HomeMy WebLinkAboutDAQ-2024-0045691
DAQC-CI159500001-23
Site ID 15950 (B1)
MEMORANDUM
TO: FILE – SCHUFF STEEL – Lindon Steel Fabrication Facility
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Susan Weisenberg, Environmental Scientist
DATE: November 8, 2023
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County
INSPECTION DATE: August 25, 2023
SOURCE LOCATION: 325 South Geneva Road
Lindon, UT 84042
DIRECTIONS: Take I-15 southbound to Exit 273. Drive to North Geneva Road.
SOURCE CONTACTS: Gary Johnson, Area Safety Manager
385-256-9219 gary.johnson@schuff.com
Luis Roibal, Site Safety Manager
385-256-9219
OPERATING STATUS: Operating normally.
PROCESS DESCRIPTION: Schuff Steel Company (Schuff Steel) is a steel fabrication
facility. Emissions are primarily associated with cutting, abrasive
blasting, and painting large steel pieces. Schuff Steel employs
plasma cutters and welding machines to form the steel.
Compressor engines are employed to run the outdoor abrasive
blasting. Schuff Steel receives and ships steel products via road
and rail. Schuff Steel uses several different types of steel cutting
equipment including a CNC plasma cutter, a plasma burner
table, a CNC pedd plate machine, 25 hand cutting torches, and
five (5) hand plasma units. The source has 85 mobile welding
units throughout the facility. The blasting equipment includes a
Blastec Descale, a hand blaster, a shot blaster, and a jet blaster.
The Blastec Descale, shot blaster, and jet blaster use steel shot
while the hand blaster uses garnet. The blasting equipment is
confined in buildings on site. There is one (1) unconfined
blasting unit, the Chemo Blaster, that uses sand. Schuff Steel has
three (3) paint buildings on site. The source uses airless spray
guns in these buildings. Schuff Steel has two (2) compression
engines on site that are 49 hp and 275 hp. These engines are used
to run the unconfined blasting process.
2
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN159500001-19, dated
December 4, 2019
MACT (Part 63) - XXXXXX: National Emission Standards for
Hazardous Air Pollutants Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories,
UAC R307-203 Emission Standards: Sulfur Content of Fuels
UAC R307-306 PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting
UAC R307-309 Nonattainment and Maintenance Areas for
PM10 and PM2.5: Fugitive Emissions and Fugitive Dust
R307-350 Miscellaneous Metal Parts and Products Coatings
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Schuff Steel - Lindon Steel Fabrication Facility
325 South Geneva Road 325 South Geneva Road
Lindon, UT 84042 Lindon, UT 84042
SIC Code: 3441: (Fabricated Structural Metal)
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. Records, maintenance, and Emission Inventories have been
maintained. No equipment modifications have occurred since the current AO was issued.
No applicable Unavoidable Breakdowns have occurred since the source was last inspected.
Schuff Steel purchased the equipment and site buildings from an older steel company that
was associated with Geneva Steel. Startup notifications are not applicable for this facility.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Schuff Steel
Steel Fabrication Facility
II.A.2 One (1) Blastec Descale Blaster
Media: Steel Shot
Control: Dust Collector
II.A.3 One (1) Hand Blaster
Media: Garnet (Sand)
Control: Dust Collector
II.A.4 One (1) Shot Blaster
Media: Steel Shot
Control: Dust Collector
II.A.5 One (1) Jet Blaster
Media: Steel Shot
Control: Dust Collector
II.A.6 One (1) Chemco Blaster
Media: Green Sand, Garnet (Sand)
Control: None, unconfined outdoor blasting
II.A.7 One (1) Plasma Cutter
Control: Dust Collector
II.A.8 One (1) Plasma Burner Table
Control: none, cuts on a water table
II.A.9 One (1) Pedd Plate Machine
Control: Dust Collector
II.A.10 Various Cutting Torches and Hand Plasma Units
II.A.11 Hand Welders and Robotic Welders
II.A.12 Three (3) Paint Buildings
Various spray guns in operation.
4
II.A.13 Two (2) Emergency Compressor Engines
Capacity: 49hp and 275 hp
Fuel: Diesel
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ
II.A.14 One (1) Diesel Tank
Capacity: 1,000 gallons
II.A.15 One (1) Parts Washer
Status: In Compliance. The permitted equipment was observed on site as described with the
exception of II.A.13, the two (2) emergency compressor engines, which were
discontinued in 2018. II.A.14, the diesel tank, is still being used to fuel the off-road
vehicles used on site. No additional equipment was observed during the site
observations.
II.B Requirements and Limitations
II.B.1 Site-wide Requirement
II.B.1.a The owner/operator shall not use more than 5,187,748 cubic feet of oxygen combined for plasma
cutting operations, with no more than 1,680,696 cubic feet of oxygen used for the plasma burner
table per rolling 12-month period. [R307-401-8]
Status: In Compliance. A total of 3,089,924.00 cubic feet of oxygen for all combined plasma
cutting operations, of which 83,820.00 cubic feet of that amount was used for the Plasma
Burner table, was reported for the period of August 2022, through July of 2023.
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. Records
of oxygen use shall be kept for all periods when the facility is in operation. Oxygen use shall be
determined by vendor receipts. [R307-401-8]
Status: In Compliance. The records are calculated as required on a monthly basis. See the
attached Oxygen Usage spreadsheet.
II.B.2 Dry Abrasive Blasting Operations Requirements
II.B.2.a The owner/operator shall not use more than 1,385,900 pounds of abrasive media per rolling 12-
month period for all abrasive blasting operations with no more than 50,000 pounds being used
per rolling 12-month period for unenclosed abrasive blasting operations. [R307-401-8]
Status: In Compliance. A total of 993,400 lbs blasting media was reported for confined
blasting for the 12-month period of August 2022, through July 2023. No unconfined
blasting operations were reported for that time period.
II.B.2.b 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
of the amount abrasive media used for enclosed and unenclosed abrasive blasting shall be kept
for all periods when the plant is in operation. Records of abrasive media use shall be kept on a
daily basis. [R307-401-8]
Status: In Compliance. Records are kept for each day of operation and then tabulated into
monthly amounts as required. See the attached Confined & Unconfined Blasting Record.
5
II.B.2.c The owner/operator shall route all emissions from enclosed blasting operations (II.A.2 through
II.A.5) to a working dust collector. [R307-401-8]
Status: In Compliance. Schuff Steel routes all emissions from enclosed blasting operations
(II.A.2 through II.A.5) to a dust collector.
II.B.2.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
differential pressure across the dust collectors. The static pressure differential across the dust
collectors shall be between 0.5 and 6.0 inches of water column. [R307-401-8]
Status: In Compliance. The static pressure differential was observed operating at 2.1 inches
of water column on the day the inspection.
II.B.2.d.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. The pressure gauge shall measure the pressure drop in half (1/2)-inch water column
increments or less. The pressure gauge shall be calibrated according to the manufacturer's
instructions at least once every 12 months. [R307-401-8]
Status: In Compliance. The gauges are located adjacent to the dust collectors. They were
calibrated by Western States in December of 2022, and September of 2023. See the
attached calibration sheets.
II.B.3 Haul roads and Fugitive Dust Source
II.B.3.a The owner/operator shall not allow visible emissions from haul roads, and all other fugitive dust
sources to exceed 20 percent opacity on site and 10 percent at the property boundary unless
otherwise specified in this permit. [R307-309-5, R307-401-8]
Status: In Compliance. No visible emissions were observed from the haul roads or the
operation areas on the day of this inspection.
II.B.3.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall use
procedures similar to Method 9. The normal requirement for observations to be made at 15-
second intervals over a six-minute period, however, shall not apply. Visible emissions shall be
measured at the densest point of the plume but at a point not less than one-half vehicle length
behind the vehicle and not less than one-half the height of the vehicle.
[R307-309-5, R307-401-8]
Status: In Compliance. Observations were done in a manner consistent with Method 9.
II.B.3.b The owner/operator shall use water application or other control options contained in R307-309 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads.
Controls shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-309-5,
R307-401-8]
Status: In Compliance. Schuff Steel applies water to minimize dust from haul roads and
operation areas. The unpaved areas at the facility appeared damp on the day of the
inspection.
II.B.3.b.1 The owner/operator shall keep and maintain records of water application for all periods when the
plant is in operation. The records shall include the following items:
A. Date and time treatments were made
B. Number of treatments made
[R307-309-5, R307-401-8]
Status: In Compliance. Watering records include the date of the application and the
signature of the operator. See the attached Water Log records.
6
II.B.3.b.2 Opacity requirements for fugitive dust shall not apply when the wind speed exceeds 25 miles per
hour if the owner or operator has implemented, and continues to implement, the accepted fugitive
dust control plan and administers at least one of the following contingency measures:
A. Pre-event watering;
B. Hourly watering;
C. Additional chemical stabilization; or
D. Cease or reduce fugitive dust producing operations.
E. Other contingency measure approved by the director.
[R307-309-5]
Status: In Compliance. Schuff Steel has a Fugitive Dust Control Plan dated September 17,
2019. The site manager is aware of the opacity requirements for dust when the wind speed
exceeds 25 miles per hour.
II.B.3.c Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic or
written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan
Permit Application Website. If a written FDCP is completed, it shall be submitted to the
Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the
FDCP for control of all fugitive dust sources associated with Schuff Steel facility. [R307-309-6]
Status: In Compliance. Schuff Steel has a FDCP dated September 17, 2019.
II.B.4 VOC and HAP Limitati
II.B.4.a The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:
31.28 tons per rolling 12-month period for VOCs
1.24 tons per rolling 12-month period for Ethyl Benzene
8.22 tons per rolling 12-month period for Xylenes
7.00 pounds per rolling 12-month period for MDI
100 pounds per rolling 12-month period for each HAP not listed above
9.47 tons per rolling 12-month period for total combined HAPs
[R307-401-8]
Status: In Compliance. The reported 12-month totals for the time period of August 2022,
through July 2023, are as follows:
VOC = 4.869 tons (9739.73 lbs)
Ethyl Benzene = 0.419 tons (838.19 lbs)
Xylenes = 1.38 tons (2760.54 lbs)
Methylene Diphenyl Diisocynate (MDI) = 0 tons
Other HAP not listed = 0 tons
Total combined HAPs = 0.896 tons (1793.4 lbs)
See the attached Schuff Steel Company Paint Operation HAP Emission (lbs) table
7
II.B.4.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]
Status: In Compliance. Schuff Steel uses the mass-balance method to calculate emissions
from evaporative sources.
II.B.4.a.2 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]
Status: In Compliance. This company maintains SDS as required by this condition.
II.B.4.b The owner/operator shall comply with the VOC content limit requirements as listed in R307-
350-5. [R307-350-5, R307-401-8]
Status: In Compliance. Coatings referenced by Schuff Steel indicated compliance with the
limits of R307-350-5.
II.B.5 Emergency Compressor Engine Requirement
II.B.5.a 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 63 Subpart ZZZZ, R307-401-8]
Status: Not Applicable. The emergency generators have not been used since 2018.
II.B.5.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. 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
8
C. The reason for the emergency engine usage. [R307-401-8]
Status: Not Applicable. The generators are not currently being used.
II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency compressor engine. [R307-401-8]
Status: Not Applicable. The generators are not currently being used.
II.B.5.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the
compressor engines. All diesel burned shall meet the definition of ultra-low sulfur diesel
(ULSD), and contain no more than 15 ppm sulfur. [R307-401-8]
Status: In Compliance. Diesel fuel is currently only used in off-road vehicles such as fork
lifts and small transport trucks. The Area Safety Manager stated that only #2 ULSD is
used.
II.B.5.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the
owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall
indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain
certification of sulfur content from the fuel supplier. [R307-401-8]
Status: In Compliance. The Area Safety Manager stated that only #2 ULSD is used for off
road vehicles. A fuel usage report was submitted with the other required records.
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) -XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source
Standards for Nine Metal Fabrication and Finishing Source Categories
Status: In Compliance. A Notification of Compliance Status (NOCS) according to MACT (Part 63),
XXXXXX was submitted to the DAQ on January 10, 2019. According to the NOCS, this was an existing
source since July 25, 2011. The main operations include Dry Abrasive Blasting and Welding. Dry
Abrasive Blasting are typically enclosed in unvented blast chambers or vented enclosures with a
filtration control device or objects over 8 feet in any dimension without a filtration control device. The
welding includes the use of 2,000 pounds of Metal Fabrication or finishing metal HAP (MFHAP) -
containing welding rod or welding wire annually. The Annual Certification and Compliance Report for
40 CFR 63 was submitted to the DAQ and received on February 2, 2023. The report was reviewed by
Chad Gilgen and accepted on March 20, 2023. The Schuff Steel contact signature date (see page 7) is
January 23, 2023. There were no visible emissions observed during this inspection.
MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: Not Applicable. The emergency generators have not been used since 2018.
9
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Emission Standards: Sulfur Content of Fuels [R307-203]
Status: In Compliance. The requirements of this rule are met by compliance with Conditions II.B.5.b
and II.B.5.b.1. The diesel fuel used for off-road vehicles at this site was USLD #2.
PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306]
Status: In Compliance. The requirements of this rule are met by compliance with Conditions II.B.2.a
through II.II.B.2.c. The Area Safety Manager stated that only dry enclosed blasting operations were
conducted during the 12-month period of August 2022, through July 2023. No visible emissions
exiting the enclosed blasting areas were observed during the inspection.
Nonattainment and Maintenance Areas for PM10:Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]
Status: In Compliance. The requirements of this rule are met by compliance with Conditions II.B.3.a
through II.B.3.c. Schuff Steel has a routine watering application procedure in place and a FDCP
dated September 17, 2019.
Miscellaneous Metal Parts and Products Coatings [R307-350]
Status: In Compliance. The requirements of this rule are met by compliance with Condition II.B.4.b.
EMISSION INVENTORY:
An Emission Inventory for the 2022 activity year was submitted to the DAQ and has been recorded in
SLEIS. See the attached SLEIS Summary Report.
Listed before are the Actual Emissions Inventory provided from Schuff Steel - Lindon Steel Fabrication
Facility. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN159500001-
19, dated December 4, 2019, is provided.
(PTE) are supplied for supplemental purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 19.00
Carbon Monoxide 0.11
Nitrogen Oxides 3.58
Particulate Matter - PM10 5.68
Particulate Matter - PM2.5 1.48
Sulfur Oxides 0.28
Volatile Organic Compounds 31.65
10
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Ethyl Benzene (CAS #100414) 2480
Generic HAPs (CAS #GHAPS) 700
Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 8
Xylenes (Isomers And Mixture) (CAS #1330207) 16440
PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory dated May 20, 2021 (DAQC-638-21),
for failure to maintain records of oxygen in plasma cutting
operations and abrasive media usage.
A No Further Action Letter, dated July 22, 2021 (DAQC-980-
21), was submitted to resolve the above Advisory without
penalty.
COMPLIANCE STATUS &
RECOMMENDATIONS: Schuff Steel should be considered to be in compliance with the
AO AN159500001-19 dated December 4, 2019, MACT
XXXXXX, and the applicable State Rules at the time of this
inspection.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: PPE should include steel toed boots, hard hat, and safety vest.
Inspect as usual maintaining the same targeting frequency.
NSR RECOMMENDATIONS:
ATTACHMENTS: VEO, Material Usage & Emissions, Water Logs, Calibration
Certifications, SDS sheet, and 6X Annual Certification
08/2022 - 07/2023 Aug-22 Sep-22 Oct-22 Nov-22 Dec-22 Jan-23 Feb-23 Mar-23 Apr-23 May-23 Jun-23 Jul-23
ACRYLONITRILE 0 0 0 0 0 0 0 0 0 0 0 0
BENZENE, 1,2-DIMETHYL 0 0 0 0 0 0 0 0 0 0 0 0
BENZENE, 1,3-DIMETHYL 0 0 0 0 0 0 0 0 0 0 0 0
BENZENE, 1,4-DIMETHYL 0 0 0 0 0 0 0 0 0 0 0 0
CHLORO EPOXYPR 0 0 0 0 0 0 0 0 0 0 0 0
CHROMIUM 0 0 0 0 0 0 0 0 0 0 0 0
COBALT 0 0 0 0 0 0 0 0 0 0 0 0
DIBUTYL PHTHALATE 0 0 0 0 0 0 0 0 0 0 0 0
DICHLORO-PROPN 0 0 0 0 0 0 0 0 0 0 0 0
DIMETHYL BENZENE 0 0 0 0 0 0 0 0 0 0 0 0
ETHYL BENZENE 2 9.65 0.18 0 79.14 49.17 135.09 53.68 76.02 23.46 229.82 179.98
ETHYLENE GLYCOL 0 0 0 0 0 0 0 0 0 0 0 0
GLYCOL ETHERS 0 0 0 0 0 0 0 0 0 0 0 0
LEAD 0 0 0 0 0 0 0 0 0 0 0 0
MANGANESE 0 0 0 0 0 0 0 0 0 0 0 0
MDI 0 0 0 0 0 0 0 0 0 0 0 0
METHANOL (SKIN)0 0 0 0 0 0 0 0 0 0 0 0
METHYLENE CHLORIDE 6.5 0 0 0 29.9 0 0 0 0 0 0 0
METHYL ISOBUTYL KETONE 0 17.5 0 0 172.26 9.28 315 133 182 57.4 581 455
NAPHTALENE 0 0 0 0 0 0 0 0 0 0 0 0
NICKLE 0 0 0 0 0 0 0 0 0 0 0 0
O-XYLENE 0 0 0 0 0 0 0 0 0 0 0 0
PHENOL 0 0 0 0 0 0 0 0 0 0 0 0
STYRENE 0 0 0 0 0 0 0 0 0 0 0 0
TDI 0 0 0 0 0 0 0 0 0 0 0 0
TOLUENE 0 0 0 0 0 0 0 0 0 0 0 0
XYLENE 10.5 51.05 1.61 30.51 325.57 150.15 442.98 168.04 244.47 74.16 707.46 554.04
Monthly - HAPs (lbs)19 78.2 1.79 30.51 606.87 208.6 893.07 354.72 502.49 155.02 1518.28 1189.02
6,856.53 2,595.68 2,578.05 1,812.35 2,620.84 1,430.22 1,554.69 1,595.66 1,636.15 1793.4
Schuff Steel Company
Permit AN15950001
Paint Operation HAP Emission (lbs)
12 Month Total - HAPs (lbs) - Facilitywide Emission
08/2022 - 07/2023 VOC (lbs)
Aug-22 199.84
Sep-22 272.49
Oct-22 953.53
Nov-22 30.50
Dec-22 3692.93
Jan-23 198.99
Feb-23 1174.92
Mar-23 307.23
Apr-23 437.49
May-23 134.52
Jun-23 1310.78
Jul-23 1026.51
12 Month Total (lbs) - Facilitywide Emission 9739.73
Schuff Steel Company
Permit AN15950001
Paint Operation VOC Emission (lbs)
08/2022 - 07/2023 Material Usage
Material Fueling
Type Diesel
Units (Gallons)
Aug-22 713
Sep-22 659
Oct-22 0
Nov-22 356
Dec-22 440
Jan-23 2,111.00
Feb-23 1,624.00
Mar-23 1,379.00
Apr-23 1,726.00
May-23 1,876.00
Jun-23 1,535.00
Jul-23 343
12 Month Total (Gallons) - Facilitywide Usage 12762.00
Schuff Steel Company
Permit AN15950001
Fuel Usage (Gallons)
08/2022 - 07/2023 Material Usage Material Usage 12 -
Month Total
Material
Type Blasting Media Blasting Media Blasting Media Blasting Media
Units (lbs)(lbs)(lbs)(lbs)
Aug-22 - 122,400.00 - -
Sep-22 8,000.00 130,400.00 - -
Oct-22 - 116,400.00 - -
Nov-22 - 110,400.00 - -
Dec-22 - 100,400.00 - -
Jan-23 - 99,400.00 - -
Feb-23 - 82,400.00 - -
Mar-23 - 69,600.00 - -
Apr-23 - 60,800.00 - -
May-23 - 52,000.00 - -
Jun-23 - 41,200.00 - -
Jul-23 - 8,000.00 - -
12 Month Total (lbs) - Facilitywide Usage 8,000.00
Unconfied Blasting
Schuff Steel Company
Permit AN15950001
Confined & Unconfined Blasting (lbs)
Material Usage 12 -
Month Total
Confined Blasting
Material Usage
08/2022 - 07/2023 Material Usage
Material Metal Cutting CNC 04 - Plasma Cutter Plasma Burner Table
Type Oxygen (Bulk)Oxygen Oxygen
Units (Cubic Feet)(Cubic Feet)(Cubic Feet)
Aug-22 133,700.00 936,420.00 936,420.00
Sep-22 0.00 846,420.00 846,420.00
Oct-22 122,000.00 796,770.00 796,770.00
Nov-22 270,000.00 790,230.00 790,230.00
Dec-22 285,300.00 784,260.00 784,260.00
Jan-23 296,900.00 794,730.00 794,730.00
Feb-23 202,700.00 770,940.00 770,940.00
Mar-23 557,124.00 862,117.20 862,117.20
Apr-23 317,400.00 894,337.20 894,337.20
May-23 348,800.00 870,787.20 870,787.20
Jun-23 276,600.00 924,157.20 924,157.20
Jul-23 279,400.00 83,820.00 83,820.00
12 Month Total (Cu Ft) - Facilitywide Usage 3,089,924.00
Material Usage 12 - Month Total
Schuff Steel Company
Permit AN15950001
Oxygen Usage (Cubic Feet)
Water Log 07/2022-08/2023
Water Log 07/2022-08/2023
Annual Certificatlon & Gompliance Report
For Sources Reporting Visible Emissions lnformation
National Emission Standards for Hazardous Air Pollutants:
Area Source Standards for Nine Metal Fabrication and Finiehing Source
Received
rAil s I 10?J
u0h9Eo
EDO
Facili$ (physical location) address: 325 S Geneva Rd, Lindon, UT 84042
Owner nameftitle:DBM Global
owner/company address: 3020 E. camelback Rd. suite 100, Phoenix AZ 85016
Owner telephone number:602-252-7787
Owner email address (if available):
ls the Operatorthe same person as the Ownef Yes I NoM
lf the Operator information
Operator nameftitle:
is different from the Owner, please provide the following:
Scott Esmeier, Executive VP of Fabrication
1213112A22
Operator telephone number:(602) 2s1-0341
Operator email address (if available):
Section 2 Date of Report and Reporting Period
The first annual certification and compliance report must cover the first annual reporting
period which begins the day after the compliance date and ends on December 31.
*L::HH:n#ff ffi :Iil"iil:Jil::":JJl}r',fi'lEwtp
Initiats: C C D*.,L-lo-Z3
compl iance sru*r,U.oll //H ( LDate:
Reporting Period:011o112022
Page 1 of6
i,# ltlfo
Section 3. Visible Emission and Opacity Reporting
Abrasive Blastinq Visible Emission Reportinq (63.11519 {b) (5)}
Weldins Visible Emissign Reportinq (63.11519 (bl ($l
N/A f
N/A E
212412A22
511612022
0712812022
1212012022
212412A22
511612022
712812022
121201202?
Page 2 of 6
N/AM
W,eldino Opacitv Reportinq (63.11519 (bl (61 & (8U N/A EI
Page 3 of 6
Section 4. Site.specific Welding Emissions ilanagement Plan Reporting.
If required, atkach a copy of the records of daily visual determinations of emissions
recorded in accordance with S63.11516(00)(iv), "Tier 3 requirements for opacities
exceeding 20 percent," and a copy of your Site-Specific Welding Emissions
Management PIan and any subsequent revisions to the plan pursuant to
563.11516(0(8), "Site-specffic Welding Emission Management Plan," along with your
annual certification and compliance report, according to the requirements in paragraph
63.111519(bX1).
Copy of the daily visua! emissions attached: Yes fi NoI
Page 4 of 6
section 5, changes to Facility operations since Last Report
Yes, there are changes in or additions to the processes at my facility and/or
applicable reqUirements under 40 CFR Part 63 subpart XXXXXX, National
Emission Standards for Hazardous Air Pollutants: Area Source Standards for
Nine Metal Fabrication and Finishing source categories, as follows:
Source/requirement that has changed:
How my requirements or source (s) have changed:
ls source now in compliance and if not, reason why not:
No, there have been no changes in or additions to the processes at my facility
and/or applicable requirements under 40 CFR Part 63 subpart XXXXXX, National
Emission Standards for Hazardous Air Pollutants: Area Source Standards for
Nine Metal Fabrication and Finishing Source Categories since the last report
Page 5 of 6
Section 6. Certification of Gompliance Status
n Yes, the facility referenced below !$ operating in comptiance with alt of the
relevant standards and other requirements of 40 CFR Part 63 subpart XXXXXX,
National Emission Standards for Hazardous Air Pollutants: Area Source Standards for
Nine Metal Fabrication and Finishing Source Categories
t] No, the facility referenced below is NOT operating in compliance with the
relevant standards and/or other requirements of 40 CFR Part 63 subpart XXXXXX,
National Emission Standards for Hazardous Air Pollutants: Area Source Standards for
Nine Metal Fabrication and Finishing Source Categories
Reason for noncompliance:
I hereby certifu that the information presented herein is correct to the best of my
knowledge.
t/ag /zorz
(Date)
Scott Esmeier 4t 251-0s41 _
(Signature)
(Name/title)
Page 6 of 6
(Telephone No.)
NESHAP 6X VISIBLE EMISSIONS TESTING
WELDING OPERATIONS -TIER 1- Method 22
Company Name: SchuffSteel Company
Locatlon: Llndon, Utah
Observer: Luls Roibal
Tltle: Safety Manager
NAICSISIC codes: 3441 Datei r lrLl t t
Weldlng Unlt Descrlption (indoor or outdoor):Visible Emisslon Testlng (clrcle one):
Dally Weekly Monthly ffirt.rlil
Sky Conditionsi clcvt
Precipltatlon:
Wind Directlon: 5E
Wind Speed: J
Sketch Welding Unit: lndlcate observer posltion relatlve to sourcei lndicate potential emission points
and/or actual emisslon polnts (primaryvent, stack, exlt, or opening from bulldlng which houses the
| .o',')," - ( yl ent111*,
I
I st*t*1 { r I 'v'+hhr
Itttl*l rrrvlI nit. slor, | 'Y'
I
VISIBTE EMISSIONS TESTING
Begln Observotion
Record lnltlal c'lock time:
Record total Ume of contlnuous emlsslons:
Record total tlme of mntlnuous emlsslons:
Record total time of contlnuous emlsslons:
Record total tlme of conUnuous emtsslons:
Record flnal clock tlme ("15 mln. later):
Total tlme emlsslons observed:
(lf more than 6 mln., then lrnmedlate correctlve
actlon requlred,)
End observotlon
swl sw2
Clodr Tlme lntervalTime(s)
Emlsslons Observed
{mlnutes: seconds) (mlnutes : seconds}
l': zO{t,t
,r, ,r,
-tf en o
NESHAP 6X VISIBTE EMISSIONS TESTING
BLASTING OPERATIONS -TIER 1- Method 22
Company Name: Schuff Steel Company
Location: Undon, Utah
Observer: Luls Roibal
Tltle: Safety Manager
NAlcs/slc codes: 3441 Date; z ,{.Zt
Weldlng Unlt Descrlption (lndoor or outdoor):Vislble Emlsslon Testing (circle one):
Daily Weekly Monthty Auatterlil
Sky Condltio fist clecv
Precipltatlon:
Wind Directlon: .5b
Wind Speed: 1
Slretch Welding Unit: lndlcate observer posltlon relatlve to source; lndtcate potentlal emission points
and/or actual emisslon points tprlmary vent, stack, exlt, or openlng from buildlng whlch houses the
unltl.
VISIBLE EMISSIONS TESTING
Begh Abseruatlon
51'lr1
Ctoc* Tlme
sw2
lnterual Tlme{s)
Emlsslong Observed
(mlnutes : seconds) (mlnutes: seconds)
Record inltlal clock tlme: t ?i' '{O f n
Record totaltlme of contlnuous emlsslons:
Record total tlme of contlnuous emlsslons:
iecord total tlrne of contlnuous emlsslons:
Record total tlme of continuous emlsslons:
Record flnalclocktlme (-l5 mln.later): l: Oian---
Totaltlmeemlsslonsobseryed: lfn;n - -
(lf more than 5 mln., then lmmedlate correctlve
actlon requlred.)
EN obseruatlon
s1t [1t9'on
i/,r;ll
hbtf
Y
^1
,t
NESHAP 6X VISIBLE EMISSIONS TESTING
WELDING OPERATIONS - TIER 1- Method 22
Company Name: Schuff Steel Company
Location: Undon, Utah
Observen Luis Roibal
Title: Safety Manager
NAICS/5|C codes: 3441 Date: {- tf - tQ
Welding Unlt Descrlptlon (indooror outdoor):Vislble Emisslon Testlng (circle one):
Daily Weekly Monthly E*Crtil
Sky Conditlons: cl.a'
Preclpltatlon:
Wlnd Dlrection: ta/
Wind Speedl 12
Sketch Welding Unit: lndlcate obseruer posltion relative to sourcel indlcate potintial emlsslotl points
and/or actual emlsslon points (prlmary vent, stack, exlt, or opening from bullding which houses the
unit).
$7tilgtdn
JatrTz
VIS]BLE EMISSIONS TESNN€
Segln Observotlon
sw1
Clock Tlme
sw2
'lnterualXme(s)
Emlsslons Observed
(mlnutes : seconds) (mlnutes : seconds)
Record lnltial clock tlme:
Record total tlme of continuous emlsslons:
Record total tlme of continuous emlssions:
Record total tlme of contlnuous emlsslons:
Record total tlme of contlnuous emlssions:
Record final clock tlme t-tS min, later!: I !tf o-.
-
Total tlrne emlsslons observed: t f4;n
(lf more than 6 min., then lmmedlate correctlve
actlon requlred.)
End observation
NESHAP 6X VISIBLE EMISSIONS TESTING
BLASTING OPERATIONS -TIER 1- Method 22
Company Name: Schuff Steel Company
Location: Lindon, Utah
Observer: Luls Roibal
Tltle: Safety Manager
NAICS/SIC codes:3441 Date: f- l6-LZ
Weldlng Unit Description (indoor or outdoor):Visible Ernlssion Testing (circle one):
Dally Weekly Monthly Euaftem
Sky Conditionst c/eu-
Preclpitatlon:
Wind Dlrectlon: vr
Wlnd Speed: tL
Sketch Weldlng Uni* lndlcate observer position relative to source; lndicate poGntialemtsslon polnts
andlor actual emlsslon polnts (prlmary vent, stack, exl! or opening from building whlch houses the
unit),
tt. 0l*
r
)( = Ernlshiltt
\?
VISIBIE EMISSIONS TESTING
Eegh Abservatlon
5W1
ClockTlme
sw2
lnterual Tlme(s)
Emlsslons Observed
(mlnutes : seconds) (mlnutes I seconds)
Record inltlalclocktlme: l' lott*
Record total tlme of contlnuous emlsslons:
Record total tlme of contlnuous emlssions:
Record total Ume of contlnuous emlsslons:
Record tota! tlme of continuous emisslons;
Remrd flnalclock tlme (^115 mln. later): _(t{ftn
Total tlrne emlsslons observed: I i71in
(lf more than 6 mln., then Immedlate correctlve
actlon requlred.)
End observotlon
NESHAP 6X VISIBLE EMISSIONS TESTING
WELDING OPERATIONS -TIER 1- Method 22
Company Name: Schuff SteelCompany
Locatlon: Lindon, Utah
Observer: Luls Roibal
Title: Safety Manager
NAICS/SlC codes: 3441
,J?Date: 69.tn,zz
Weldlng Unit Description {indoor or outdoor}:Vlsible Emlssion Testlng (circle one):
Daily Weekly Monthly n-.rt@
SkyCondlttons: hnry
Precipitatloni Nlt
Wlnd Directlon: ) c
Wlnd Speed: r tr
Sketch Welding Unlt: lndlcate observer posltion relatlve to source; indlcate potential emission points
and/or actual emission points (primary vent, stack, exlt, or opening from bulldlng whlch houses the
unit).
VISIBTE EMISSIONS TESTING
Begln Observatlon
sw1
ClockTlme
swz
lntervalTlme(s|
Emlsslons Observed
{rninutes : seconds} (mlnutes : seconds)
Record lnltialctock tlme: Q'Lto tn
Record total tlme of continuous emlsslons:
Record total tlme of contlnuous emlsslons:
Record total tlme of contlnuous emlsslons:
Record total Ume of condnuous ernlsslons:
Record final clock tlm6 (-15 mln, later): 1:ll u
Total time emlssions observed: l{nin
(lf more than 5 mln., then lmmedlate mrrectlve
action requlred.)
End obseruation
)<
LUA|' ?c,l
x
51ru"/w,lr
X t Ertigon
!94tt7
rtitl. 9lt
Vo6n" 7,,
t
NESHAP 6X VISIBTE EIVIISSIONS TESTING
BLASTING OPERATIONS-TIER 1- Method 22
Company Name: Schuff SteelCompany
Locatlon: Lindon, Utah
Observer; Luls Rolbal
Title: Safety Manager
NAICS/SIC codes: 3441 Date: 07- 28 . Zz
Weldlng Unlt Descrlptlon (lndoor or outdoorl:Visible Emlsslon Testlng (circle one):
Daily Weekly Monthly ffitedil
Sky Conditlons: Saty
Precipltatlon:
Wlnd Dlrectlon: 1E
Wind Speed: rp
Sketch Weldlng Unlt: lndlcate observer position relatlve to source; lndicate potential emisslon polnts
and/or actual emlsslon polnts (primary vent, stack, exlt, or opening from bulldlng whtch houses the
VISIBTE EMISSIONS TESTING
Eegln Obseruatlon
swl
ClockTlme
sun
lntervalTlme(s!
Emlsrlons Obsarved
(mlnutes : seconds) (mlnutes : seconds)
Record tnittal clock tlme: lol qo Anl
Record total tlme of contlnuous emlssions:
Record total tlme of contlnuous emlsslons:
Record totaltlme of contlnuous emlsslons:
Record total tlme of contlnuous emissions:
Record flnal clock tlme (-15 mln. later): - t CI: tipr,l
Totaltlmeemlsslonsobserved: ., t fm'q.
(lf more than 6 mln., then lmmedlatemrrectlve
actlon requlred.)
End obseruotlan
t
dotf
/
f, = E/ritelon
A/t y,,
NESHAP 6X VISIBLE EMISSIONS TESTING
WELDING OPERATIONS -TIER 1. Method 22
Company Name: Schuff Steel Company
Location: Llndon, Utah
Observer: Luis Roibal
Tltle: Safety Manager
NAICS/SlC codes: 3441 Dater l?-.t_o- Zt
Welding Unit Descrlptlon (indoor or outdoor):Visible Emlsslon TestinB (circle one):
Daily Weekly Monthly lA,*trrlil
Sky Conditlons; llor/y
Preclpltation: t lA'
Wind Dlrectlont il
Wnd Speed: t/.
Sketch Welding Unit: lndlcate observer posltion relative to source; indicate potentlal emlssion polnts
and/or actual emlssion points (prlmary vent, stack, exit, or opening from buildlng whlch houses the
I LyM roi
X
glnra/sttst/
{
tr1ia. !'q"
cooa
{) frfittbtr
fi ob"rn'
i 5on
VISIBLE EMISSIONS TESTING
Begh Abseruatlon
Record inltlal clock tlme:
Record total tlme of contlnuous emlsslons:
Record total tlme of contlnuous emlsslons:
Record total tlme of contlnuous emisslons:
Record total time of contlnuous emlssions:
Record linal clock dme (-x5 mln. later!:
Total tlme emlsslons observed:
(lf more than 6 mln., then immedlate correctlve
action requlred.)
End observatlon
sw1
ClockTlme
(minutes : seconds)
I l, gO AnI
S,W2
lntervalTlme(s)
Emlsslons Obseryed
(mlnutes : seconds)
NESHAP 6X VISIBLE EMISSIONS TESTING
BTASTING OPEMTIONS-TIER 1- Method 22
Cornpany Name: Schuff Steel Company
Location: Lindon, Utah
Observer: Luls Rolbal
Tltle: Safety Manager
NAICS/SIC codes:3441 Date: t) .roJ ?
Welding Unlt Descrlptlon (lndoor or outdoor):Vlslble Emission Testing (clrcle one):
Daily Weekly Monthly nu.nerlil
Sky Condltlo nt, CloulY
Preclpitation:
Wind Dlrectlant il
Wlnd Speedr {
Sketch Weldlng Unit: lndlcate observer positlon relatfue to sourcel lndicate potentlal emlsslon points
and/or actual emission polnts (prlmaryvent, stack, exlt, or opening from bullding whlch houses the
unltl.
Nfi,rf
r
S= En&s0n
fil 5 ,r,
VISIELE EMISSIONS TESNNG
Begln obserwtlon
Record lnltlal cloc* Ume:
Record total tlme of contlnuous emisslons:
Record total Hme of contlnuous emlsslonsr
Record total tlme of contlnuous emlssions:
Record totalttme of contlnuous emisslons:
Record ffnal clock tlme {-15 mln. later}:
Total tlme emlsslons observed:
(lf more than 6 mln., then lmmedlate conectlve
actlon requlred.)
End obseruatlon
t2:tian
tfn;a
sw1
ClockTIme
(mlnutes : secondsf
t2:0opn
sw2
lnterualfhe(s)
Embslons Observed
(mlnutes: semndsl
i uTaH DEPARTMENT OFI EUvTnoNMENTALQUALtTYt.-.-..-------
FEB 2023
I
DIVISION OFAIR OUALITY
2022 Emissions Inventory Report
Emissions Summary for Schuff Steel Company - Lindon Steel Fabrication Facility (15950)
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)0.70263 <.00001 0.70263
PM10-FIL PM10 Filterable 0.70263 <.00001 0.70263
PM25-PRI PM2.5 Primary (Filt + Cond)0.00013 <.00001 0.00013
PM25-FIL PM2.5 Filterable 0.00013 <.00001 0.00013
VOC Volatile Organic Compounds 6.90161 <.00001 6.90161
HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM?Total Emissions
(tons)*
7440473 Chromium (HAP)PM 0.00054
7440484 Cobalt (HAP)PM 0.00004
100414 Ethyl Benzene (HAP)VOC 0.08
7439965 Manganese (HAP)PM 0.031
108101 Methyl Isobutyl Ketone (HAP)VOC 0.14
75092 Methylene Chloride (HAP)-0.14
7440020 Nickel (HAP)PM 0.00027
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.32
*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2