DAQ-2024-010989

1
DAQC-CI100220001-24
Site ID 10022 (B1)

MEMORANDUM

TO: FILE – TMS INTERNATIONAL, LLC – Plymouth Slag By-Product
Processing Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: September 18, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: July 22, 2024

SOURCE LOCATION: TMS International, LLC
7285 West 21200 North, Plymouth, UT 84330

DIRECTIONS: Approximately 3 miles west of Exit 392, Plymouth, Box Elder
County, UT. TMS International, LLC is located on Nucor Steel
property and is an onsite contractor for Nucor. All visitors must
sign in at Nucor's main gate and watch a safety video. After the
video, you will be instructed on how to get to the TMS offices
located south of the Nucor facility.

SOURCE CONTACTS: Todd Marshall, Superintendent
435-458-3893

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: TMS International, LLC operates a slag screening/crushing
operation in the southeast corner of the Nucor Steel property.
Slag from Nucor Steel is dropped onto pads where it air cools to
a temperature that can be managed by the hauling equipment.
The cooled slag is loaded into a haul truck by a front-end loader
and hauled and dumped into the cooling pits where the slag is
sprayed with water to cool the slag for approximately 24 hours.
The water-cooled slag is then fed by front-end loader into a
feeder. The feeder is equipped with an overhead magnet which
removes ferrous scraps and deposits them onto a conveyor. The
scrap conveyor then deposits the scraps onto a pile to be recycled
back into the steel refinery. The material that does not stick to
the magnet is mostly slag and is conveyed to a shaker screen.
The screen separates the material according to size. The sized
material is then conveyed on three separate belts to the
appropriate piles. The larger slag material will be sold or crushed
at a later date.

2
The smaller slag material is sold to customers as aggregate, or
back to Nucor for further processing. Dust is controlled at the
facility by water sprays and water trucks.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN100220004-20, dated
September 21, 2020

SOURCE EVALUATION:
Name of Permittee: Permitted Location: TMS International, LLC Plymouth Slag By-Product Processing Plant TMS International, LLC 1155 Business Center Drive 7285 West 21200 North Horsham, PA 19044-3454 Plymouth, UT 84330 SIC Code: 3295: (Minerals & Earths, Ground or Otherwise Treated)

Section I: GENERAL PROVISIONS

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

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

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

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

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

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. The source has not been directed to submit an Emission Inventory.
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Section II: SPECIAL PROVISIONS

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

II.A.1 Slag By-Product Processing Plant

II.A.2 One (1) Horizontal Shaft Impact Crusher
Capacity: 200 tons/hour (TPH)

II.A.3 Two (2) Double Deck Screens
Size: 5' x 12' and 5' x 14'

II.A.4 One (1) Triple Deck Screen
Size: 6' x 20'

II.A.5 Portable Source
Including: Crushing and Screening Equipment, Conveying Equipment, and Diesel-Fired
Engines

II.A.6 Various Fabricated Metal Containers
Included as a VOC source; removal of paint by covering fence post hangers in hot slag

II.A.7 One (1) Vibrating Grizzly Feeder

II.A.8 Various Conveyors

II.A.9 Various Mobile Equipment
Loaders and Haul Trucks
Informational purposes only

Status: In Compliance. No unapproved equipment was observed during the
inspection.

Additional Information:
II.A.5: The portable equipment has not been on site for at least three years and
is utilized as needed.

One Reznor Model RA-235 used oil burner is installed in the machine shop.
The maximum heating range for this burner is 0.5 MMBtu/hr and only oil
from on-site sources are utilized to heat the shop in the winter.

One fully enclosed aqueous parts washer was observed in the machine shop.

II.B Requirements and Limitations

II.B.1 Slag Processing Requirements

II.B.1.a The owner/operator shall not process more than the following:

A. 400,000 tons of slag per rolling 12-month period
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B. 3,000 tons of slag per day. [R307-401-8]

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 slag processing shall be kept for all periods when the plant is in operation. Slag processing
records shall be determined by hauling records. The records of slag processing shall be kept on a
daily basis. [R307-401-8]

Status: In Compliance. The source processed 270,263 tons of slag and did not exceed the
3,000 tons of slag per day limit for the rolling 12-month period from July 2023 – June 2024.
Refer to the Plant Activity and Daily Operations Log in the attachments for more details.
II.B.1.b Visible emissions from the following emission points shall not exceed the following values: A. Crushers - 12% opacity B. Screens 7% opacity C. All Conveyor Transfer Points - 7% opacity D. All Diesel Engines - 20% opacity E. All Conveyor Drop Points - 20% opacity F. All Other Points - 20% opacity. [R307-312-4, R307-401-8]
II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

Status: In Compliance. No visible emissions from the listed emissions points were observed
during the inspection. The cooling pits are watered so slag is wet entering the screens and
crusher. Spray bars are attached and used as needed.

II.B.2 Paint Removal Process

II.B.2.a The owner/operator shall not remove paint from more than 3,000 fence post hangers per rolling
12-month period. [R307-401-8]

II.B.2.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 paint removal shall be kept for all periods when the plant is in operation. The number of fence
post hangers cleaned shall be determined by hauling records. The records of fence post hangers
shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. The source removed paint from 1,641 fence post hangers for the
rolling 12-month period. Daily records are kept and were viewed during the inspection.
Refer to the TMS Grape Stakes Log in the attachments for more details.

II.B.3 Haul Roads and Fugitive Dust Sources Requirements

II.B.3.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to
exceed 20% opacity on site and 10% at the property boundary. [R307-309-5]

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II.B.3.a.1 Visible determinations for fugitive dust emissions from haul road traffic and mobile equipment
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 1/2 vehicle length
behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5]

Status: In Compliance. No fugitive dust from haul road traffic and mobile equipment was
observed. The haul road was wet upon arrival and actively watered during the inspection.
Refer to the VEO form in the attachments for more details.

II.B.3.b The haul roads shall not exceed 0.90 miles in round trip length. [R307-401-8]

II.B.3.b.1 Compliance shall be determined through GPS measurements or aerial photographs.
[R307-401-8]

Status: In Compliance. The haul road measured 0.3 miles at the time of the inspection.
This was determined by a vehicle odometer reading taken at the time of the visit.

II.B.3.c To prevent visible emissions from exceeding the opacity limits listed in this AO, the
owner/operator shall apply water or chemical suppressant to all unpaved haul roads on site, shall
apply water to all storage piles on site, and shall apply water to all fugitive dust sources on site.
The owner/operator may stop applying water to fugitive dust sources when the temperature is
below freezing but shall apply other controls as necessary to prevent visible emissions from
exceeding the opacity limits listed in the AO. [R307-401-8]

II.B.3.c.1 Records of water and chemical suppressant application shall be kept 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 and quantity of water or chemical suppressant applied

C. Rainfall amount received, if any

D. Records of temperature, if the temperature was below freezing. [R307-309]

Status: In Compliance. Daily watering occurs and records are kept according to this
condition. Refer to the June 2024 Road Watering Log in the attachments for more details.

Section III: APPLICABLE FEDERAL REQUIREMENTS

No federal requirements apply at this time.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

6
Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No fugitive emissions or fugitive dust were observed during the inspection. A
Fugitive Dust Control Plan was submitted by TMS International, LLC on January 12, 2017. Refer to
the VEO form in the attachments for more details.

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

Status: In Compliance. The source minimizes VOC emissions during paint removal by handling the
material properly and discarding material in closed containers.

Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. The aqueous parts washer located in the machine shop is fully enclosed and
has internal drainage. Written procedures are posted and waste is properly stored and disposed. No
leaks were observed.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from TMS
International, LLC – Plymouth Slag By-Product Processing Plant on the Approval Order (AO)
DAQE-AN100220004-20, dated September 21, 2020. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 28.59
Carbon Monoxide 0.01
Nitrogen Oxides 0.25
Particulate Matter - PM10 6.06
Particulate Matter - PM2.5 6.06
Sulfur Dioxide 0.00
Volatile Organic Compounds 0.23

Hazardous Air Pollutant PTE lbs/yr
Dibutylphthalate (CAS #84742) 1800
Generic HAPs (CAS #GHAPS) 46

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN100220004-20,
dated September 21, 2020, the overall status is: In Compliance.
The source appears to be well maintained and operated. Records
were available on site and provided during the inspection.

HPV STATUS: Not Applicable.

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RECOMMENDATION FOR
NEXT INSPECTION: Hard hat, safety glasses, high visibility long sleeve clothing, and
steel toe shoes are required to tour the operation.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Plant Activity and Daily Operations Log, TMS
Grape Stakes Log, June 2024 Road Watering Log
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Page_of _
EPA METHOD 9-VISIBLE EMISSION OBSERVATION FORM
Source Name: \Af\$ :t:~roobwn \ / ~100 v\111 )!r.
Street Address: 7 ili W 2Xlen 11 :)
City/County: ~\y."ou~ J k f:.\c\u
Phone: L-\3S-4'$' -~3
Site ID: 0)7,/l,
Facility: 5\«j ~ mD)'l_) [ UY'~l~'q
Equipment/Process: G-vsJ.e.r /2l'E'tfl>
Control Equipment: !h,k,c
Emission Point: ½i\11£..
Sky Conditions: Clear [XJ Partly Cloudy [ ] Overcast [ ]
Precipitation: No ~] Yes [ ] ____ _
Wind: Direction: f% Speed: _\ O __ mph
Ambient Temp: J5t °F RH: 3[ %
Height Relative to Observer: __ _
Distance From Observer: __ _
Condensed Water Vapor Present: No [ ] Yes [ ]
Attached [ ] Detached [ ]
Length of Condensed Water Vapor Plume: _____ _
Background: _____________ _
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
0
Dnw nonh am,"
• observer
~
Sun ♦ Wind Emission Point with Plume (L]
Observer Position x
Observer's Signature:
Distrib: white-file; canary-inspe
OBSERVATION DATE: 1 f~z__/ 2:\.{ '
Start time: __ _ Stop time: __ _
~ n 0 15 30 45
1 /"""
2 /' Iv
3 v1
4 / V\._/
5 /
6
7
8
9
10
11
12
~l\i~ \2 -~ ~~\ CSvl~ loZ-3-Jv~ Zotti) COMMENTS:
11 ,P>.\ o-', _:of\~ "~ ~ IC\~ r<c ro11 ,,~ \Z -koci',1>: ✓
\o~ o~ Sln~ j>tr ~, ~/
✓Jr ,6, ?,,, C\ '. 'Toki [\t Jrt'½tc a~ k;Ne p:5J bao9es: Wi ~
(~~A ?9;" 1-✓-n-· ~. =>, b • · H•'v l &,,,d lrn?¼
/-n-· &. 2 ·0-l ~ ¾ ~ ·±rt4,w,4 CT wrrl S
SIGNATURE:
Printed Name: T J~ t{1 N$¼ ¼
Plant Activity
Nucor/Plymouth, TMS International, LLC Site #008201
Per Condition 8, Air Penn It DAQE-AN100220004-20
Limits: 400,000 tons/12 months running; 3,000 tons/day
Plant Throuahout Ooeratlna Hours Rate of Throuahout
Runnina Runnina Runnina
For Month 12 Month For Month 12 Month For Month 12 Month
Sum Sum Averaae
tons tons hours hours tons/hour tons/hour
Jan-20 24,815 264,688 189 2,077 131 127
Feb-20 18,963 268,599 185 2,156 103 125
Mar-20 27,029 270,443 205 2,205 132 123
Apr-20 16,148 259,143 149 2,163 108 120
May-20 14,846 247,584 122 2,077 122 119
Jun-20 15,228 234,458 149 2,021 102 116
Jan-22 21,285 237,938 155 2,018 137 118
Feb-22 27,693 247.712 167 1,985 166 125
Mar-22 25,397 255,020 154 1,965 165 130
Apr-22 39,392 269,943 228 1,999 173 135
May-22 35,650 285,986 209 2,091 171 137
Jun-22 39,811 306,257 236 2,148 169 143
Jul-22 31,557 312,999 190 2,148 166 146
Aug-22 28,947 322,983 202 2,165 143 149
Sep-22 0 295,954 0 1,999 0 148
Oct-22 1,039 280,845 31 1,842 34 152
Nov-22 29.779 295,778 222 1,942 134 152
Dec-22 29,954 310,504 225 2,017 133 154
Jan-23 19,121 308,340 155 2,017 124 153
Feb-23 17,159 297,806 151 2,001 113 149
Mar-23 22,439 294,848 175 1,999 128 147
Apr-23 43,539 298,995 300 2,094 145 143
May-23 30,533 293,878 235 2,120 130 139
Jun-23 29,666 283,733 217 2,101 137 135
Jul-23 35,285 287,461 156 2,067 226 139
AUQ-23 35,868 294,382 130 1,995 277 148
Sep-23 25,943 320,326 190 1,999 136 160
Oct-23 23,905 343,192 149 2,304 160 149
Nov-23 23,379 336.792 160 2,242 146 150
Dec-23 19,285 326,123 118 2,135 164 153
Jan-24 15,544 322,546 143 2,124 109 152
Feb-24 19,941 325,329 169 2,141 118 152
Mar-24 23,658 326,547 170 1,999 139 163
Apr-24 19,423 302,431 151 1,987 129 152
May-24 13,336 285,234 95 1,847 140 154
Jun-24 14,695 270,263 115 1,746 128 155
Nucor PlymotAh Rl.nnng Sun Plant Activ,ty ma'ch 202◄
A 8 D J p
1
2 Dltlt Tone Tona Tone Tone Toal Tona TPl4 Drlilfll T-
3 1.Jun 5 ~02 IIDIV/01 0
4 2.Jun #OIV/01 0
5 s.Jun 12.4 u 5.5 5"1.53 0 I 21.12
8 "-'w1 1.7 8.2 u 802.11 7 111.79
7 ""1n 10.8 u 1 1009.117 0 e 29.211
a I.Jun Z2.l5 u 13.25 1425.32 0 9 4U4
9 7.Jun 5 23e0.4 0
10 Wun 8.75 u 2.25 1077.24 0
11 Wun IIOIV/01
12 1G-Jun 10.4 3.4 7 308.12 #DIV/01 0 1411.5
13 11 #DIV/01 0 2 37.79
14 12.Jun 20.56 14.1 9.25 1795.92 #DIV/01 0 4 IS.45
15 1S.Jun 10.45 11.2 1.25 1eou1 #OIV/01 0 4 ee.18
16 14.Jun 20 18 1 2723.2 #DIV/01 0 3 58.45
17 11.Jun IIDIV/01 0
18 1Wun IIDIV/01 0
19 17.Jun 10.2 5.2 5 471..23 IIDIV/01 0 4 911.113
20 11.Jun IIDIV/01 0
#DIV/01
IIOIV/01 0
#DIV/01 0
#OIV/01 0
#DIV/01 0
IIDIV/01 0
#DIV/01 0
V/01 0
#DIV/01 0
#DIV/01 0
31 a.Jun IIDIV/01 0
32 3G-Jun #DIV/01 0
0
0 44.00 ---
TIIS Grape Stakes Returned to Nucor
Nucor1PlymouthSlte
Grape Stake Hangers
Return
Januarv-22 287
Feoruary-22 198
Marth-22 132
Ap,11-22 264
May-22 198
J\.ne-22 2<43
Jliv-22 286
Auousl-22 176
Septembef-22 198
Odobel'-22 132
Nowmbef-22 68
Decembef-22 110
2022 Total 2312
Januarv-23 176
Februaf'V-23 68
March-23 1<41
IADnl-23 111
May-23 176
Juoe-23 176
Jutv-23 132
Auoust-23 110
Seotember-23 21
October-23 219
Novembef-23 131
December~23 85
2023 Total 1566
January-2.C 1<47
Februarv-2.C 159
Marth--2.C 87
Aonl-2.C 264
Mav-2.C 196
Jtrie-2.c 68
Auoust-2.C
r -2,4
Oct.ober-2.C
NoYemtlef-2.C
Decemtlef-2-4
202.C YTD 9-43
Davs Retuned & Quanlitv
Jan 12. 13, 1.C, 17. 18, 19. 20, 21. 25, 26 Returned 22; Jan 11 Returned 23 & Jan 31 Returned«
Feb 2, 9, 1.C, 15, 18, 21, 23, 25, Returned 22
march 1. 13 23 31, returned 22 march 10 returned«
APril .C,5,6,7,8, 11,12,15,27.28.29 returned 22
May 3,.C,6, 12, 16,2.C,25,28,27 returned 22 5/31/22 returned«
June 2.3,7,10,U,15,27.28.29,30, returned 22 oer day retumed 23 on 6/8/22
uly 1,7, 12,13. 19,25,28,retumed 22 per day iuly 6,21 retumed « Iulv 15 retum 23 iuly 1.C return 21
Auoust 16, 17, 19, 22, 23, 25, 26, 31, returned 22
Seotember 1, 2, 7, 8, 9, 12, 13, 26, 30, retumed 22
October 5.10.13.31, returned 22 october 17, returned«
November 3. 15, 21. 28. Retumed 22
December 2. 16, 20. 28, 30. returned 22 oer day
January 3 . .c. 5, 10. 18. 23. 25. 31 returned 22 oer dav
Februarv 3. 6. 15. 20, returned 22 oer day
march 6. 17. 27, 28 rel. 22: march 3. ret. 2.C march 7 ret. 18 march 8 rel. 11
IAoril 3 ret 46. 10 ret 21. 17, 27 ret 22
May .c, 22 returned«; May 8, 19. 26. 30 returned 22
June 5.8.1.C.19.21.23 returned 22 June 20 returned 10. June 26, retumed 3.iC
July 5.10.12, returned 22 July U returned 66
!August 2.7,23.2.C.28 returned 22
September 5, returned 21
10/.C,5.9.11.12.18.20.23 returned 22 10/16 returned 21
11/2, 9, 15. 20, 27 returned 22: 11/30 returned 21
12/7, 12/26, returned 22, 12/11 returned 20, 12/21 returned 21
1/8, 1/10, 1/12. 1/16. 1/19, 1/22. 1/29. Returned 21
2/115: 2/2 1.C: 2/5 16; 2/6 8; 2/9 22; 2/1.C, 2/16, 2/21, 2/29, 21 returned
3/11 returned 21. 3/.C, 3/21. 3/26 returned 22
Aoril .C.5.6.7,8, 11, 12.15.27.2829 returned 22
Mav 1, 2. 7, 8. 9. 12. 13. 26. 30, returned 22
3, 15, 21. 28. Returned 22
Road Watering Log for Environmental Compliance
TMS International Plymouth, Utah Mth/Yr:
# #
Date Weather Moisture Watered Apprx. Inches Gallons of Loads of Loads
Condition of Precipitation Roads Plies
1 C D y 0 104000 16
2 C D y 0 72000
3 0 w N 0.21
4 0 w N 0.12
5 C D y 0 68000 9
6 C D y 0 68000 8
7 C D y 0 92000 13
8 C D y 0 104000 17
9 C D y 0 48000 12
10 C D y 0.03 48000 8
11 C D y 0 64000 10
12 C D y 0 80000 15
13 0 w y 0.27 28000 5
14 C D y 0 28000 7
15 C D y 0 56000 9
16 C D y 0 48000 8
17 C D y 0 40000 7
18 C D y 0 56000 10
19 C D y 0.01 64000 10
20 C D y 0.08 32000 4
21 0 w N 0.53
22 0 w N 0.4
23 C D N 0
24 C D N 0
25 C D y 0 24000 3
26 C D y 0 64000 10
27 C D y 0 68000 10
28 C D y 0 48000 6
29 0 D y 0 64000 10
30 0 D y 0 28000 5
31
Weather: C = Clear, 0 = Overcast, R = Rainy, S = Snow, F = Freezing
Moisture: W = Wet, D = Dry
1 Load = 4000 Gallons
10
16
8
9
10
9
4
6
5
2
5
4
3
4
6
4
3
6
7
6
6
2
2
June 2024
Time of Day
6am-8pm
11am-8pm
10am-8pm
7am-730pm
8am-830pm
6am-8pm
830am-4pm
3am-12pm
12pm-8pm
9am-8pm
10am-4pm
11am-5pm
945am-545pm
930am-330pm
10am-530pm
10am-7pm
10am-6pm
1045am-6pm
9am-430pm
11am-7pm
10am-7pm
10am-7pm
9am-630pm
1030am-230pm
Person
making entrv
NN
0