Decomposition temperature:Not determined.
·Auto-ignition temperature:Product is not selfigniting.
·Explosive properties:Product does not present an explosion hazard.
·Explosion limits:
Lower:Not determined.
Upper:Not determined.
·Density:Not determined.
·Relative density Not determined.
·Vapour density Not applicable.
·Evaporation rate Not applicable.
·water:Insoluble.
·Partition coefficient: n-octanol/water:Not determined.
·Dynamic:Not applicable.
·Kinematic:Not applicable.
·Solvent separation test:
Solids content:100.0 %
·9.2 Other information No further relevant information available.
SECTION 10: Stability and reactivity
·10.1 Reactivity No further relevant information available.
·10.2 Chemical stability
·Thermal decomposition / conditions to be avoided:
No decomposition if used and stored according to specifications.
·10.3 Possibility of hazardous reactions No dangerous reactions known.
·10.4 Conditions to avoid No further relevant information available.
·10.5 Incompatible materials:No further relevant information available.
·10.6 Hazardous decomposition products:No dangerous decomposition products known.
SECTION 11: Toxicological information
·11.1 Information on toxicological effects
·Acute toxicity Based on available data, the classification criteria are not met.
·Primary irritant effect:
·Skin corrosion/irritation Based on available data, the classification criteria are not met.
·Serious eye damage/irritation Based on available data, the classification criteria are not met.
·Respiratory or skin sensitisation Based on available data, the classification criteria are not met.
·Additional toxicological information:
·Repeated dose toxicity
·Germ cell mutagenicity Based on available data, the classification criteria are not met.
·Carcinogenicity Based on available data, the classification criteria are not met.
·Reproductive toxicity Based on available data, the classification criteria are not met.
·STOT-single exposure Based on available data, the classification criteria are not met.
·STOT-repeated exposure Based on available data, the classification criteria are not met.
(Contd. on page 5)
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·Aspiration hazard Based on available data, the classification criteria are not met.
SECTION 12: Ecological information
·12.1 Toxicity
·Aquatic toxicity:No further relevant information available.
·12.2 Persistence and degradability No further relevant information available.
·12.3 Bioaccumulative potential No further relevant information available.
·12.4 Mobility in soil No further relevant information available.
·Additional ecological information:
·General notes:Not hazardous for water.
·12.5 Results of PBT and vPvB assessment
·PBT:Not applicable.
·vPvB:Not applicable.
·12.6 Other adverse effects No further relevant information available.
SECTION 13: Disposal considerations
·13.1 Waste treatment methods
·Recommendation Must be specially treated adhering to official regulations.
·European waste catalogue
12 01 13 welding wastes
·Uncleaned packaging:
·Recommendation:Disposal must be made according to official regulations.
SECTION 14: Transport information
·14.1 UN-Number Void
·ADR, ADN, IMDG, IATA Void
·14.2 UN proper shipping name
·ADR, ADN, IMDG, IATA Void
·14.3 Transport hazard class(es)
·ADR, ADN, IMDG, IATA
·Class Void
·14.4 Packing group
·ADR, IMDG, IATA Void
·14.5 Environmental hazards:
·Marine pollutant:No
·14.6 Special precautions for user Not applicable.
·14.7 Transport in bulk according to Annex II of
Marpol and the IBC Code Not applicable.
(Contd. on page 6)
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·Transport/Additional information:Not dangerous according to the above specifications.
·UN "Model Regulation":-
Void
*SECTION 15: Regulatory information
·15.1 Safety, health and environmental regulations/legislation specific for the substance or
mixture
No further relevant information available.
·Directive 2012/18/EU
·Named dangerous substances - ANNEX I None of the ingredients is listed.
·REGULATION (EC) No 1907/2006 ANNEX XVII Conditions of restriction: 27
·DIRECTIVE 2011/65/EU on the restriction of the use of certain hazardous substances in electrical
and electronic equipment – Annex II
None of the ingredients is listed.
·REGULATION (EU) 2019/1148
·Annex I - RESTRICTED EXPLOSIVES PRECURSORS (Upper limit value for the purpose of
licensing under Article 5(3))
None of the ingredients is listed.
·Annex II - REPORTABLE EXPLOSIVES PRECURSORS
None of the ingredients is listed.
·Regulation (EC) No 273/2004 on drug precursors
7723-14-0 phosphorus 2A
·Regulation (EC) No 111/2005 laying down rules for the monitoring of trade between the
Community and third countries in drug precursors
7723-14-0 phosphorus 2
·15.2 Chemical safety assessment:A Chemical Safety Assessment has not been carried out.
SECTION 16: Other information
This information is based on our present knowledge. However, this shall not constitute a guarantee for any specific
product features and shall not establish a legally valid contractual relationship.
·Additional information:
Recommendations for exposure scenarios, measures for risk management and identification of working conditions
under which metals, metal alloys and products made of metal can be safely worked can be found attached.
Detailed information can be found on our webpage www.voestalpine.com (Environment, REACH at voestalpine).
(Contd. on page 7)
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·
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·
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·
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·
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·
·
·Relevant phrases
H228 Flammable solid.
·Department issuing SDS:R&D
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·Contact:Helena Stabel
·Abbreviations and acronyms:
NCEC - National Chemical Emergency Centre (=Carechem24)
ADR: Accord relatif au transport international des marchandises dangereuses par route (European Agreement Concerning the International Carriage
of Dangerous Goods by Road)
IMDG: International Maritime Code for Dangerous Goods
IATA: International Air Transport Association
GHS: Globally Harmonised System of Classification and Labelling of Chemicals
EINECS: European Inventory of Existing Commercial Chemical Substances
ELINCS: European List of Notified Chemical Substances
CAS: Chemical Abstracts Service (division of the American Chemical Society)
TRGS: Technische Regeln für Gefahrstoffe (Technical Rules for Dangerous Substances, BAuA, Germany)
PBT: Persistent, Bioaccumulative and Toxic
vPvB: very Persistent and very Bioaccumulative
Flam. Sol. 2: Flammable solids – Category 2
·* Data compared to the previous version altered.
EU
BÖHLER Q G 316L-Si
Solid wire, high-alloyed, austenitic stainless
Classifi cations
EN ISO 14343-A AWS A5.9 / SFA-5.9
G 19 12 3 L Si ER316LSi
Characteristics and typical fi elds of application
Solid wire G 19 12 3 L Si / ER316LSi for joining and surfacing of matching and similar austenitic steels and cast steel grades. Good
corrosion resistance. Max. service temperature 400ºC.
1.4401 X5CrNiMo17-12-2, 1.4404 X2CrNiMo17-12-2, 1.4409 GX2CrNiMo19-11-2, 1.4429 X2CrNiMoN17-12-3, 1.4432 X2CrNi-
Mo17-12-3, 1.4435 X2CrNiMo18-14-3, 1.4436 X3CrNiMo17-12-3, 1.4571 X6CrNiMoTi17-12-2, 1.4580 X6CrNiMoNb17-12-2, 1.4583
X10CrNiMoNb18-12
UNS S31600, S31603, S31635, S31640, S31653
AISI 316L, 316Ti, 316Cb
Base materials
Typical analysis
C Si Mn Cr Ni Mo
wt.-% 0.02 0.8 1.7 18.4 12.4 2.8
Condition Yield strength R p0.2 Tensile strength R m Elongation A (L 0 =5d 0 ) Impact energy ISO-V KV J
MPa MPa % 20°C –196°C
u 430 ( 320) 580 ( 510) 38 ( 25) 120 45 ( 32)
u untreated, as-welded – shielding gas Ar + 2.5% CO 2
Mechanical properties of all-weld metal - typical values (min. values)
Operating data
Polarity DC +
Shielding gas
(EN ISO 14175)
M12, M13
Dimension mm
0.8
1.0
1.2
1.6
TÜV (19798), DB (43.132.93), CE
Approvals
1 / 1 03/2021
www.voestalpine.com/welding
All information provided is based upon careful investigation and intensive research.
However, we do not assume any liability for correctness and information is subject to change without notice.
Jordan Garahana <[e-mail]>
Compliance Report for 2023
2 messages
Chris Clark <[e-mail]>Fri, May 10, 2024 at 1:18 PM
To: Jordan Garahana <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Hi Jordan, please see attached Report if you need anything Else, please let me know

Thanks
Chris

CHRIS CLARK
Purchasing
Operations: Quality Control/Safety
Direct Line: 801-922-9832
Web: InterstateGratings.com

5/13/24, 12:06 PM State of Utah Mail - Compliance Report for 2023
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1798694477458264098&simpl=msg-f:17986944774582640…1/2
Annual Certification &Compliance Report .pdf
244K
Jordan Garahana <[e-mail]>Mon, May 13, 2024 at 12:01 PM
To: Chris Clark <[e-mail]>
Cc: Kriss Sweat <[e-mail]>
Hey Chris,
Thanks for sending all the information that I have requested. I will let you know if there is anything else I need for my
inspection.
Thanks,
Jordan
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
5/13/24, 12:06 PM State of Utah Mail - Compliance Report for 2023
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1798694477458264098&simpl=msg-f:17986944774582640…2/2