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HomeMy WebLinkAboutDAQ-2024-0070181 DAQC-CI130500001-24 Site ID 13050 (B1) MEMORANDUM TO: FILE – UNIVERSAL INDUSTRIAL SALES INCORPORATED – Galvanizing Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: February 27, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: February 6, 2024 SOURCE LOCATION: 1065 West 400 North Lindon, UT 84042 DIRECTIONS: The office is located at 433 North 1060 West, Lindon, UT. Take I-15 exit 273 to Geneva Road, then north bound to 500 North. SOURCE CONTACTS: Scott Turner, Project Manager 801-406-9338 safety@uismail.com Bart Adams, Summit Environmental Consultant 801-599-2748 badams@summit-enviro.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Universal Industrial Sales, Inc. (UIS Inc.) manufactures highway signs, railings, posts, and other components for the Utah Department of Transportation and other state transportation departments. Mild grade carbon steel, that is manufactured at other companies, arrives onsite. The metal can be lightly sand blasted when necessary for coating adhesion. The product is then painted or galvanized to form a zinc layer. The galvanization process involves removing any surface impurities in a hot alkaline (NaOH) solution, the items are then rinsed in water, then pickled in a hot acid (H2SO4) solution, then rinsed again. The items are then submerged in a pre-fluxing ammonium chloride solution, and then dipped into molten zinc. Grinding and HVLP painting operations are also conducted at the source in enclosed areas. Employees wear protective gear when engaging in these processes. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN130500005-19, dated November 13, 2019 0 0 2 NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, SOURCE EVALUATION: Name of Permittee: Permitted Location: Universal Industrial Sales Incorporated – Galvanizing Facility P.O. Box 699 1065 West 400 North Pleasant Grove, UT 84062 Lindon, UT 84042 SIC Code: 3479: (Coating, Engraving, & Allied Services, NEC) 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] 3 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. No limits appear to have been exceeded. No modifications have been made to equipment or process. Records were provided during and after the site visit. Records are maintained for a minimum of two years. No reportable breakdowns have occurred since the previous inspection. An emission inventory was submitted to DAQ. All equipment was already installed when the current AO was issued, but a formal notification was made September 14, 2021. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Galvanizing Plant Universal Industrial Sales, Inc. II.A.2 Indoor Grit Blasting Capacity: 2,000 lbs/hr II.A.3 Two (2) Natural Gas-Fired Boilers Capacity: <5MMBtu/hr each Fuel: natural gas II.A.4 Emergency Engine Capacity: 142 hp (106 kW) Fuel: diesel II.A.5 Galvanizing Kettle Heater Capacity: 7.6 MMBtu/hr Fuel: natural gas II.A.6 One (1) Galvanizing Kettle Capacity: 15 tons/hr Maximum operating temperature 860ºF II.A.7 Paint Booth II.A.8 One (1) Dip Tank The tank shall contain sulfur acidic dip, caustic soda dip, or water dip as needed. Operating temperature 160ºF II.A.9 Two (2) Caustic Soda Dip Tanks Operating temperature 160ºF II.A.10 Two (2) Water Rinse Tanks for Caustic Line This equipment is listed for informational purposes only. II.A.11 Three (3) Sulfuric Acid Dip Tanks Maximum operating temperature 160ºF Surface dimensions 6 ft x 46 ft 4 II.A.12 Two (2) Water Rinse Tanks for Sulfuric Line This equipment is listed for informational purposes only. II.A.13 Pre-Flux Dip Tank Contains zinc ammonium chloride solution This equipment is listed for informational purposes only. II.A.14 Sulfuric Acid Purification System This equipment is listed for informational purposes only. Status: In Compliance. The equipment listed in this section has been installed in the two operation buildings, located southwest of the main office building, and west of the unrelated Valmont operation buildings. Additional information: • II.A.2 - Indoor Grit Blasting is contained in an enclosed area within the operation building. A fan has been installed on the east side of the building that vents air outward without any permitted or required filtration. • II.A.5 - The Galvanizing kettle heater is located in the basement directly below the Galvanizing Kettle (tank). Two burners are located on each end of the heater. • II.A.6 - The Galvanizing kettle was operating at 833° F, on the day of this inspection, under the 860° F maximum operating temperature listed above. • The paint booth is an unfiltered enclosed area within the building. • Small amounts of hand grinding take place at the end of the galvanizing line. This is mostly for touch-up and to remove excess material from the steel. No grinding was taking place during the time of the of this inspection. • II.A.4 the emergency engine has been installed on the west side of the main tank operation building. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not exceed 2,100 tons of Zinc consumed per rolling 12-month period. [R307-401] II.B.1.a.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. Consumption of zinc shall be determined by purchase records. The records of consumption shall be maintained on a monthly basis and retained for all periods when the plant is in operation. [R307-401-8] Status: In Compliance. The 12-month rolling total for consumed Zinc was 1,878 tons for the period of January through December 2023. See attached. 5 II.B.1.b The owner/operator shall not allow visible emissions from the following points to exceed the specified opacity values: A. Paint booth operation - 0% (i.e. no visible emissions) B. Grit blasting operation - 20% C. Emergency generator engine - 20% D. All other points - 10%. [R307-306-4, R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources on site shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. No visible emissions were observed from any point during the inspection. The generator and abrasive blasting operation were not in use. Only small paint projects were being conducted. II.B.2 Galvanizing Process Tanks Requirements II.B.2.a The owner/operator shall not exceed the following operating parameters in the specified tanks at any time: Tank Contents Concentration: Temperature NaOH 15% wt 160oF H2SO4 15% wt 160oF Pre-flux - 160oF [R307-401] II.B.2.a.1 The owner/operator shall measure and record the concentration of the NaOH, H2SO4, and pre- flux dip tanks at least once weekly using a method approved by the Director. [R307-401-8] II.B.2.a.2 The owner/operator shall measure and record the temperature of the NaOH, H2SO4 and pre-flux solutions tanks at least once weekly. [R307-401-8] II.B.2.a.3 The owner/operator shall equip the NaOH, H2SO4, and pre-flux dip tanks with a permanently mounted thermometer to measure the temperature of the water in each tank. A portable thermometer may be used in lieu of the permanently mounted thermometer. Continuous reading is not required. Both the temperature and the concentration shall be recorded in a log. [R307-401-8] Status: In Compliance. Temperatures and concentrations are noted daily in a log book. The notations are entered on a computerized spreadsheet weekly. The day of inspection, the concentrations and temperatures were 10% at 150.2 degrees F for NaOH, 10% at 158.7 degrees F for H2S04, and Pre-flux at 158.6 degrees F. Permanently mounted thermometers are in place, and temperature readouts can be observed in the office of the chemical tank building. II.B.3 Emergency Generator Engine Requirements II.B.3.a The owner/operator shall install an emergency engine that is certified to meet a NMHC + NOx emission rate of 3.0 g/hp-hr or less. [R307-401-8] Status: In Compliance. A Cummins Exhaust Emission Data Sheet was submitted as part of the NOI January 24, 2019, which stated that the engine meets the above emission rate when used at 1/2 standby. The source maintains a complete copy of the NOI on site. 6 II.B.3.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. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.1 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.2 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] II.B.3.b.3 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 IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The engine operated for 26.5 hours for testing and maintenance during the 12-month period. The engine is equipped with a non-resettable hour meter. The source maintains a copy of the engines emission rate on site. The engine also operated for three hours of emergency use. II.B.4 Fuel Requirements II.B.4.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8] II.B.4.a.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.4.a.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. The source purchased diesel fuel through Rinehart Oil, which declared it to be 15 ppm or less sulfur content. II.B.5 VOC & HAP Requirements 7 II.B.5.a The owner/operator shall not emit more than the following from evaporative sources (painting, coating, and/or cleaning) on site: 10.20 tons per rolling 12-month period for all VOCs combined 0.90 tons per rolling 12-month period for Ethylbenzene 0.60 tons per rolling 12-month period for Methyl Isobutyl Ketone 1.50 tons per rolling 12-month period for Toluene 2.40 tons per rolling 12-month period for Xylene (considered together) 0.10 tons per rolling 12-month period for each individual HAPs not listed above 5.80 tons per rolling 12-month period for all HAPs combined. [R307-401-8] II.B.5.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.5.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] II.B.5.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] Status: In Compliance. The 12-month rolling totals are as follows: 7.16 tons of VOC 0.13 tons of Ethylbenzene 0.14 tons of Methyl Isobutyl Ketone 0.51 tons of Toluene 0.82 tons of Xylene 0.02 tons of HAPs not listed 1.64 tons of HAPs combined See attached. 8 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) IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. Standards are met by Conditions II.B.3.a through II.B.4.a.2 of this AO. This engine operates for non-emergency purposes under 100 hours in any given 12-month period. The engine installation includes a non-resettable hour meter and usage is logged as required. The Project Manager certifies that the ½ hour a week maintenance program in place for the engine includes the required engine services. The manufacturer of the engine certifies the engine to meet the EPA NOx emissions standards. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. This emergency engine meets the standards for NSPS Subpart IIII. The diesel fuel is certified to be low sulfur #2. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-210. Standards of Performance for New Stationary Sources. Status: In compliance. Compliance with this rule is met by compliance with subpart IIII. R307-214. Incorporating National Emission Standards for Hazardous Air Pollutants, ZZZZ. Status: In Compliance. This rule is met by compliance with ZZZZ concerning the emergency generator. R307-214. Incorporating National Emission Standards for Hazardous Air Pollutants, MMMM. Status: Not applicable for 40 CFR Part 63 Subpart MMMM. National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products is only applicable to a major sources, per section §63.3881(b). R307-214. Incorporating National Emission Standards for Hazardous Air Pollutants, XXXXXX. Status: Not applicable for 40 CFR Part 63 Subpart XXXXXX, National Emission Standards for Hazardous Air Pollutants for Nine Metal Fabrication and Finishing. UIS Inc. uses mild-grade carbon steel and no stainless steel metal components. The source does not fall under a SIC classification category, which would trigger applicability to subpart XXXXXX. 9 PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306] Status: In Compliance. This area source rule is satisfied by compliance with condition II.B.1.b of the AO. All abrasive blasting conducted at the source takes place within the Indoor Grit Blasting building. Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. No visible emissions were observed from any point during the inspection. Miscellaneous Metal Parts and Products Coatings [R307-350] Status: In Compliance. The products used at UIS Inc. comply with R307-350-5 Table I Coating Limits for Extreme Performance. The product line presented as being in use at the time of the inspection indicated that the VOC content of all of the coatings were under the 3.5 pounds per gallon limit. The highest percentage of VOC per gallon was for Endura-Shield Series 73 product. The VOC weight per gallon for this coating ranges from 2.70 to 3.15 pounds per gallon depending on how it is thinned and the type of thinner used. The source does not use solvents. EMISSION INVENTORY: Listed are the Actual Emissions Inventory provided from Universal Industrial Sales Incorporated – Galvanizing Facility. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN130500005-19, dated November 13, 2019, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 4205.00 Carbon Monoxide 3.41 1.5683 Nitrogen Oxides 2.47 1.8662 Particulate Matter - PM10 6.60 0.8028 Particulate Matter - PM2.5 5.73 0.5906 Sulfur Dioxide 0.04 0.012 Volatile Organic Compounds 10.22 8.192 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Ethyl Benzene (CAS #100414) 1800 0.27 Generic HAPs (CAS #GHAPS) 800 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 1200 0.34 Toluene (CAS #108883) 3000 0.42 Xylenes (Isomers and Mixture) (CAS #1330207) 4800 1.8 10 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN130500005-19, dated November 13, 2019: UIS Inc. should be considered in compliance. The source appeared to be adequately maintained and operated properly. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. Hard hat, steel toes, and safety glasses are needed to tour the facility. NSR RECOMMENDATIONS: None at this time ATTACHMENTS: VEO Form, Zinc and VOC/HAPs Records UIS Monthly Zinc Galvanizing Line Months Zinc Jan-23 186,853 Feb-23 264,073 Mar-23 363,220 Apr-23 305,066 May-23 279,326 Jun-23 372,753 Jul-23 382,286 Aug-23 374,660 Sep-23 325,086 Oct-23 369,893 Nov-23 268,840 Dec-23 263,120 12 mo rolling total lbs 3,755,176 12 mo rolling total tons 1,878 Permit Limits/Tons 2,100 Paint Line Limits in Tons Tons per 12 mo Total VOC- Permitted to 10.20 7.16 See 12 mo reports Comb HAP- Permitted to 5.80 1.64 See 12 mo reports Xylene 2.40 0.82 See 12 mo reports Toluene 1.50 0.51 See 12 mo reports MIBK 0.6 0.14 See 12 mo reports Ethyl Benzene 0.9 0.13 See 12 mo reports HEXMAMETHYLENE-1,6-DIISOCYANATE 0.1 0.01 See 12 mo reports Methanol 0.1 0.01 See 12 mo reports Other HAPS 0.1 Ethylene Glycol Monoproply Ether 0.1 0 See 12 mo reportsSee 12 mo reports DEHP 0.1 0 See 12 mo reportsSee 12 mo reports DIBUTYL PHTHALATE 0.1 0 See 12 mo reportsSee 12 mo reports NAPHTHALENE 0.1 0 See 12 mo reportsSee 12 mo reports Cumene 0.1 0.02 See 12 mo reportsSee 12 mo reports Other HAPS total 0.02 See 12 mo reportsSee 12 mo reports MONTH YEAR MONTH TOTAL VOC IN LBS 12 Month Rolling Total VOC/Emission Estimates Universial Industrial Supply (UIS) MONTH TOTAL VOC IN TONS FACILITY NAME: December 2023 1,334.28 0.6671416553025 November 2023 363.42 0.1817076441075 October 2023 661.60 0.330800464365 September 2023 734.11 0.367054098775 August 2023 1,965.00 0.9825004737975 July 2023 901.18 0.45059242424 June 2023 1,927.01 0.9635053957025 May 2023 1,706.36 0.85317985816 April 2023 516.79 0.2583939156575 March 2023 1,168.87 0.5844357467375 February 2023 2,520.84 1.26041990529 January 2023 511.08 0.2555418735975 14,310.5512 Month Rolling Total VOC in LBS:7.16Tons: Monday, February 12, 2024 Page 1 of 1 Prepared by Using CHEMICAL NAME MONTH/YEAR MONTHLY INDIVIDUAL HAP IN LBS 12 Month Rolling Individual HAP/Emission Estimates/Sept 2020 thru Aug 2021Universial Industrial Supply (UIS) CAS # MONTHLY INDIVIDUAL HAP IN TONS FACILITY NAME: ETHYL BENZENE100-41-4 12 Month Aggregate Total of Individual HAP in LBS 255.24 12 Month Aggregate Total of Individual HAP in Tons 0.13 METHYLENEBIS(PHENYLISOCYANATE) {MDI} {METHYLENE DIPHENYL DIISO..}101-68-8 12 Month Aggregate Total of Individual HAP in LBS 6.66 12 Month Aggregate Total of Individual HAP in Tons 0.00 Methyl Isobutyl Ketone108-10-1 12 Month Aggregate Total of Individual HAP in LBS 288.46 12 Month Aggregate Total of Individual HAP in Tons 0.14 TOLUENE108-88-3 12 Month Aggregate Total of Individual HAP in LBS 1,020.64 12 Month Aggregate Total of Individual HAP in Tons 0.51 XYLENE (MIXED ISOMERS)1330-20-7 12 Month Aggregate Total of Individual HAP in LBS 1,640.10 12 Month Aggregate Total of Individual HAP in Tons 0.82 Methanol67-56-1 12 Month Aggregate Total of Individual HAP in LBS 19.48 12 Month Aggregate Total of Individual HAP in Tons 0.01 HEXMAMETHYLENE-1,6-DIISOCYANATE822-06-0 12 Month Aggregate Total of Individual HAP in LBS 15.31 12 Month Aggregate Total of Individual HAP in Tons 0.01 CUMENE98-82-8 12 Month Aggregate Total of Individual HAP in LBS 34.51 12 Month Aggregate Total of Individual HAP in Tons 0.02 Monday, February 12, 2024 Page 1 of 1 Prepared by Using MONTH YEAR MONTH COMBINED HAP IN LBS 12 Month Rolling Combined HAP/Emission Estimates Universial Industrial Supply (UIS) MONTH COMBINED HAP IN TONS FACILITY NAME: December 2023 310.36 0.1551787015975 November 2023 161.24 0.0806204909825 October 2023 91.90 0.04595128713 September 2023 241.72 0.120862214935 August 2023 442.46 0.2212306577425 July 2023 287.36 0.143679709285 June 2023 463.18 0.2315924197125 May 2023 334.15 0.16707561801 April 2023 70.08 0.0350382228525 March 2023 225.79 0.1128959922825 February 2023 560.92 0.280461937 January 2023 85.74 0.0428721047125 3,274.9212 Month Rolling Combined HAP in LBS:1.64Tons: Monday, February 12, 2024 Page 1 of 1 Prepared by Using