DAQ-2024-012133

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DAQC-CI115060001-24
Site ID 11506 (B1)

MEMORANDUM

TO: FILE – GOLDEN EMPIRE MANUFACTURING, INC. – Brigham City Paint
Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: October 23, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: September 19, 2024

SOURCE LOCATION: 1025 North Watery Lane
Brigham City, UT 84302

SOURCE CONTACT: Wayne McCandless, Safety Manager, 435-538-5398,
435-720-7077, [e-mail]

OPERATING STATUS: In operation

PROCESS DESCRIPTION: Golden Empire operates a structural steel manufacturing plant in
Brigham City. The basic processes are cutting, welding,
assembling, and painting of large steel units that are used for
steel girders for construction of major load bearing structures.

Steel beams arrive by truck and are transferred to the Cut and
Prep Area for cutting and drilling by computer-aided machines.

Fabrication: The cut pieces are cleaned and welded using
shielding gas by Metal Inert Gas-Gas Metal Arc Welding (MIG-
GMAW).

Painting: The assembled structures are then painted in the new
enclosed facility using airless spray gun applicators. The source
indicated that the paints are water-based and arrive in 55-gallon
metal drums. There was no painting in progress during this
inspection.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN115060007-23, dated
January 25, 2023

MACT (Part 63) - XXXXXX: National Emission Standards for
Hazardous Air Pollutants Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Golden Empire Manufacturing, Inc.
Brigham City Paint Facility

P.O. Box 832
1025 North Watery Lane

1025 North Watery Lane
Brigham City, UT 84302 Brigham City, UT 84302

SIC Code: 3441: (Fabricated Structural Metal)

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Status: In Compliance. Golden Empire Manufacturing did not exceed any limits set forth
in this AO. Golden Empire Manufacturing did not experience any breakdowns resulting in
an emissions event. Golden Empire Manufacturing plans to keep records for a minimum of
two years, and also maintains records of maintenance activities performed on equipment
authorized by this AO. Golden Empire Manufacturing is not required to submit an
Emissions Inventory Report at this time.

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SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Golden Empire Manufacturing

II.A.2 Enclosed Cleaning System

II.A.3 Indoor Paint Area

II.A.4 Paint Sprayers
Three (3) airless paint sprayers
Capacity: three (3) gallons per minute each

Status: In Compliance. Golden Empire Manufacturing is in the process of adding an
indoor Shot Blaster which will be venting internally upon completion. Golden Empire
Manufacturing responded to NSR that the Shot Blaster will vent internally. See the
email response in the attachment. Golden Empire Manufacturing also operates an
internally-vented Messner Cutting Systems Plasma-Cutting Table equipped with a
Dust Collector.

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Plantwide Requirements

II.B.1.a The owner/operator shall equip the indoor painting operations with filters to control particulate
emissions. All exhaust air from the painting operations shall be routed through the filters before
being vented to the atmosphere. [R307-401-8]

Status: In Compliance. The indoor painting operations are equipped with filters to control
particulate emissions. All exhaust air from the painting operations are routed through the
filters before being vented to the atmosphere.

II.B.1.b The owner/operator shall store VOC containing materials in covered containers (except when in
use) and shall store VOC laden rags in covered containers. The owner/operator shall clean the
spray guns in an enclosed cleaning system to control VOC emissions. [R307-401-8]

Status: No longer applicable. According to Golden Empire Manufacturing, they switched
to water-based paints since 2010. However, coatings containing VOC such as W/R Dark
Vulcraft Gray was last ordered in July 2022, and 0032 LVOC Gray Shop Prime was last
ordered in February 2020. See the email attachment for additional information. During
this inspection, the paints were observed in 55-gallon drums which were closed. See the
SDS of the coatings in the attachment.
II.B.1.c The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All painting operations -10% opacity B. All other points -20% opacity. [R307-401-8]
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II.B.1.c.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. There were no visible emissions observed from painting operations
and all other points during this inspection. The opacity observations were conducted
according to 40 CFR 60, Appendix A, Method 9.

II.B.1.d The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:

34.35 tons per rolling 12-month period for VOCs (excluding HAPs)
19.07 tons per rolling 12-month period for HAPs.

The owner/operator shall emit less than 10 tons per rolling 12-month period for each individual
HAP (The HAPs include xylene, MIBK, toluene, and ethyl benzene.). [R307-401-8]

II.B.1.d.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]

II.B.1.d.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons) [R307-401-8]. [R307-401-8] Status: In Compliance. According to Golden Empire Manufacturing, they switched to water-based paints since 2010. See the SDS of the coatings in the attachment. Xylene is used to clean the paint equipment, the pump system, the spray tips, and the spray guns and also contains ethylbenzene and Toluene according to the SDS. Therefore, the rolling 12-month usage of HAPs from October 2023 to September 2024 indicated the following: Ethylbenzene, 0.065 tons; Toluene, 0.00004 tons; and Xylene, 0.043 tons. See the attachment 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) - XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source
Standards for Nine Metal Fabrication and Finishing Source Categories

Status: In Compliance. Golden Empire Manufacturing submitted a Notice of Compliance Status
(NOCS) to the DAQ dated January 2, 2024. See the attachment for additional information.
Golden Empire Manufacturing uses 2,000 pounds or more of MFHAP-containing welding rod or
welding wire annually. Golden Empire Manufacturing uses welding filler metals, shielding gases, and
carrier gases in the Gas Metal Arc Welding process with reduced fume generation.

The 2021 initial daily, weekly, and monthly Welding Visible Emissions Observations record
has been included in the attachment. See the 2023 and the current 2024 quarterly Welding Visible
Emissions Observation in the attachment.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-214 - National Emission Standards for Hazardous Air Pollutants

Status: In Compliance. This Area Source Rule is applicable to MACT (Part 63) – XXXXXX. See
Section III for additional information.

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

Status: In Compliance. There were no fugitive emissions and fugitive dust observed during this
inspection. The Fugitive Dust Control Plan for the Golden Empire Manufacturing is dated March 12,
2021. See the email attachment for additional information.

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

Status: In Compliance. The paint equipment, the pump system, the spray tips, and the spray guns
are cleaned with Xylene in a Parts Washer which is kept closed when not in use. See the SDS in the
attachment. Spent Xylene is placed in barrels and transferred to Safety Kleen for offsite disposal.

R307-335 – Degreasing

Status: In Compliance. During this inspection, the Degreaser was closed, when not in use. See the
attachment for additional information.

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R307–350 Miscellaneous Metal Parts and Products Coatings

Status: Not in Compliance, however, no further action is required at this time. Golden Empire
Manufacturing conducts indoor painting operations. The paint booth is equipped with filters to
control particulate emissions, and the filters are replaced as needed. The coatings are applied using
High Volume Low Pressure (HVLP) spray guns for maximum efficiency. The paint equipment, the
pump system, the spray tips, and the spray guns are cleaned with Xylene. Spent Xylene is placed in
barrels and transferred to Safety Kleen for offsite disposal. The Vapor Pressure of Xylene at 20
degrees C is 6.72 mmHg. This is not in compliance with R307-350-7(2), which requires cleaning
solvents to have a composite vapor pressure of 1 mm Hg at 20 degrees Celsius. Golden Empire
Manufacturing is willing to work with their coating and solvent distributor to find a suitable
alternative to Xylene that meets the 1 mm Hg at 20 degrees C requirement. See the SDS of the
coatings and the email communication in the attachment.

EMISSION INVENTORY: Not Applicable. Golden Empire Manufacturing is not required to
submit an Emissions Inventory Report at this time.

The emissions listed below are an estimate of the total potential emissions (PTE) from Golden Empire
Manufacturing Inc. – Brigham City Paint Facility on the Approval Order (AO) DAQE-AN115060007-23,
dated January 25, 2023. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
Particulate Matter - PM10 3.50
Particulate Matter - PM2.5 3.50
Volatile Organic Compounds 34.35

Hazardous Air Pollutant PTE lbs/yr
Generic HAPs (CAS #GHAPS) 38140

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

COMPLIANCE STATUS &
RECOMMENDATIONS: Golden Empire Manufacturing is not in compliance with
R307-350-7(2), which requires cleaning solvents to have a
composite vapor pressure of 1 mm Hg at 20 degrees Celsius,
while the composite vapor pressure of Xylene is 6.72 mmHg at
20 degrees C. No further action is required at this time. Golden
Empire Manufacturing is willing to work with their coating and
solvent distributor to find a suitable alternative to Xylene that
meets the 1 mm Hg at 20 degrees C requirement. See the email
in the attachment.

HPV STATUS: Not Applicable.

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RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots, safety
glasses, and earplugs. Check to make sure Golden Empire
Manufacturing has replaced Xylene with a cleaning solvent
compliant with the vapor composite pressure in R307-350-7(2).

NSR RECOMMENDATIONS: Golden Empire Manufacturing is in the process of adding an
indoor Shot Blaster which will be venting internally upon
completion. Golden Empire Manufacturing responded to NSR
that the Shot Blaster will vent internally. See the email response
in the attachment.

Recommendations from DAQC-300-21 includes the following:

Include a reference to 307-309 applicability for the unpaved 12
acre steel beam storage area south and west of the
manufacturing building; Include the internally-vented Messer
Cutting Systems plasma-cutting table “for informational
purposes.”

ATTACHMENTS: Applicable Supporting Documentation Included