DAQ-2024-012130

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DAQC-CI103370001-24
Site ID 10337 (B1)

MEMORANDUM

TO: FILE – UTAH METAL WORKS, INCORPORATED – Utah Metal Works

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: December 3, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: May 15, 2024

SOURCE LOCATION: 805 Everett Avenue
Salt Lake City, UT 84116

DIRECTIONS: From I-15 north bound, exit 309 US-89 to Everett Avenue

SOURCE CONTACTS: Brenda Terry, Environmental/Safety Contact
801-364-5679, [e-mail]

OPERATING STATUS: Incinerator, mechanical separation lines, and evaporator were
operating.

PROCESS DESCRIPTION: Recycles different types of metal and sells it in bulk to refineries for
processing. Methods used to separate the metal in the wire from the
insulation include incineration and mechanical separation.

Incineration - Wires containing oil, cloth insulation, or tar that may
gum up the choppers in the mechanical separation process are
incinerated. The incinerator has a slanted floor, which slopes to the
back where a spout previously drained molten lead to a mold. Lead
has not been recovered for about fifteen years. The incinerator
consists of a primary chamber that operates at approximately
900 - 1700° F and a secondary chamber that is to be operated at a
minimum of 1300° F. The lower temperature in the primary chamber
is necessary to keep the copper wire from sticking, sweating, or
discoloring. Wires are charged in the incinerator for approximately
2-5 hours per load to burn off all insulation. Pump housings or other
objects are also processed through the incinerator to burn away rubber
gaskets and plastic components, as is small amounts of cutting oil
from the evaporator system. There is no control equipment other than
the afterburner installed to the side of the primary chamber.

Mechanical Separation - The insulation and wire are mechanically
separated by a wire chopper and two gravity separators. The
emissions from the wire chopper and one gravity separator are vented
through a baghouse and cyclone. Emissions from the other gravity
separator are just vented through a baghouse.
0 . ) $ . ) - "
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Wastewater Evaporator System - A small burner heats the lower
reservoir of a machining mix of water and oils. Water is pumped and
sprayed in an upper chamber to evaporate water so oil can be
disposed.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN103370009-24, dated
March 27, 2024
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Utah Metal Works, Incorporated
Utah Metal Works

P.O. Box 1073 805 Everett Avenue
Salt Lake City, UT 84110 Salt Lake City, UT 84116

SIC Code: 5093: (Scrap & Waste Materials)

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]

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
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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. This facility has a plasma cutter system operating within the
metal separating tables that have not been identified on the AO. Following this inspection,
on June 5, 2024, an environmental consultant, Kristine Davies, with Alliance Technical
Group, notified the DAQ and identified the plasma cutter as an emission source. On June
25, 2024, the consulting company contacted stated that a NOI to add the cutters to a new
modified AO would be submitted. On November 21, 2024, the consulting contact stated that
the NOI will be delayed in order to complete air dispersion modeling. See the attached
email correspondence. A Warning Letter regarding the requirement to submit a NOI prior
to the operation of equipment was issued. No additional compliance action is recommended
at this time. Utah Metal Works is otherwise in compliance with the conditions of the
current March 27, 2024, AO. No other changes to the equipment and process were detected,
no limits were exceeded, all records, including maintenance records are kept as required,
and no applicable breakdowns have occurred. An Emission Inventory for the 2023 activity
year was submitted and a summary report is attached to this inspection memo. A
notification of the installation and operation of the new Aluminum Wire Chopping Line is
included with the stack testing protocol submitted by Alliance Technical Group for this
equipment (DAQC-314-24).

Section II: SPECIAL PROVISIONS

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

II.A.1 Utah Metal Works
A scrap metal recycling plant

II.A.2 East Cyclone/Baghouse
One (1) Baghouse controlling one (1) copper separating table
Flow rate: 14,728 acfm

II.A.3 West Cyclone/Baghouse
One (1) Cyclone and Baghouse in series controlling one (1) copper separating table
Flow rate: 14,728 acfm

II.A.4 Aluminum Cyclone/Baghouse
Manufacturer: CamCorp
One (1) Cyclone controlled by a dust collector and baghouse in series
Flow rate: 25,345 acfm

II.A.5 Wire Incinerator
One (1) Incinerator
Primary Chamber Burner Capacity: 1.0 MMBtu/hr
Secondary Chamber Burner Capacity: 1.0 MMBtu/hr Control: Secondary Chamber

II.A.6 Wastewater Evaporator System
One (1) Wastewater Evaporator System
Fuel: Propane
Maximum Rated Capacity: Less than 5.0 MMBtu/hr burner
Control: Filter

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II.A.7 Aluminum Wire Chopping Line
Location: East Building 2
Includes: Primary shredder, secondary shredder, magnetic separator, tertiary granulator, and various
bucket elevators

II.A.8 One (1) Vibrating Screen
Location: East Building 2
Control: Baghouse

II.A.9 Two (2) Gravity Separators
Location: East Building 2
Control: Baghouse

II.A.10 Miscellaneous Combustion Equipment
Miscellaneous off-road diesel and liquid propane-powered equipment

Status: Out of Compliance. The AO DAQE-AN103370009-24 failed to include a plasma
cutter operation. The remaining listed equipment has been installed and is
operational. The plasma cutters are being added through an NOI submitted by the
environmental consultants Alliance Tech. See the attached email correspondence. A
Warning Letter was issued to document the unpermitted equipment. No additional
compliance action is recommended.

II.B Requirements and Limitations

II.B.1 Plant-Wide Requirements

II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Incinerator - 5% opacity

B. Baghouses/Dust Collector Filters - 10% opacity

C. Fugitive dust - 20% opacity

D. Haul road and mobile equipment operational areas - 20% opacity

E. Wastewater evaporator system filter - 10% opacity

F. All other points - 15% opacity. [R307-401-8]

Status: In Compliance. No visible emissions were observed from the operating equipment
during this inspection. All emissions are controlled by baghouses. The haul roads and
operational areas are paved.

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 from any point were observed during this
inspection. The observations were made in a manner consistent with Method 9. See the
attached VEO.
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II.B.1.a.2 Opacity observations of fugitive dust from intermittent sources shall be conducted according to
40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-
second intervals over a six-minute period shall not apply. The number of observations and the
time period shall be determined by the length of the intermittent source. For fugitive dust
generated by mobile sources, 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. [R307-401-8]

Status: In Compliance. No visible dust was observed from any mobile sources during this
inspection.

II.B.1.b The owner/operator shall not produce more than 10,530 tons of Aluminum per rolling 12-month
period. [R307-401-8]

Status: In Compliance. The Aluminum Wire processing line was permitted by the March
27, 2024, AO and had only been operating as of April of 2024. Because of this, only one
month has been recorded for this 12-month period. The amount of scrap aluminum coming
into the system for that month was weighed as 823,625 pounds (411.8 tons) which resulted
in 535,356 pounds (267.7 tons) of refined aluminum produced. See the attached Aluminum
Chopping Line record.

II.B.1.b.1 The owner/operator shall: A. Determine production with belt scales or a scale house B. Record production on a daily basis C. Use the production data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. Aluminum scrap is weighed on a belt scale as it enters the Aluminum Chopping Line. The resulting refined aluminum is weighed as a product that is invoiced to the customer. This process line has only been fully operational as of April 2024.

II.B.1.c The owner/operator shall use only natural gas as fuel in the incinerator. [R307-401-8]

Status: In Compliance. Only natural gas is used in the wire incinerator.

II.B.2 Baghouse Conditions

II.B.2.a The owner/operator shall use the East Baghouse, West Baghouse, and Aluminum Baghouse to
control particulate emissions from each attached feeding gravity separator/vibrating screen.
[R307-401-8]

Status: In Compliance. The assigned baghouses are used to control the particulates from
the attached gravity separators and vibrating screens.

II.B.2.b The owner/operator shall not operate the Aluminum baghouse for more than 3,900 hours per
rolling 12-month period. [R307-401-8]

Status: In Compliance. 90 hours were reported for this baghouse for the month of April
2024.

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II.B.2.b.1 The owner/operator shall:

A. Determine hours of operation with a supervisor monitoring and maintaining an
operations log

B. Record hours of operation each day

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. The aluminum baghouse captures particulate from the aluminum
chopping line which at the time of this inspection started operations in April of 2024. The
baghouse operated 90 hours during that month. See the attached Aluminum chopping line
reported total.

II.B.2.c The owner/operator shall operate the Aluminum baghouse with a flowrate from 12,221 scfm to
14,937 scfm. [R307-401-8]

Status: In Compliance. The records reviewed for the month of operation for the aluminum
baghouse were consistently between 12,221 and 14,937 scfm and were read at 13,410 scfm
at the time of the inspection.

II.B.2.c.1 The owner/operator shall take the measurement of the flow rate, in scfm, once per operating day
through the Aluminum baghouse. [R307-401-8]

Status: In Compliance. The flow rate measurements are taken at least once daily. The flow
rate was observed at 13,410 scfm during the inspection.

II.B.2.c.2 The owner/operator shall maintain records of the flow rates through the Aluminum baghouse.
[R307-401-8]

Status: In Compliance. Records of the flow rates for the aluminum baghouse are
electronically monitored and recorded. The records can be viewed in the main office.

II.B.2.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across each baghouse. [R307-401-8]

Status: In Compliance. Pressure gauges have been installed to monitor the associated
baghouses.

II.B.2.d.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

Status: In Compliance. Pressure gauges have been installed to monitor the associated
baghouses.

II.B.2.d.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

Status: In Compliance. The gauges are set up to measure the static pressure differentials in
at least 1-inch increments.
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II.B.2.e During operation of each baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between 2 and 7 inches of water column. [R307-401-8]

Status: In Compliance. The requirement to record the baghouse static pressure differential
began with this March 27, 2024, AO and did not exist on the previous DAQE-
AN103370008-18 permit conditions. Utah Metal Works had just begun to implement the
water column recordings for the baghouses at the time of this inspection. Only a few weeks
of differential readings were available but all were between 2 and 7 inches. The reading for
the Aluminum baghouse was at 3.2 during the inspection. The other baghouses were not
operating during the site observations.

II.B.2.e.1 The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

Status: In Compliance. The requirement to record the baghouse static pressure differential
began with this March 27, 2024, AO and did not exist on the previous DAQE-
AN103370008-18 permit conditions. Utah Metal Works had just begun to implement the
water column recordings for the baghouses at the time of this inspection. Only a few weeks
of differential readings were available but all were between 2 and 7 inches. The reading for
the Aluminum baghouse was at 3.2 during the inspection. The other baghouses were not
operating during the site observations.

II.B.2.e.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended static pressure differential for the unit (if applicable); C. Daily static pressure differential readings; D. Date of reading. [R307-401-8] Status: In Compliance. The system that has been put in place to read baghouse static pressure differentials include the date of the reading, the reading in water column inches, and a unit identification.

II.B.2.f At least once every 12 months, the owner/operator shall calibrate each pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

Status: In Compliance. The requirement to calibrate the baghouse pressure gauges began
with the March 27, 2024, AO. The new annual calibration requirement was discussed with
the source contact, Brenda Terry.

II.B.2.f.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

Status: In Compliance. The conditions related to the baghouse pressure gauges were
initiated with the March 27, 2024, AO. The source is aware of the new baghouse record
keeping requirements.

II.B.2.g The owner/operator shall cover the receptor bin attached to the Aluminum baghouse to protect
fugitive dust being re-entrained into the atmosphere. [R307-401-8]

Status: In Compliance. The receptor bin to the aluminum baghouse is covered at all times.
No visible dust was observed from this point during this inspection.
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II.B.3 Emission Unit Specific Condition

II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from three (3) baghouses each: Pollutant lb/hr grains/dscf East and West Baghouses Filterable PM10 1.10 0.020 Filterable PM2.5 1.10 0.020 Aluminum Baghouse (new) Filterable PM10 0.24 0.00133 Filterable PM2.5 0.12 0.00065. [R307-401-8] Status: In Compliance. The East and West Baghouses were tested on May 9, 2024 (Unit #2 for the Gravity Separator Baghouse), and May 10, 2024 (Unit #1 for the Wire Chopper Baghouse). Unit #1 DAQ review tested results were 0.0011 gr/dscf, and 0.060 lb/hr for PM10. Unit #2 DAQ review tested results were 0.00098 gr/dscf and 0.053 lb/hr for PM10. Both were under the AO established limits of 0.020 gr/dscf and 1.10 lb/hr for PM10 and PM2.5. The Aluminum Baghouse (Chopping Line) tested on May 7-8, 2024. The DAQ review tested results were 0.000097 gr/dscf and 0.18 lb/hr for PM10. The tested results were under the AO established limit for PM10 but the pound per hour result was over the PM2.5 limit of 0.12 lb/hr. See the email correspondence from DAQ stack test reviewer, Paul Bushman, and DAQC-624-24 for more information. The source tested again in order to meet the PM2.5 limit. This test was conducted on September 23-25, 2024. The DAQ review results were 0.00054 gr/dscf and 0.09048 lb/hr for PM10 and 0.00036 gr/dscf and 0.06057 lb/hr for PM2.5. See DAQC-1077-24 for more information.

II.B.3.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-401-8]

Status: In Compliance. The stack testing protocols were submitted as required. See
DAQC-314-24, DAQC-624-24, and DAQC-763-24 for more information. The DAQ stack
testing review indicated that the tests were conducted as per the AO with the exception of
the missed PM2.5 test for the new aluminum baghouse which was retested as required on
September 23-25, 2024.

II.B.3.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. The owner/operator shall stack test the Baghouse 3 controlling the
Aluminum wire chopping line within 180 days of the date on this AO. [R307-401-8]

Status: In Compliance. The tests for the new baghouse were performed within 180 days of
the startup of the equipment.

II.B.3.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within three (3) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-401-8]

Status: In Compliance. The next stack tests scheduled for all three baghouses are
scheduled for the calendar year of 2027.
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II.B.4 Stack Testing Requirement

II.B.4.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.4.a.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in R307-165-
3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3,
R307-401-8]

II.B.4.a.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.4.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.4.a.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.4.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.4.a.6 Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.4.a.7 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40
CFR 63 Subpart A, R307-401-8]

II.B.4.a.8 Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10

[R307-401-8]

II.B.4.a.9 Filterable PM2.5
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40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5. [R307-401-8]

Status: In Compliance for the above stack testing conditions. The stack testing protocols
were submitted as required. See DAQC-314-24, DAQC-624-24, and DAQC-763-24 for
more information. A second stack test was required for the new aluminum chopping line
baghouse for PM2.5. See DAQC-1077-24. The DAQ stack test reviews indicated compliance
with the AO requirements for the Unit #1, Unit #2, and the retest of the Aluminum
Chopping Line baghouse.

II.B.5 Incinerator Requirement

II.B.5.a The owner/operator shall not operate the incinerator for more than 3,000 hours per rolling 12-
month period. [R307-401-8]

Status: In Compliance. The incinerator operation hours were reported as 817.08 for the
12-month period running from April 2023 through March 2024. The incinerator was shut
down in April of 2024 in order to replace the interior heating brick lining the chamber and
change the fuel to gas control in the thermalcouple instruments. The incinerator was still
non-operational at the time of this inspection. See the attached operation hour spreadsheet.

II.B.5.a.1 The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log

B. Record hours of operation each day

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. Utah Metal Works will be using an electronic monitoring system
for the incinerator when the chamber is operational again. The previous system consisted
of a hand-written log that included the date, time periods of use, and fuel used. See the
attached example of the hand-written log system.

II.B.5.b The owner/operator shall not operate the primary chamber at less than 800 degrees Fahrenheit for
more than five minutes in any 60-minute period. [R307-401-8]

Status: In Compliance. The company's Environmental Contact, Brenda Terry, stated that
the primary incineration system has a set point of at least 900 degrees Fahrenheit. The
system is designed to trigger an alarm to notify the operators if the temperature drops
below that minimum.

II.B.5.c The owner/operator shall not load material into the primary chamber until the secondary chamber
has correctly preheated to a minimum temperature of 1,300 degrees Fahrenheit. The
owner/operator shall operate the secondary chamber at a temperature at or above 1,300 degrees
Fahrenheit throughout the entire incineration cycle. [R307-401-8]

Status: In Compliance. The source Environmental contact, Brenda Terry, stated that the
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secondary incineration chamber system has a set preheat temperature of 1,400 degrees
Fahrenheit. The secondary chamber will not accept the materials until this minimum
temperature will be reached.

II.B.5.d The owner/operator shall install thermocouples in the incinerator in both the primary and
secondary chambers. [R307-401-8]

Status: In Compliance. Thermocouples had been installed in both the primary and
secondary chambers at the time of this inspection. The incinerator brick replacement was
still in process so that the system was still not operational.

II.B.5.d.1 The owner/operator shall install the thermocouples such that an inspector/operator can safely
read the output any time. All instruments shall be calibrated against a primary standard at least
once per rolling 12-month period. Records of the temperature of the secondary chamber shall be
kept daily and include the following information:

A. Temperature of the secondary chamber at the start of the incineration cycle

B. Temperature of the secondary chamber halfway through the incineration cycle

C. Temperature of the secondary chamber at the end of the incineration cycle. [R307-401-8]

Status: In Compliance. The thermocouples had been installed into the incinerator on
January 2, 2024. The placement of the monitors for both chambers can be easily viewed at
the side of incinerators. Brenda Terry stated that the thermocouples will be calibrated
within 6 months of the startup of the new equipment.

II.B.6 Wastewater Evaporator System Requirement

II.B.6.a The owner/operator shall equip the wastewater evaporator system with a filter, or equivalent, to
control particulate emissions. All air exiting the wastewater evaporator system shall pass through
this control system before being vented to the atmosphere. [R307-401-8]

Status: In Compliance. All air exiting the wastewater evaporator system passes through the
system filter. The source contact stated that this filter is replaced monthly.

II.B.6.b The owner/operator shall not operate the wastewater evaporator system for more than 3,000 hours
per rolling 12-month period. [R307-401-8]

Status: In Compliance. The wastewater evaporator system was operated a reported 711
hours for the 12-month rolling period of May 2023 through April 2024. See the Evaporator
Hour print out log.

II.B.6.b.1 The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log

B. Record hours of operation each day the wastewater evaporator system is in operation

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months

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D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. The hours of use are recorded for all periods when the system
operates. The daily totals are recorded in a binder located by the equipment and were
reviewed during the site inspection. The monthly totals are then summarized and recorded
in an electronic log.

Section III: APPLICABLE FEDERAL REQUIREMENTS

Status: Not Applicable at this time. There are no federal requirements identified on the permit for this
scrap metal facility.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: In Compliance. No references to R307-309 are identified on the current AO DAQE-
AN103370009-24, however an opacity limit of 20% is referenced for the haul roads on Condition
II.B.1.a.C. This facility is paved and there are short distances between delivery and pick up stations.
No visible dust was observed from any moving vehicle. No track out debris was observed at the
entrance.

EMISSION INVENTORY:
An Emissions Inventory has been submitted for the 2023 Activity Year and has been attached to this
inspection memo. Listed below are the Actual Emissions Inventory provided from Utah Metal Works
Incorporated – Utah Metal Works. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN103370009-24, dated March 27, 2024, is provided. PTE are supplied for supplemental purposes
only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 2118.00
Carbon Monoxide 11.01
Nitrogen Oxides 24.10
Particulate Matter - PM10 15.44
Particulate Matter - PM2.5 15.44
Sulfur Dioxide 2.07
Volatile Organic Compounds 2.58

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

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PREVIOUS ENFORCEMENT
ACTIONS: No formal compliance actions are on record for this facility for the
last five years prior to this inspection.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN103370009-24, dated
March 27, 2024, the overall status is: Out of Compliance with
R307-401, Condition 1.3, for not identifying the plasma cutter on the
equipment list. A Warning Letter was issued to document this issue
of non-compliance. Check for a new AO that adds the plasma cutter
to the permitted equipment.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Check the baghouse and incinerator operation records to ensure that
all the 2024 AO requirements are being met. Check for a new AO that
includes the plasma cutters. The targeting frequency should be
increased until it is documented that all the added conditions are
successfully evaluated.

NSR RECOMMENDATIONS: The plasma cutter should be added to the permitted equipment list.

ATTACHMENTS: VEO, inspection and production record correspondence, Aluminum
production totals, Aluminum Chopping line daily tallies and hour
records, Incinerator total burn hours, incinerator daily temperature
readings examples, initial calibration for the incinerator
thermocouples, Alliance NOI correspondence, stack testing
correspondence, Evaporator Wastewater system hours, and 2023
Emissions Inventory Summary report.
Susan Weisenberg <[e-mail]>
RE: scheduling a routine inspection for May 15
1 message
Brenda Terry <[e-mail]>Wed, May 15, 2024 at 3:41 PM
To: Susan Weisenberg <[e-mail]>
Cc: Catherine Williams <[e-mail]>
Hi Susan,
Thank you so much for coming out and going through everything with us. You guys were so much fun to show around! I
love it when people get excited about our processes.
I have attached all the files we discussed. Let me know if I missed anything.
Thanks,
Brenda
Brenda Terry
IT/Safety/Environmental
Utah Metal Works
801-364-5679
[e-mail]
www.umw.com
From: Susan Weisenberg <[e-mail]>
Sent: Tuesday, May 14, 2024 9:07 AM
To: Brenda Terry <[e-mail]>
Cc: Catherine Williams <[e-mail]>
Subject: Re: scheduling a routine inspection for May 15
12/3/24, 2:08 PM State of Utah Mail - RE: scheduling a routine inspection for May 15
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r2751654427027063200%7Cmsg-f:1799156469584938763…1/5
CAUTION: The email below is from an external source. Please exercise caution before opening attachments,
clicking links, or interacting with this message.
Thanks for the information regarding the incinerator. We will still proceed with the site inspection and will just review the
records and the other applicable conditions. Thanks, see you tomorrow.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Mon, May 13, 2024 at 10:54 AM Brenda Terry <[e-mail]> wrote:
Just wanted to give you a heads up that the Incinerator will not be in operation on the 15th, it has been down for a little
over a month with a gas valve controller problem and we had a hard time finding and scheduling a new person to come
work on that, our old person is retiring. We are in the process of new brick while it is down.
I don’t know if this makes a difference to you, if it does would could postpone until June if you would like.
Let me know what you would like to do.
Thanks,
Brenda
Brenda Terry
IT/Safety/Environmental
Utah Metal Works
801-364-5679
[e-mail]
www.umw.com
12/3/24, 2:08 PM State of Utah Mail - RE: scheduling a routine inspection for May 15
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r2751654427027063200%7Cmsg-f:1799156469584938763…2/5
From: Susan Weisenberg <[e-mail]>
Sent: Thursday, May 02, 2024 3:35 PM
To: Brenda Terry <[e-mail]>
Cc: Catherine Williams <[e-mail]>
Subject: Re: scheduling a routine inspection for May 15
CAUTION: The email below is from an external source. Please exercise caution before opening
attachments, clicking links, or interacting with this message.
One pm will work well. Thanks! I will let you know if anything changes.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Thu, May 2, 2024 at 11:47 AM Brenda Terry <[e-mail]> wrote:
That day would work for me. Can we plan on early afternoon about 1 or 2?
Thanks,
Brenda
Brenda Terry
IT/Safety/Environmental
Utah Metal Works
801-364-5679
12/3/24, 2:08 PM State of Utah Mail - RE: scheduling a routine inspection for May 15
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r2751654427027063200%7Cmsg-f:1799156469584938763…3/5
[e-mail]
www.umw.com
From: Susan Weisenberg <[e-mail]>
Sent: Thursday, May 02, 2024 11:22 AM
To: Brenda Terry <[e-mail]>
Subject: scheduling a routine inspection for May 15
CAUTION: The email below is from an external source. Please exercise caution before opening
attachments, clicking links, or interacting with this message.
Hello, my name is Susan Weisenberg. I work with the Division of Air Quality (DAQ) for the State of Utah. I have been
assigned Utah Metal Works, located at 805 Everett Avenue, Salt Lake City, as a routine inspection. I am trying to
schedule this year's inspection as there are two additional DAQ employees that work for the Emissions Inventory
Section, who would like to accompany me for general training purposes.
I am hoping to schedule this site visit for any time of day during Wednesday, May 15. The purpose of the inspection
will be to determine compliance with your new Approval Order dated March 27, 2024.
Let me know if this date will work for you and if so, your preferred time. Also, let me know if you have any questions
or need any additional information. Thank you for your time with this.
Utah Metal Works AN103370009-24.pdf
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
6 attachments
12 MONTH ROLLING TOTAL INCINERATOR HOURS.pdf
32K
12/3/24, 2:08 PM State of Utah Mail - RE: scheduling a routine inspection for May 15
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r2751654427027063200%7Cmsg-f:1799156469584938763…4/5
ALUMINUM CHOPPING LINE HOURS AND LBS DOCUMENTATION.pdf
556K
EVAPORATOR HOURS AND 12 MONTH ROLLING TOTALS.pdf
2409K
INCINERATOR HANDWRITTEN LOGS APRIL 2023 SAMPLE.pdf
1263K
INCINERATOR TIMES AND TEMPS SPREADSHEETS.zip
5888K
THERMOCOUPLE REPLACEMENT 5-15-24 AND CALIBRATION CERT.pdf
360K
12/3/24, 2:08 PM State of Utah Mail - RE: scheduling a routine inspection for May 15
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r2751654427027063200%7Cmsg-f:1799156469584938763…5/5
Susan Weisenberg <[e-mail]>
RE: NOI to add Plasma Cutter Utah Metal Works
1 message
Kristine Davies <[e-mail]>
To: Susan Weisenberg <[e-mail]>Cc: Chad Gilgen <[e-mail]>, Alan Humpherys <[e-mail]>
Susan,

Thank you for reaching out. After talking to both Alan and Chad, we determined we needed to do some air dispersion modeling, so we had to back up and get that projecmodeler, he had a lot of it set up, so let me see where he is and I can provide a better idea of when we expect to submit.

Kristine Davies
Project Director
Mobile: [phone]
www.alliancetg.com

From: Susan Weisenberg <[e-mail]>
Sent: Thursday, November 21, 2024 11:04 AM
To: Krisne Davies <[e-mail]>
Cc: Chad Gilgen <[e-mail]>; Alan Humpherys <[e-mail]>
Subject: NOI to add Plasma Cuer Utah Metal Works

EXTERNAL EMAIL - This email was sent by a person from outside your organization. Exercise caution when clicking links, opening attachments or taking further action, before validating its authenticity.

Hello, my name is Susan Weisenberg and I am an inspector for the Division of Air Quality's Minor Source Compliance Section. I am trying to finalize an inspection memo for Utah Metal WCity, Utah.

On July 1, 2024 you stated in an email to Chad Gilgen that you would be submitting to our New Source Review engineering section, Notice of Intent (NOI) information to add a plasma cua record of this submission. Can you let me know the status of this NOI? Thanks

Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

12/3/24, 1:37 PM State of Utah Mail - RE: NOI to add Plasma Cutter Utah Metal Works
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-147742948670931879%7Cmsg-f:1816365398189923274&…1/1
Susan Weisenberg <[e-mail]>
Utah Metal Works
1 message
Paul Bushman <[e-mail]>Tue, Jun 25, 2024 at 1:44 PM
To: Susan Weisenberg <[e-mail]>
Hi Susan,
Chad said you were working on an inspection memo for Utah Metal Works. They have PM10 and PM2.5 limits on all
three baghouses, however it looks like the limits on the east and west are identical, and since they were below the PM10
limit, it would appear that they are below the PM2.5 limit as well since they capture everything PM10 and lower during that
test. However, the new baghouse has a smaller limit for the PM2.5 than the PM10 and they did not speciate during
testing, and the values they have for PM10 exceed the PM2.5 limit, so we don't know if they are in compliance or not until
they test for the PM2.5.
The stack test report is going through esign right now, and I can send you a copy once it's done so that you can look at it.
Also I'll attach the correspondence with Brenda Terry letting them know that they still needed to determine the PM2.5
emissions, which is also attached to the stack test report.
Paul

Paul Bushman
Environmental Scientist | Minor Source Compliance
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements
State of Utah Mail - Chopping Line Baghouse Stack Test results- UDAQ.pdf
183K
12/3/24, 1:32 PM State of Utah Mail - Utah Metal Works
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1802863555450346195%7Cmsg-f:1802863555450346195&s…1/1
Susan Weisenberg <[e-mail]>
Fwd: Question Regarding Plasma Cutting Operation
1 message
Chad Gilgen <[e-mail]>
To: Susan Weisenberg <[e-mail]>
Chad Gilgen | Manager | Minor Source Compliance385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
---------- Forwarded message ---------From: Chad Gilgen <[e-mail]>
Date: Mon, Jul 1, 2024 at 4:27 PMSubject: Re: Question Regarding Plasma Cutting Operation
To: Kristine Davies <[e-mail]>Cc: Susan Weisenberg <[e-mail]>, Alan Humpherys <[e-mail]>
Hi Kristine,
That sounds great. Thanks for letting me know.
Chad
Chad Gilgen | Manager | Minor Source Compliance385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Tue, Jun 25, 2024 at 6:38 PM Kristine Davies <[e-mail]> wrote:
Chad,

Thank you for the follow up and additional information. I had discussed the questions from the self-evaluation with the site but was not aware of the recent inspection. should be well ahead of the game in getting the operation into the AO prior to the next inspection.

Kristine Davies
Project Director
Mobile: [phone]
www.alliancetg.com

From: Chad Gilgen <[e-mail]>
Sent: Tuesday, June 25, 2024 1:35 PM
To: Krisne Davies <[e-mail]>; Susan Weisenberg <[e-mail]>
Cc: Alan Humpherys <[e-mail]>
Subject: Re: Queson Regarding Plasma Cung Operaon

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hello Kristine,

After our previous correspondence, it was brought to my attention that one of our inspectors (Susan Weisenberg) was at Utah Metal Works on May 15, 2024, and observed the unapproved
found while Utah Metal Works was preparing their 2023 Emissions Inventory for the DAQ. Based on this information, these plasma cutters would not be covered under the Utah Environme
12/3/24, 2:21 PM State of Utah Mail - Fwd: Question Regarding Plasma Cutting Operation
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1801241399053528056%7Cmsg-f:1814269464639859615&s…1/3
evaluated for inclusion on the Approval Order (AO).

However, it was noted that these plasma cutters have been on-site for around 13 years and are not new equipment. It also sounds like you are currently working with Alan Humpherys to ad
memo and Utah Metal Works will be scheduled for a follow-up inspection next year. This should give Utah Metal Works time to complete the modification with Alan's group. If the AO has nup inspection, then Utah Metal Works could be cited for non-compliance with Utah air quality rules.

Let me know if you have any questions or would like to discuss this one further.

Thanks,
Chad

Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Jun 10, 2024 at 5:12 PM Kristine Davies <[e-mail]> wrote:
Chad,

Thank you for the reply. I will work with UMW to get responses to those questions and let you know.

Kristine Davies
Project Director
Mobile: [phone]
www.alliancetg.com

From: Chad Gilgen <[e-mail]>
Sent: Friday, June 7, 2024 3:59 PM
To: Krisne Davies <[e-mail]>
Subject: Re: Queson Regarding Plasma Cung Operaon

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hi Kristine,

Thanks for contacting me regarding your question. Based on the information you have provided, this discovery likely qualifies as a voluntary disclosure under the Utah Environmental Se
Title19/Chapter7/19-7.html. If Utah Metal Works can provide an acceptable response for items 2 through 3 of Section 109, then the DAQ can waive civil penalties and additional compliamanner. Use of the equipment can be detailed as part of the evaluation. Once this voluntary disclosure is submitted, I will review it and let you know if it meets the criteria of The Act.

Thanks and please let me know if you have any questions or would like to set up a time to discuss further.

Sincerely,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
12/3/24, 2:21 PM State of Utah Mail - Fwd: Question Regarding Plasma Cutting Operation
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1801241399053528056%7Cmsg-f:1814269464639859615&s…2/3

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Wed, Jun 5, 2024 at 9:56 AM Kristine Davies <[e-mail]> wrote:
Chad,

I have a new client (Utah Metal Works) that has a small plasma cutting operation in addition to other activities conducted at the site. Most of the activities are permitted under Approva
discovered that the plasma cutting operation had not been previously permitted. We have discussed the situation with Alan Humpherys from the Minor Source NSR unit, so will be subabout whether they can continue to operate the process during the interim as they are working on the AO modification. Alan suggested we reach out to you to discuss. Please let me
or if you have any immediate questions regarding the operation.

Thank you,

Kristine Davies
Project Director
Mobile: [phone]
www.alliancetg.com

12/3/24, 2:21 PM State of Utah Mail - Fwd: Question Regarding Plasma Cutting Operation
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1801241399053528056%7Cmsg-f:1814269464639859615&s…3/3
2023 Emissions Inventory Report
Utah Metal Works Incorporated- Scrap Metal Recycling Plant (10337)
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)1.4534 0.14441 1.59781
PM10-FIL PM10 Filterable 1.44123 0.031 1.47223
PM25-PRI PM2.5 Primary (Filt + Cond)1.4534 0.14441 1.59781
PM25-FIL PM2.5 Filterable 1.44123 0.031 1.47223
PM-CON PM Condensible 0.01217 <.00001 0.01217
SO2 Sulfur Dioxide 0.06054 0.01642 0.07696
NOX Nitrogen Oxides 1.1323 4.30402 5.43633
VOC Volatile Organic Compounds 0.12801 1.40821 1.53622
CO Carbon Monoxide 0.46613 4.61258 5.0787

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 0.227
7439965 Manganese (HAP)PM 0.028
7440020 Nickel (HAP)PM 0.102

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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