DAQ-2024-011813

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DAQC-CI125380001-24
Site ID 12538 (B1)

MEMORANDUM

TO: FILE – LIBERTY SAFE AND SECURITY PRODUCTS, INC. – Payson
Manufacturing Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: November 4, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: May 1, 2024

SOURCE LOCATION: 1199 West Utah Avenue
Payson, UT 84651
SOURCE CONTACTS: Jesse Enciso, Safety
[e-mail]

OPERATING STATUS: Operating normally at the time of inspection

PROCESS DESCRIPTION: This source manufactures metal gun safes. The safes are cut,
formed, and folded from rolled coil steel and welded together in
the metal shop. After forming and welding, the safes are placed
on a metal prep line for grinding and sanding. The safe is then
conveyed through a 5-stage washer to be cleaned. After exiting
the washer, the safes are oven dried before entering into either
one of two powder coating booths or one of two wet coating
booths, for surface coating.

Some safes are painted with a primer, baked, sanded, top coated
with liquid paint, and baked while others are painted directly
with a powder color. Each powder booth is vented to a cartridge
filtering system that recirculates filtered exhaust air back into the
building. There are no VOCs present in the powder coating
process. Powder coated safes are conveyed to a curing oven and
allowed to cure at about 325°F to 375°F. Safes painted with a
powder color are conveyed into the final assembly area to be
finished.

The safes that have been painted with a primer are conveyed to a
sanding booth. After sanding, they receive a final coat of
automotive quality wet paint. They are then hand-sprayed with a
coat of glossy paint in one of several colors. The wet painted
safes are then conveyed through a drying oven heated at about
160°F to 180°F and allowed to air-dry.

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Paint overspray and VOC emissions are pulled through each
booth's bank of paint particulate filters. All of the paint booths
are equipped with 25 paint arrestor filters 20"x 20" in dimension.
Not all of the paint booths are in continuous use. Some are used
for experimental design rather than full production. Each booth's
filter bank has an area of approximately 69.5 square feet. The
overspray is collected on the filters. The VOCs pass through the
filters and are vented through each booth's 24" equivalent
diameter exhaust stack. The filters in all of the wet paint booths
are changed out once every one to two weeks depending on the
number of safes sprayed in each particular booth.

Once into final assembly, the powder coated safes and wet
painted safes are lined on the inside with sheet rock for fire
proofing and the locking mechanisms are attached to each safe.
The safes are then wrapped in foam and boxed in cardboard for
shipment. The entire fabrication, painting, and assembly process
is all completed during the same day.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN125380008-19 dated March 11,
2019:
MACT (Part 63) -A: General Provisions,
MACT (Part 63) -XXXXXX: National Emission Standards for
Hazardous Air Pollutants Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories,

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Liberty Safe and Security Products, Inc. - Payson
Manufacturing Plant

1199 West Utah Avenue 1199 West Utah Avenue
Payson, UT 84651 Payson, UT 84651

SIC Code: 3499: (Fabricated Metal Products, 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]
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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]
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: Out of Compliance. The source exceeded their limits for styrene emitted within a 12-month period. The source submitted a self-report notification of non-compliance for the styrene exceedance on April 8, 2024. Since the source followed the rules established in Section 109 of the Utah Environmental Self-Evaluation Act for self-reporting non-compliance, the styrene exceedance is not considered a compliance issue. The source has not had any breakdowns in equipment and submitted their 2023 Emission Inventory by the April 15, 2024, deadline. The 2022 Emission Inventory is attached and listed below. The new equipment (II.A.43 and II.A.44) was observed to be in operation at the time of inspection. No notification that the equipment was installed or operational has been made. The source is currently going through an AO modification to add a sheet rock shredder and compliance assistance was provided to ensure that notification is made once that equipment is installed and operational. No further action is currently required.

Section II: SPECIAL PROVISIONS

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

II.A.1 Manufacturing Plant
Safe and Security Products

II.A.2 Paint Booth A
Equipment ID: WPB-A#1
Emission Point ID: WPB-A#1
System: High End Wet Coat

II.A.3 Paint Booth B
Equipment ID: WPB-B#1
Emission Point ID: WPB-B#1 System: High End Wet Coat

II.A.4 Paint Booth C Equipment ID: WPB-C#1
Emission Point ID: WPB-C#1
System: High End Wet Coat
II.A.5 Paint Booth D
Equipment ID: WPB-D#1 Emission Point ID: WPB-D#1
System: High End Wet Coat

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II.A.6 Paint Booth E Equipment ID: WPB-E#1 Emission Point ID: WPB-E#1 System: High End Wet Coat
II.A.7 Paint Booth F Equipment ID: WPB-F#1 Emission Point ID: WPB-F#1 System: High End Wet Coat
II.A.8 Paint Booth G Equipment ID: WPB-G#1 Emission Point ID: WPB-G#1 System: High End Wet Coat
II.A.9 Paint Booth H Equipment ID: WCTUB#1 Emission Point ID: WCTUB#1 System: High End Wet Coat
II.A.10 Powder Coating Booth Equipment ID: PB#1 Emission Point ID: Discharges to PCS#1 System: CN Line
II.A.11 Powder Coating Dust Collector and Cyclone Sep. Equipment ID: PCS#1 Emission Point ID: PDC#1 System: CN Line *Noted for informational purposes only as this system discharges inside the building.
II.A.12 Secondary Powder Coat Dust Collector and Baghouse Equipment ID: PDC#1 Emission Point ID: Discharge into Building System: CN Line *Noted for informational purposes only.
II.A.13 Powder Coating Booth A#2 Equipment ID: PB-A#2 Emission Point ID: PCS-A#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.14 Powder Coating Dust Collector and Cyclone Sep. A#2 Equipment ID: PCS-A#2 Emission Point ID: PDC-A#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.15 Secondary Pwdr Coating Dust Collector, Cyclone A#2 Equipment ID: PDC-A#2 Emission Point ID: Discharge into Building System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.16 Powder Coating Booth B#2 Equipment ID: PB-B#2 Emission Point ID: PCS-B#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
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II.A.17 Powder Coating Dust Collector and Cyclone Sep B#2 Equipment ID: PCS-B#2 Emission Point ID: PDC-B#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.18 Secondary Pwdr Coat Dust Collector, Baghouse B#2 Equipment ID: PDC-B#2 Emission Point ID: Discharge into Building System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.19 Wood Cutting System with Dust Collector Equipment ID: RWDC#1 Emission Point ID: RWDC#1 System: CN Line
II.A.20 Cure Oven #1 with Burner Equipment ID: WCOB#1 Emission Point ID: WCOE#1 A,B, & C Maximum Burner Rating: 3.0 MMBTU/hr System: High End Wet Coat Fuel Type: Natural Gas
II.A.21 Cure Oven #2 with Burner Equipment ID: WCOB#2 Emission Point ID: WCOE#2 A,B, & C Maximum Burner Rating: 3.0 MMBTU/hr System: High End Wet Coat Fuel Type: Natural Gas
II.A.22 Sanding Booth #1 Equipment ID: WSB#1 Equipment ID: WSBE#1 A,B, & C Control Equipment: Dust Control Filters System: High End Wet Coat
II.A.23 Sanding Booth #2 Equipment ID: WCOB#2 Emission Point ID: WCOE#2 A,B, & C Control Equipment: Dust Control Filters System: High End Wet Coat
II.A.24 Paint Kitchen #1 Small container for paint drum storage Equipment ID: PKE#1 Emission Point ID: PKE#1 System: High End Wet Coat
II.A.25 Metal Water Wash System with Boiler Equipment ID: WSB#1 Emission Point ID: WSE-A#1 and WSE-B#1 System: CN Line One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr Fuel Type: Natural Gas

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II.A.26 Dry-Off/Cure Combo Oven with Burners Equipment ID: PCOB#1 Emission Point ID: PCOE#1 System: CN Line Maximum Equipment Rating: 4.0 MMBTU/hr Fuel Type: Natural Gas
II.A.27 Metal Water Wash System with Boiler Equipment ID: WSB#2 Emission Point ID: WSE-A#2 and WSE-B#2 System: High Volume Powder Coat One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr Fuel Type: Natural Gas
II.A.28 Dry-Off/Cure Combo Oven with Burners Equipment ID: PDOB#2 Emission Point ID: PCOE-A#2 and PCOE-B#2 System: High Volume Metal Shop Maximum Equipment Rating: 7.6 MMBTU/hr (Includes 2 - 2.4 MMBTU/hr and 1 - 2.8 MMBTU/hr burners) Fuel Type: Natural Gas
II.A.29 Burn-Off Oven with Burners Equipment ID: BOO#1 Emission Point ID: BOO#1 System: High Volume Powder Coat Equipment: Two (2) Burners Maximum Equipment Rating: 0.48 MMBTU/hr (each) Fuel Type: Natural Gas
II.A.30 Comfort Heaters Various natural gas fueled comfort heating devices rated less than 5 MMBtu/hr - each Listed for information purposes only.
II.A.31 Baghouse #1 Equipment ID: WJDC-#1 Emission Point ID: Discharges into Building Equipment Location: Water Jet Room System *Noted for informational purposes only.
II.A.32 Water Jet Cutter A Equipment ID: WJC-A Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1
II.A.33 Water Jet Cutter B Equipment ID: WJC-B Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1
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II.A.34 Two (2) Robotic Welders and Hoods Equipment ID: WDC#1 Emission Point ID: Discharges into Building System: CN Line *Noted for informational purposes only.
II.A.35 Robotic Welder with Smoke/Dust Collector A Equipment ID: WDC-A Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.36 Robotic Welder with Smoke/Dust Collector B Equipment ID: WDC-B Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.37 Dack Square Tack Welder with Smoke/Dust Collect C Equipment ID: WDC-C Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.38 Face Corner Welder with Smoke/Dust Collector D Equipment ID: WDC-D Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.39 Door Build Welder with Smoke/Dust Collector E Equipment ID: WDC-E Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.40 Door Build Welder with Smoke/Dust Collector F Equipment ID: WDC-F Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.41 Grinders Equipment ID: PGA#1 Emission Point ID: Discharges into Building System: CN Line *Noted for informational purposes only.
II.A.42 Infrared Pre-Cure Oven Equipment ID: IPCO#1 Emission Point ID: Discharges to Building System: High Volume Powder Coat *Noted for informational purposes only as unit uses infrared heating.

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II.A.43 Spray/Bake Combo Oven with Burner (New Equipment) Equipment ID: VDP-A Emission Point ID: VDP-A#1 System: Vault Door Line Control Equipment: Dust Control Filters One(1) Burner Maximum Equipment Rating: 1.44 MMBtu/hr Fuel Type: Natural Gas
II.A.44 Sanding Booth (New Equipment) Equipment ID: VDS-A System: Vault Door Line *Noted for informational purposes only as this system discharges inside the building.
Status: In Compliance. No unapproved equipment was observed at the time of inspection. A sheet rock shredder was not installed or operational but was observed at the time of inspection. Liberty Safe inquired with NSR about filing an NOI to receive a new AO in order to operate the new sheet rock shredder and received information that they will need to receive a new AO in order to operate that equipment. Additional information from previous inspections that applies to this inspection: II.A.8- Paint Booth G is not currently used and is part of the old powder coating system. II.A.9- Paint Booth H is a primer booth II.A.10- Powder Coating Booth - the dust collector is inside the building II.A.19- Wood Cutting System with Dust Collector is controlled by a Donaldson Torit dust collector that vents internally. II.A.20&21- Cure Oven #1, #2 vent outside II.A.23- Sanding booth #2 - not currently in use II.A.26- Dry-Off/Cure Combo Oven with Burners is part of the Metal Water Wash System of II.A.25 II.A.27- Metal Water Wash System with Boiler - boiler is a Rite-brand Boiler rated 5 MMBtu/hr II.A.29- Burn-Off Oven with Burners - is equipped with a primary burner and an afterburner. II.A.31- Baghouse #1 - is a pulse jet baghouse. II.A.34- Two (2) Robotic Welders and Hoods - vent into a dust collector before being discharged back into the building. II.A.37- Dack Square Tack Welder with Smoke/Dust Collect C - should be Back Square Tack Welder with Smoke/Dust Collector C. All hand welding and grinding operations are controlled by vacuum dust collection systems that vent internally. Source also operated two parts washers that utilize Safety-Kleen Armakleen 4 in 1 cleaning solution. Both appeared to be in compliance at the time of inspection.

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II.B Requirements and Limitations

II.B.1 The Safe Manufacturing Plant shall be subject to the following limitations:

II.B.1.a Visible emissions from the following emission points shall not exceed the following values:

A. Paint spray booth exhaust stacks - 10% opacity
B. Powder coating booth exhaust stacks - 10% opacity
C. Sanding booth exhaust stacks - 10% opacity
D. Boiler and natural gas fired burner exhaust stacks - 10% opacity
E. All other points - 20% opacity. [R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No visible emissions were observed at the time of inspection. See the
attached VEO form for additional information.
II.B.1.b The emissions from all coating, painting, and other non-combustion processes shall not exceed:
33.70 tons per rolling 12-month period for VOCs
4.29 tons per rolling 12-month period for Xylene
4.01 tons per rolling 12-month period for Methyl Isobutyl Ketone 3.47 tons per rolling 12-month period for Toluene
1.85 tons per rolling 12-month period for Naphthalene
1.00 tons per rolling 12-month period for Ethyl Benzene 0.12 tons per rolling 12-month period for Styrene
0.07 tons per rolling 12-month period for Methanol
14.82 tons per rolling 12-month period for all combined HAPs. [R307-401-8]
II.B.1.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
first day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Monthly calculations shall be made no later than 20 days after the end of each calendar
month. [R307-401-8]
II.B.1.b.2 The VOCs or HAPs emissions shall be determined by maintaining a record of VOC- or HAP-
emitting materials used each month. The record shall include the following data for each material
used:
A. Name of the VOC- or HAP-emitting material, such as: paint, adhesive, solvent, thinner,
reducers, chemical compounds, toxics, isocyanates, etc.
B. Density of each material used (pounds per gallon)
C. Percent by weight of all VOCs or HAPs in each material used

D. Gallons of each VOC- or HAP-emitting material used
E. The amount of VOCs or HAPs emitted monthly by each material used shall be calculated by the following procedure:
VOC = % VOC by Weight/100 x [Density ( lb/gal )] x Gal Consumed x 1 ton/2000 lb HAP = % HAP by Weight/100 x [Density ( lb/gal )] x Gal Consumed x 1 ton/2000 lb
F. The amount of VOCs or HAPs emitted monthly from all materials used
G. The amount of VOCs, or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC, or HAP emissions
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H. VOC or HAP emissions from the fuel burning devices (products of incomplete combustion generated by the comfort heating devices) are NOT included in the above total. [R307-401-8] Status: In Compliance. The rolling 12-month totals from May 2023 to April 2024, for VOC and HAPs emitted are as follows: 8.23 tons of VOCs 1.17 tons of total HAPs 0.41 tons of xylene 0.04 tons of ethylbenzene 0.00 tons of toluene 0.00 tons of methyl isobutyl ketone 0.00 tons of naphthalene 0.72 tons of styrene 0.00 tons of methanol The source exceeded their allowance for styrene within a rolling 12-month period. The source filed a self-report of non-compliance of the styrene exceedance and according to the rules established within Section 109 of the Utah Environmental Self-Evaluation Act, the source followed all procedures required. Since this was accepted, this does not make the source out of compliance with this AO condition. See the attachments section for a copy of the non-compliance statement, as well as the calculations for the rolling 12-month totals. II.B.1.c All exhaust air from all spray booths and powder coating booths shall pass through particulate filters, installed in each booth, prior to being discharged to the atmosphere. [R307-401-8] II.B.1.c.1 All spray booths and powder coating booths shall be equipped with a manometer or magnehelic pressure gauge to measure the pressure differential across the particulate filters. The pressure gauge shall be located such that an inspector/operator can safely read the output at any time. The particulate filters shall be replaced when the pressure differential exceeds manufacturer's recommended operating ranges. Pressure drop readings shall be recorded weekly for each spray and powder coating booth. Records shall include booth identification, weekly pressure drop readings, and date of particulate filter replacement. [R307-401-8] Status: In Compliance. Each spray paint and powder booth is equipped with a magnahelic gauge. Readings are recorded weekly and are operated according to the manufacturer's specifications. See the attachments section for additional information. II.B.1.d All paint and solvent drums or containers shall be closed/sealed while not in use in Paint Kitchen #1. Additionally, only two drums shall be open at any one time in Paint Kitchen #1. [R307-401-8] Status: In Compliance. All paint and solvent drums were closed when not in use in Kitchen #1. The number of open drums in use did not exceed two at the time of inspection. II.B.1.e The following equipment and their associated collection/emission points shall be vented or routed back into the safe manufacturing building: 1) Water Jet Cutter A - WJC-A; 2) Water Jet Cutter B - WJC-B; 3) Baghouse #1 - WJDC-#1; 4) Robotic Welders and Hoods - WDC#1; 5) Robotic Welder with Smoke/Dust Collector A - WDC-A; 6) Robotic Welder with Smoke/Dust Collector B - WDC-B;
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7) Dack Square Tack Welder with Smoke/Dust Collector C - WDC-C; 8) Face Corner Welder with Smoke/Dust Collector D - WDC-D; 9) Door Build Welder with Smoke/Dust Collector E - WDC-E; 10) Door Build Welder with Smoke/Dust Collector F - WDC-F; 11) Powder Coating Booth PB#1, Dust Collector and Cyclone Separator - PCS#1, Secondary Powder Coat Dust Collector and Baghouse - PDC#1; 12 Powder Coating Booth - A#2, Powder Coating Dust Collector and Cyclone Separator - A#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-A#2; 13) Powder Coating Booth - B#2, Powder Coating Dust Collector and Cyclone Separator - B#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-B#2. 14) Grinders - CN Line - PGA#1; 15) Infrared Pre-Cure Oven - High Volume Powder Coat - IPCO #1 16) Sanding Booth - Vault Door Line - VDS-A. [R307-401] Status: In Compliance. All the equipment listed is vented or routed back into the building. II.B.2 Fuel Combustion Requirements II.B.2.a The owner/operator shall only use natural gas as fuel in all on-site equipment. [R307-401-8] Status: In Compliance. Only natural gas is used onsite. II.B.2.b The following consumption limit shall not be exceeded: 239,823 decatherms of natural gas consumed per rolling 12-month period. [R307-401-8] II.B.2.b.1 Based on the first day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Monthly calculations shall be made no later than 20 days after the end of each calendar month. Records of fuel consumption shall be kept for all periods when the plant is in operation. Fuel consumption shall be determined by examination of fuel supplier billing records. The records of fuel consumption shall be kept on a monthly basis. [R307-401-8] Status: In Compliance. The rolling 12-month total from May 2023 to April 2024, for natural gas consumption is as follows: 53,774 decatherms of natural gas consumed Rolling total is calculated by the 20th of each month. See the attachments section for additional information.

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Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

MACT (Part 63) -A: General Provisions

Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable
subparts.
MACT (Part 63) -XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source
Standards for Nine Metal Fabrication and Finishing Source Categories

Status: Out of Compliance. Subpart XXXXXX is applicable under §63.11514(a) as the source SIC code
is 3499 – Fabricated Metal Products. Subpart XXXXXX applies to the welding operations at the source
location as follows: • §63.11516(f) Standards for Welding due to using more than 2,000 lbs. of welding
rod and wire containing Metal Fabrication Hazardous Air Pollutants (MFHAPs) per calendar year. The
source needs to submit annual notifications of compliance status. No other requirements of the rule are
currently applicable as all welding emissions are controlled by vacuum dust/fume collection systems that
vent internally. Source did not file their XXXXXX notification at the appropriate timeframe for the
2023 reporting year. Source submitted it in May and was reminded to submit for each year by January
31. No further action is recommended. In compliance with the rest of the requirements of XXXXXX.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: Out of Compliance. Compliance with R307-214 is determined by compliance with applicable
federal subparts. Subpart XXXXXX applies to this rule. See Section III for additional information.

Solvent Cleaning [R307-304]

Status: Not applicable. Source is exempt from this rule as they are subject to R307-350. Solvent
cleaning for this source is addressed by R307-350-7(2).
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. All VOC containers were closed at the time of inspection when not in use and
the source followed rules listed within the AO in regard to Paint Kitchen #1. See II.B.1.d for
additional information.

Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. There is a parts cleaner that is utilized onsite. During the inspection, the lid of
the parts cleaner was closed. All solvent waste is properly disposed of.
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Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. The source still utilizes Cardinal paint products for their operations. The
source changed their paint products, which led to an exceedance of styrene in their rolling 12-month
totals for emission. The source self-reported the exceedance according to Section 109 of the Utah
Environmental Self-Evaluation Act and followed the procedures listed in the rule, making this not a
compliance issue. The source has switched back to the products that were listed in the 2022
inspection. See the attachments section for information about the self-report.

EMISSION INVENTORY:

Listed below are the Actual Emissions Inventory provided from Liberty Safe and Security Products, Inc. -
Payson Manufacturing Plant. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN125380008-19 dated March 11, 2019, is provided. The 2022 Emission Inventory is listed and
attached below. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 16426.36
Carbon Monoxide 4.73 1.14
Nitrogen Oxides 10.47 2.69
Particulate Matter - PM10 1.01 0.21
Particulate Matter - PM2.5 1.01 0.20
Sulfur Oxides 0.11 0.01
Volatile Organic Compounds 33.70 7.12

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Ethyl Benzene (CAS #100414) 2020 0.00
Generic HAPs (CAS #GHAPS) 2140
Methanol (CAS #67561) 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 8028
Naphthalene (CAS #91203) 3700
Styrene (CAS #100425) 241
Toluene (CAS #108883) 6940
Xylenes (Isomers And Mixture) (CAS #1330207) 8580 22.0

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN125380008-19
dated March 11, 2019: Out of compliance with reporting
requirements of Subpart XXXXXX by not filing the annual
compliance statement within the appropriate timeframe.
Statement was submitted on May 7, 2024. No further action is
currently recommended. Source self-reported emissions of
styrene exceeding the permitted limits and issued a statement to
the DAQ stating this self-report, following the rules established
for self-reporting violations of non-compliance. In compliance
with the conditions listed in the AO. Source is also out of
compliance with condition I.8 by not submitting notification that
the new equipment on this AO is operational. No further action
is currently recommended. Facility is well maintained, and
records were provided within a timely manner.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Source is planning to update their AO to include a new sheet
rock shredder. Check to see the status of the NOI or new AO and
inspect after that is completed.

NSR RECOMMENDATIONS: Update the equipment list. See status of Section II.A for specific
equipment information.

Include 40 CFR 63 Subpart XXXXXX under Section III -
Applicable Federal Requirements

Include a condition referencing applicability of R307-350

Evaluate the two parts washers for inclusion in the equipment
list.

ATTACHMENTS: Applicable Supporting Documentation Included
2022 Emissions Inventory Report
Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant (12538)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)0.21417 <.00001 0.21417
PM10-FIL PM10 Filterable 0.07077 <.00001 0.07077
PM25-PRI PM2.5 Primary (Filt + Cond)0.20606 <.00001 0.20606
PM25-FIL PM2.5 Filterable 0.04777 <.00001 0.04777
PM-CON PM Condensible 0.1433 <.00001 0.1433
SO2 Sulfur Dioxide 0.01718 <.00001 0.01718
NOX Nitrogen Oxides 2.69216 <.00001 2.69216
VOC Volatile Organic Compounds 7.12327 <.00001 7.12327
CO Carbon Monoxide 1.1456 <.00001 1.1456
7439921 Lead <.00001 <.00001 <.00001
NH3 Ammonia 0.00401 <.00001 0.00401

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
100414 Ethyl Benzene (HAP)VOC 0.0034
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.01701

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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Jordan Garahana <[e-mail]>
Info Requested from 5/1/24 visit
2 messages
Jesse Enciso <[e-mail]>Wed, May 8, 2024 at 1:31 PM
To: "[e-mail]" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Good Aernoon Jordan,
Here is the info requested from your visit, if you need anything else, please let me know. The Subpart xxxxxx
do I need to send anywhere else besides you and also, we are looking into geng the permit for our sheet
rock shredder since it does require one.
Thank You,
Jesse Enciso
9 attachments
Gas Usage from march 2023-April 2024.docx
14K
May 23 through Apr 24 Emissions.pdf
190K
Bulk Kleen 842LF.pdf
1430K
E-CLPS 1700RA.pdf
1227K
Manometer Reading March-June 2023.pdf
5808K
July-September 2023.pdf
4246K
October 2023-January 2024.pdf
5425K
February-April 2024.pdf
3991K
40 CFR 63 Subpart XXXXXX.pdf
1319K
Jordan Garahana <[e-mail]>Wed, May 8, 2024 at 1:47 PM
To: Jesse Enciso <[e-mail]>, [e-mail]
Hey Jesse,
Thanks for getting the information back to me that I requested. I can add the Subpart 6X information to your file when I
submit my inspection. When you submit that next year, make sure you submit it in January since that is supposed to be
submitted at the start of each calendar year. I am glad you were able to get the help and information you needed about
the rock shredder. I will let you know if there is anything I need for my inspection.
Thanks,
Jordan
[Quoted text hidden]
5/24/24, 8:57 AM State of Utah Mail - Info Requested from 5/1/24 visit
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1798514095034470740&simpl=msg-f:17985140950344707…1/2
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
5/24/24, 8:57 AM State of Utah Mail - Info Requested from 5/1/24 visit
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1798514095034470740&simpl=msg-f:17985140950344707…2/2
Emissions Summary
May 2023 to April 2024
Liberty Safe and Security Products, Inc.
Limit(tpy)None Limit(tpy)33.7 Limit(tpy)14.82 Limit(tpy)4.29 Limit(tpy)1.00 Limit(tpy)3.47 Limit(tpy)4.01 Limit(tpy)1.85
Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling
tons tons tons tons tons tons tons tons tons tons tons tons tons tons tons tons
May-23 0.017 0.151 0.514 3.615 0.025 0.116 0.012 0.072 0.013 0.019 0.000 0.000 0.000 0.000 0.000 0.000
Jun-23 0.017 0.168 0.283 3.898 0.023 0.138 0.012 0.084 0.010 0.030 0.000 0.000 0.000 0.000 0.000 0.000Jul-23 0.017 0.185 1.157 5.055 0.224 0.362 0.063 0.148 0.000 0.030 0.000 0.000 0.000 0.000 0.000 0.000
Aug-23 0.018 0.189 0.736 5.316 0.040 0.402 0.038 0.186 0.001 0.031 0.000 0.000 0.000 0.000 0.000 0.000
Sep-23 0.016 0.189 0.523 5.675 0.011 0.413 0.011 0.197 0.000 0.031 0.000 0.000 0.000 0.000 0.000 0.000Oct-23 0.019 0.193 1.790 7.279 0.440 0.851 0.092 0.289 0.000 0.031 0.000 0.000 0.000 0.000 0.000 0.000
Nov-23 0.025 0.203 0.981 8.228 0.021 0.872 0.021 0.309 0.000 0.031 0.000 0.000 0.000 0.000 0.000 0.000Dec-23 0.023 0.213 0.293 8.501 0.022 0.894 0.022 0.331 0.000 0.031 0.000 0.000 0.000 0.000 0.000 0.000Jan-24 0.027 0.226 0.930 9.008 0.224 1.108 0.064 0.384 0.000 0.031 0.000 0.000 0.000 0.000 0.000 0.000
Feb-24 0.026 0.236 0.198 8.194 0.098 1.190 0.035 0.408 0.009 0.036 0.000 0.000 0.000 0.000 0.000 0.000Mar-24 0.020 0.239 0.823 8.822 0.023 1.199 0.021 0.418 0.002 0.037 0.000 0.000 0.000 0.000 0.000 0.000Apr-24 0.018 0.242 0.010 8.238 0.030 1.179 0.026 0.417 0.004 0.041 0.000 0.000 0.000 0.000 0.000 0.000
Limit
(tpy)1.07 Limit
(tpy)0.12 Limit
(tpy)0.07 Limit
(gal/yr)3,250 Limit
(gal/yr)4,450 Limit
(DTH/yr)239,823 Limit N/A
Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling Monthly total 12-month rolling
tons tons tons tons gal gal gal gal decatherms decatherms ton tons
May-23 0.005 0.040 0.000 0.024 0.000 0.000 66 673 189 288 3,693 36,930 218.5 2,185Jun-23 0.006 0.045 0.000 0.024 0.000 0.000 88 761 148 436 3,693 40,623 218.5 2,403
Jul-23 0.003 0.049 0.161 0.185 0.000 0.000 78 839 105 541 3,693 44,316 218.5 2,622Aug-23 0.012 0.057 0.000 0.185 0.000 0.000 291 1,130 0 541 3,693 44,316 218.5 2,622Sep-23 0.004 0.057 0.000 0.185 0.000 0.000 136 1,105 0 541 3,693 44,316 218.5 2,622
Oct-23 0.006 0.059 0.347 0.532 0.000 0.000 169 1,190 227 756 3,673 44,296 217.3 2,621Nov-23 0.005 0.061 0.000 0.532 0.000 0.000 856 1,962 0 756 5,405 46,008 319.8 2,722Dec-23 0.006 0.063 0.000 0.532 0.000 0.000 562 2,508 0 756 5,312 47,627 314.3 2,818
Jan-24 0.006 0.066 0.161 0.693 0.000 0.000 82 2,590 105 861 6,486 50,420 383.7 2,983Feb-24 0.009 0.071 0.054 0.746 0.000 0.000 262 2,728 163 960 5,616 52,343 332.2 3,097
Mar-24 0.005 0.071 0.000 0.745 0.000 0.000 66 2,708 24 983 5,003 53,653 296.0 3,174Apr-24 0.010 0.076 0.000 0.722 0.000 0.000 271 2,927 50 1,011 3,814 53,774 225.6 3,181
Month Generic Styrene Methanol Paint Usage Primer Usage Natural Gas Usage CO2e
Toluene MIBK NaphthaleneMonthPM VOC Total HAPS Xylene Ethylbenzene
Liberty safe & Security Products
Gas Usage May 2023 –April 2024
2023
MAY DTH – 2984
JUNE DTH – 3005
JULY DTH – 2603
AUGUST DTH- 4023
SEPTEMBER DTH - 3227
OCTOBER DTH -3673
NOVEMBER DTH- 5405
DECEMBER DTH - 5312
2024
JANUARY DTH- 6486
FEBRUARY DTH- 5616
MARCH DTH- 5003
APRIL DTH- 3814