DAQ-2024-007819

SESls+*loRcE
January 1.0,2024
VIA US MAIL CERTIFIED
Utah Division of Air Quali4r t/
Minor Source Compliance
PO Box 144820
salt Lake city, uT 8411,4-4820
Subject: NESHAP - Amual Certification and Compliance Report
Nine Metal Fabrication and Finishing Source Categories
40CFR63Subpart XXXXXX
To whom it may concem,
St. George Steel operates a manufacturing facility located at 1301 East 700 North in St. George,
Utah. The facility is subject to the above referenced NESHAP standard. Please accept this letter
as St. George Steel's Annual Certification and Compliance Report.
Section 1 - Facility lnformation
| -_ _.__- --
Dl\/lSr'lN OF AIR (rLlAl ITY
REVIEWED
Initials: ( 6 ,r^,. l-1q- I
(-,,rt1,1,;, t,,. .t,,,,',,,&:l 6Y
i,t,# ljln, L
Period Covered by this Report:January 1,2023 through December 31,2023
"Existing" or "New" Source:Existing
Compliance Date (initial):July 25,2011
Source Category:Fabricated Metal Products
Source NAICS Number:332999
Gompany Name:St. George Steel LLC
Facility Name (if different):St. George Steel
Facility Physical Address:1301 East 700 North, St. George, UT 84770
Owner Gompany Name:St. George Steel LLC
Owner Gompany Address:1301 East 700 North, St. George, UT 84770
Owner Telephone Number:[phone]
Owner Gontact:Mike Housley
Owner e-mail (if available):m houslev@stoeoroesteel. com
Is the owner the operator?Yes
lf No, provide operator information:NA - Same as owner
1301 East 700 North, St. George, UT 84770 [phone]
t,
02c NESHAPs Annual Cert & Comp Report - SGS - 2024.docx
Page2
Section 2 - ldentification of Affected Operations
Part 1 - The following are the operations at this facility subject* to subpart XXXXXX
Dry Abrasive Blasting Yes No
1. Totally enclosed and unvented blast chambers X
2. Vented enclosures with a filtration control device X
3. Objects over B feet in any dimension without a filtration control device
(includes outdoor blasting of objects over 8 ft in any dimension)X
Dry Machining X
Dry Grinding or Dry Polishing with Stationary Machines X
Spray Painting
1. ln a spray booth X
2. Without a spray booth (for Fabricated Structural Metal facilities or any
objects over 15 feet)X
Welding
1. Use less than 2,000 pounds of MFHAP-containing welding rod or wire
annually X
2.Use 2,000 pounds or more of MFHAP-containing welding rod or
welding wire annually X
* lmpoftant Note: The operator understands that the operations listed above are affected sources under subparT XXXXXX
onlv iflwhen they use materials that contain or have the potential to emit metal fabrication or finishing metal HAP (MFHAP).
MFHAP containinglpotential is defined to be when the compounds of cadmium, chromium, lead, manganese, and nickel,
or any of these metals in the elemental form with the exception of lead, are used or have the potential to be emifted in
quantities of 0.1 percent or more, or 1.0 percent or more for elemental of compounds of manganese.
Parl2 - This table lists each drv abrasive blastinq operation at this facility subject to subpart XXXXXX.
Abrasive Blasting
Process Description / lD No.
HAP
Emitted or Usedb
(Gd. Gr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Check allthat apply)
Outdoor Blasting Cr, Mn, Ni Totally enclosed, unvented
Vented, with control device; describe
X Objects over 8 ft (with no control)
x Management practices
Enclosed Blaster Cr, Mn, Ni Totally enclosed, unvented
X Vented, with control device
(Cartridoe filter)
Objects over 8 ft (with no control)
x Management practices
02c NESHAPS Annual Cert & Comp Report - SGS - 2024.docx
Page 3
Part 3 - This table lists each drv machininq. drv qrindino. or drv polishinq operation at this facility
subject to subpart XXXXXX.
Dry Machining, Dry Grinding,
or Dry Polishing
Process Descriotion / lD No.
HAP
Emitted or Usedb
(Gd. Cr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Gheck allthat apply)
Metal Shearing Gr, Mn, Ni Control device; describe
X Management practices
Grinding with Abrasive Wheel
PedestalGrinder
Cr, Mn, Ni Control device; describe
x Management practices
Control device; describe
Management practices
Part 4 - This table lists each sprav paintinq operation at this facility subject to subpart XXXXXX.
Spray Painting
Process Description / !D No.
HAP
Emitted or Usedb
(Cd. Cr. Pb. Mn. Ni)
Gompliance Method(s) Employed
(Check allthat apply)
Not Applicable All paints were
investigated and it was
confirmed that no paints
contain MFHAPS.
Accordingly, the Facility is
not subject to the
requirements of this
section.
Spray booth, PM filter, HVLP spray
guns
HVLP spray guns, only
Management practices
Spray booth, PM filter, HVLP spray
guns
HVLP spray guns, only
Management practices
Part 5 - This table lists each weldins operation at this facility subject to subpart XXXXXX.
Welding Process Description
/ lD No.
HAP
Emitted or Usedb
(Cd. Cr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Check allthat apply)
Production Welding Cr, Mn, Ni X Management practices
Fume capture device; describe
Management practices
Fume capture device; describe
Management practices
Fume capture device; describe
t.
02c NESHAPS Annual Cert & Comp Report - SGS - 2024.docx
Page 4
Part 6 - The following applicable management practices are used at this facility, as practicable (check
allthat apply):
Dry Abrasive Blasting
x Minimize dust generation during emptying of abrasive blasting enclosure to reduce MFHAP
emissions, as practicable.
x Operate all equipment associated with dry abrasive blasting operations according to the
manufacturer's instructions.
x Minimize excess dust in the surrounding area to reduce MFHAP emissions, as practicable.
x For Outdoor Blasting - Enclose dusty abrasive storage areas and holding bins, seal chutes and
conveyors that transport abrasive materials.
x
For Outdoor Blasting - Do not re-use dry abrasive blasting media unless contaminants (i.e., any
material other than the base metal, such as paint residue) have been removed by filtration or
screening, and the abrasive material conforms to its original size.
x
For Outdoor Blasting - When practicable, switch from high particulate matter (PM)-emitting blast
media (e.9., sand) to low PM-emitting blast media (e.9., crushed glass, specular hematite, steel
shot, aluminum oxide).
Dry Machining, Dry Grinding, Dry Polishing
x Minimize excess dust in the surrounding area to reduce MFHAP emissions, as practicable.
x Operate equipment according to manufacturer's instructions.
Spray Painting
Proper cleaning and storage of spray guns, if applicable.
Training for employees using HVLP spray equipment, with certification as having completed
classroom or hands-on training in the proper selection, mixing, and application of coatings, with
refresher training repeated at least once every 5 years.
Facility to maintain a list of trained painters.
Welding
x Operate equipment according to manufacturer's instructions.
x Use welding processes with reduced fume generation capabilities, if practicable. (e.9., gas metal
arc welding (GMAW)-also called metal inert gas welding (MlG))
x Use welding process variations (e.9., pulsed current GMAW), which can reduce fume generation
rates, if practicable.
x Use welding filler metals, shielding gases, carrier gases, or other process materials which are
capable of reduced welding fume generation, if practicable.
x Optimize welding process variables (e.9., electrode diameter, voltage, amperage, welding angle,
shield gas flow rate, travel speed) to reduce the amount of welding fume generated, if practicable.
Use a welding fume capture and control system, operated according to the manufacturer's
specifications, if practicable.
(Printed Name)
President
(Title)
EPA Region VIII
Air and Toxics Enforcement
1595 Wynkoop Street
Denver, CO 80202-1129
02c NESHAPS Annual Cert & Comp Report - SGS - 2024.docx
Page 5
[phone]
(Phone)
m houslev@stoeorqesteel. com
(e-mail)
I hereby certify that, to the best of my knowledge, the information presented herein is true,
accurate and
I z,t
(Date)
Mike Houslev
Report of Visible Observations (Dry Blasting or Welding)
lf visible emissions were detected for more than six minutes during any observation period during the year list
all such instances below along with all corrective action taken and the results of subsequent follow-up
inspections for visible emissions.
Blasting or
Welding
Date Description of Corrective
Actions
Date and result of follow-up
observation
None
Certification
x
Yes, the facility referenced below !$ operating in compliance with all of the relevant
standards and other requirements of 40 CFR Part 63 subpart National Emission
Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories.
No, the facility referenced below is NOT operating in compliance with the relevant
standards and/or other requirements of 40 CFR Part 63 subpart National
Emission Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories.
Reason for noncompliance:
-I,f5U5
NESHAP Visual Determination
Log Sheet - Weldine
" lf any point has more than 360 seconds with visible emissions, refer to NESHAP XXXXXX for additional
requirements.
301 East 700 North. St.Utah
Date:March 14.2023 (O1)Wind Soeed:5 Mph NE
Observer:Mike Houslev Skv Conditions:Clear Blue
Observation
Point:
Start Time
IClnck iimcl
End Time
(Clock time)
0bservation
(Minutes)
Seconds with visible
emissions*:
Corrective Actions Taken
1 10:15 AM 10:30 AM 15 0 N/A
2.10:30 AM 10:45 AM 15 0 N/A
3.10:45 AM 11:00 AM 15 0 N/A
4.11:00 AM 11:15 AM 15 0 N/A
Date:June 13.2023 (O2)Wind Soeed:8 Mph NE
Observer:Mike Houslev Skv Conditions:Clear Blue
Observation
Point:
Start Time
fClnck time'l
End Time
(Clock time)
Observation
(Minutes)
Seconds with visible
emissions*:
Conective Actions Taken
I 10:15 AM 10:30 AM 15 0 N/A
2.10:30 AM 10:45 AM 15 0 N/A
3.10:45 AM 11:00 AM 15 0 N/A
4.11:00 AM 11:15 AM 15 0 N/A
Date;Seotember 12.2023 (O3)Wind Soeed:5 Mph NE
Observer:Mike Houslev Skv Conditions:Clear Blue
0bservation
Point:
Start Time
/Cloek timp'l
End Time
(Clock time)
Observation
(Minutes)
Seconds with visible
emissions*:
Conective Actions Taken
1.10:15 AM 10:30 AM 15 0 N/A
2.10:30 AM 10:45 AM 15 0 N/A
3.10:45 AM 11:00 AM 15 0 N/A
4.11:00 AM 11:15 AM 15 0 N/A
Date:December 13, 2023 (Q4)Wind Soeed:6 Moh NE
Observer:Godv Jones Skv Conditions:Clear Blue
Observation
Point:
Start Time
{Clock time)
End Time
lCloek lime)
Observation
IMinrrles)
Seconds with visible
emissions*:
Conective Actions Taken
1 10:15 AM 10:30 AM 15 0 N/A
2.10:30 AM 10:45 AM 15 0 N/A
3.10:45 AM 11:00 AM 15 0 N/A
4.11:00 AM 11:15 AM 15 0 N/A
---5U5
NESHAP Visual Determination
Log Sheet - Blastins
1301 East 700 North, St. George, Utah
* lf any point has more than 360 seconds with visible emissions, refer to NESHAP XXXXXX for additional
requirements.
Date:March 14, 2023 (Q1 )Wind Soeed:5 MPH. NNE
Observer:Mike Houslev Skv Conditions:Clear Blue
Observation
Point:
Start Time
(Clock time)
End Time
(Clock time)
0bservation
(Minutes)
Seconds with
visible emissions*
Conective Actions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
Date:June 15. 20n rc21 Wind Speed:None
Observer:Mike Houslev Skv Gonditions:Clear Blue
Observation
Point:
Start Time
{Clock time)
End Time
(Clock time)
0bservation
(Minutes)
Seconds with
visible emissions*
Corrective Aclions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
Date:June 15. 2023 (Q3)Wind Speed:5 Mph NE
Observer:Mike Houslev Skv Conditions:Clear Blue
Observation
Point:
Start Time
(Clock time)
End Time
(Clock time)
Observation
(Minutes)
Seconds wlth
visible emissions*
Conective Actions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
Date:June 15,2023 (Q4)Wind Soeed:6 Moh NE
Observer:Codv Jones Skv Gonditions:Clear Blue
0bservation
Point:
Start Time
(Clock time)
End Time
(Clock time)
0bservation
{Minutes)
Seconds with
visible emissions*
Gonective Actions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
---sllJS
mark date of
Daily
(Once each work dayfor ten
work days.)
Once
(Once every fifth work day.)
Monthly
Once every calendar month.)
Once three monthlv inspections
(Once every calendar
quarter.)
Quarterly
(Once every calendar
quarter.)
Ouarterly
(Once every calendar
quarter.)
additional requirements.
Visual Determination Schedule - Blasting
,'*,ruffiZZZ
ZZZZZ
hgve been cornpleted, begiilhe quarterly inspections.
l rr,'t;t,r*l arr,;r,r*f, ltr,*^; lu*,,,l a * a rr,rr*1
I nun ll nuH ll nnarr ll urs ll MLH ll MLH
I
6t13t23
MLH 9/1s/23 MH
6113124XXX 9115124
xxx
---JTIJS
NESHAP Visual Determination
Site Map
1301 East 700 North, St. George, Utah
lnstructions:
1. Verify that the welding and cutting (or blasting) operations associated with the emission points
to be observed are operating at normal capacity.
2. Observe each emission point for 15 minutes.
3. Use the stop watch to record the total number of seconds with visible emissions from any
point. Multiple points may be observed simultaneously but all emissions during the 15 minutes
must be totaled.
4. Record observations on the Observations Log Sheet.
o
IjTAi ! DFTARTI\4r'Nl I Oh
ET'IVI RON]I/lLNTAL QUAL ITY
I
I
It:
It;t:| _--- -.----.-.-.-.J
DIVISION OF AIR QUAI,ITYO = observation Point