DAQ-2025-002020

DAQE-AN132620009-25

{{$d1 }}

Cody Jones
St. George Steel, LLC
1301 East 700 North
St. George, UT 84770
[e-mail]

Dear Mr. Jones:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN132620008-23 for a
Reduction in Air Pollutants under R307-401-12
Project Number: N132620009

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
29, 2024. St. George Steel, LLC must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Dungan Adams, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well
as the DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

cc: Southwest Utah Public Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 9, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN132620009-25
Administrative Amendment to Approval Order
DAQE-AN132620008-23 for a Reduction in Air
Pollutants under R307-401-12

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
St. George Steel, LLC

Issued On
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Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

April 9, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN132620009-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
St. George Steel, LLC St. George Steel, LLC

Mailing Address Physical Address
1301 East 700 North 1301 East 700 North
St. George, UT 84770 St. George, UT 84770

Source Contact UTM Coordinates
Name: Cody Jones 272,940 m Easting
Phone: [phone] Ext 3326 4,111,320 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3441 (Fabricated Structural Metal)

SOURCE INFORMATION
General Description
St. George Steel, LLC (St. George Steel) owns and operates a steel fabrication facility located in
Washington County. The company welds and cuts large steel shapes to their customer's specifications.
The resulting steel structures are abrasive-blasted and painted. Air pollutants are primarily emitted from
abrasive cleaning and blasting, welding equipment, plasma cutting, and painting operations.

NSR Classification
Administrative Amendment

Source Classification
Located in Attainment Area
Washington County
Airs Source Size: B

Applicable Federal Standards
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

DAQE-AN132620009-25
Page 4

Project Description
St. George Steel has requested to replace one (1) dry plasma cutting table with two (2) wet plasma cutting
tables. The one (1) dry plasma cutting table was incorrectly labeled as "Laser Cutter Table" in the
previous AOs DAQE-AN132620008-23 dated November 2, 2023, and DAQE-AN132620005-12 dated
September 13, 2012.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 180.00
Carbon Monoxide 0 0.01
Nitrogen Oxides 0 0.02
Particulate Matter - PM10 0 0.51
Particulate Matter - PM2.5 0 0.51
Sulfur Dioxide 0 0.00
Volatile Organic Compounds 0 35.00

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 0 1600
Generic HAPs (CAS #GHAPS) 0 1200
Methanol (CAS #67561) 0 3800
Toluene (CAS #108883) 0 18000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 7000
Change (TPY) Total (TPY)
Total HAPs 0 15.80

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]
DAQE-AN132620009-25
Page 5

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]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Steel Fabrication Facility
II.A.2 Abrasive Blasting Operation Control: Baghouse rated at 50 hp II.A.3 High Volume Low Pressure (HVLP) Spray Guns
II.A.4 Metal Inert Gas (MIG) Welding and Cutting II.A.5 One (1) Beamline Plasma Cutter Control: Dust Collector rated at 5 hp
II.A.6 Two (2) Wet Plasma Cutters (New) Control: Water table for each cutter II.A.7 Natural Gas-fired Comfort Heaters *Listed for informational purposes only

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements
DAQE-AN132620009-25
Page 6

II.B.1.a The owner/operator shall not consume more than the following: A. 700 tons of abrasive blasting media per rolling 12-month period B. 12,700 gallons of paint applied by spraying per rolling 12-month period C. 3,600 decatherms of natural gas per rolling 12-month period. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall:
A. Determine consumption by keeping logs of fuel use, paint use, and abrasive blasting media purchased
B. Record consumption on a daily basis

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

D. Keep consumption records for all periods that the facility is in operation.
[R307-401-8]

II.B.1.b The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: A. 35.0 tons per rolling 12-month period of VOCs B. 3.5 tons per rolling 12-month period of Xylene C. 0.8 tons per rolling 12-month period of Ethylbenzene D. 9.0 tons per rolling 12-month period of Toluene E. 1.9 tons per rolling 12-month period of Methanol F. 0.6 tons per rolling 12-month period of all Other HAPs G. 15.8 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.1.b.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]

DAQE-AN132620009-25
Page 7

II.B.1.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]
II.B.1.b.3 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]
II.B.1.c The owner/operator shall use natural gas as a primary fuel for all comfort heaters. [R307-401-8]
II.B.1.d The owner/operator shall store all VOC-containing materials and VOC-laden rags in covered containers, except when in use. [R307-401-8]

II.B.2 Haul Roads and Fugitive Dust Requirements
II.B.2.a Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. [R307-401-8]

II.B.2.a.1 Visible emissions determinations for traffic sources shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8]
II.B.2.b The owner/operator shall comply with the fugitive dust control plan received on January 6, 2010,
for control of all dust sources associated with the source. [R307-401-8]
II.B.3 Welding, Painting, Blasting, and Cutting Requirements
II.B.3.a The owner/operator shall control emissions from each wet plasma cutter using a water table. A
water table shall be used during all periods of wet plasma cutting. [R307-401-8]

II.B.3.b Visible emissions from the painting, welding, and laser cutter operations shall not exceed 10% opacity. [R307-401-8]
II.B.3.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.3.c The owner/operator shall comply with R307-206. Emission Standards: Abrasive Blasting. [R307-401-8]
DAQE-AN132620009-25
Page 8

II.B.3.d The owner/operator shall vent the exhaust from abrasive blasting operation through a baghouse. The baghouse shall be in operation during all periods of abrasive blasting. [R307-401-8] II.B.3.d.1 The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the abrasive blasting operation equipment baghouse. Static pressure
differential across the fabric filter shall be between 2 to 4 inches of water column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The reading shall be accurate to within plus or minus 1.0 inch of water column. The instrument
shall be calibrated according to the manufacturer's instructions. [R307-401-8]
II.B.3.e The owner/operator shall maintain the self-cleaning cartridge filter dust filtration system as specified by the manufacturer for proper function. Dust that is removed from the air stream that collects in the system's container shall be periodically emptied. The air filter shall be replaced frequently enough to prevent the automatic flow alarm from sounding and the unit from shutting down. The flow setting for the filtration system set by the manufacturer shall not be altered to prevent the alarm from sounding or the unit shutting down. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN132620008-23 dated November 2, 2023 Is Derived From NOI dated October 29, 2024 Incorporates Additional Information dated October 31, 2024 Incorporates Additional Information dated November 8, 2024 Incorporates Additional Information dated January 30, 2025

DAQE-AN132620009-25
Page 9

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-
RN132620009 March 14, 2025 Mike Housley St. George Steel, LLC 1301 East 700 North St. George, UT 84770 [e-mail] Dear Mike Housley, Re: Engineer Review: Administrative Amendment to Approval Order DAQE-AN132620008-23 for a Reduction in Air Pollutants under R307-401-12 Project Number: N132620009 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. St. George Steel, LLC should complete this review within 10 business days of receipt. St. George Steel, LLC should contact Dungan Adams at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If St. George Steel, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If St. George Steel, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 1
UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW
SOURCE INFORMATION Project Number N132620009 Owner Name St. George Steel, LLC Mailing Address 1301 East 700 North St. George, UT, 84770 Source Name St. George Steel, LLC Source Location 1301 East 700 North St. George, UT 84770 UTM Projection 272,940 m Easting, 4,111,320 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3441 (Fabricated Structural Metal) Source Contact Mike Housley Phone Number [phone] Email [e-mail] Billing Contact Mike Housley Phone Number [phone] Email [e-mail] Project Engineer Dungan Adams, Engineer Phone Number [phone] Email [e-mail] Notice of Intent (NOI) Submitted October 29, 2024 Date of Accepted Application January 17, 2025

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 2
SOURCE DESCRIPTION General Description St. George Steel, LLC (St. George Steel) owns and operates a steel fabrication facility located in Washington County. The company welds and cuts large steel shapes to their customer's specifications. The resulting steel structures are abrasive-blasted and painted. Air pollutants are primarily emitted from abrasive cleaning and blasting, welding equipment, plasma cutting, and painting operations. NSR Classification: Administrative Amendment Source Classification Located in Attainment Area Washington County Airs Source Size: B Applicable Federal Standards 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 Project Proposal Administrative Amendment to Approval Order DAQE-AN132620008-23 for a Reduction in Air Pollutants under R307-401-12 Project Description St. George Steel has requested to replace one (1) dry plasma cutting table with two (2) wet plasma cutting tables. The one (1) dry plasma cutting table was incorrectly labeled as "Laser Cutter Table" in previous the AOs DAQE-AN132620008-23 dated November 2, 2023 and DAQE-AN132620005-12 dated September 13, 2012. EMISSION IMPACT ANALYSIS No emissions will increase from this equipment replacement. All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are below their respective emission threshold values in R307-410-5. Therefore, no modeling is required for this amendment. [Last updated January 14, 2025]

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 3
SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 180.00
Carbon Monoxide 0 0.01 Nitrogen Oxides 0 0.02 Particulate Matter - PM10 0 0.51 Particulate Matter - PM2.5 0 0.51
Sulfur Dioxide 0 0.00 Volatile Organic Compounds 0 35.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 0 1600
Generic HAPs (CAS #GHAPS) 0 1200 Methanol (CAS #67561) 0 3800 Toluene (CAS #108883) 0 18000 Xylenes (Isomers And Mixture) (CAS #1330207) 0 7000 Change (TPY) Total (TPY)
Total HAPs 0 15.80 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding St. George Steel Fabrication Facility The project does not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant. Therefore, BACT analysis is not required. [Last updated January 14, 2025]
SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
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]

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 5
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Steel Fabrication Facility II.A.2 Abrasive Blasting Operation Control: Baghouse rated at 50 hp
II.A.3 High Volume Low Pressure (HVLP) Spray Guns II.A.4 Metal Inert Gas (MIG) Welding and Cutting II.A.5 One (1) Beamline Plasma Cutter Control: Dust Collector rated at 5 hp
II.A.6 Two (2) Wet Plasma Cutters (New) Control: Water table for each cutter
II.A.7 Natural Gas-fired Comfort Heaters *Listed for informational purposes only
SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 The St. George Steel Facility shall be subject to the following
II.B.1.a The owner/operator shall not consume more than the following: A. 700 tons of abrasive blasting media per rolling 12-month period
B. 12,700 gallons of paint applied by spraying per rolling 12-month period C. 3,600 decatherms of natural gas per rolling 12-month period. [R307-401-8]

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 6
II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Determine consumption by keeping logs of fuel use, paint use, and abrasive blasting
media purchased B. Record consumption on a daily basis C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months D. Keep consumption records for all periods that the facility is in operation. [R307-401-8] II.B.1.b The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: A. 35.0 tons per rolling 12-month period of VOCs B. 3.5 tons per rolling 12-month period of Xylene C. 0.8 tons per rolling 12-month period of Ethylbenzene D. 9.0 tons per rolling 12-month period of Toluene E. 1.9 tons per rolling 12-month period of Methanol
F. 0.6 tons per rolling 12-month period of all Other HAPs G. 15.8 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.1.b.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.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 7
II.B.1.b.3 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] II.B.1.c The owner/operator shall use natural gas as a primary fuel for all comfort heaters. [R307-401-8] II.B.1.d The owner/operator shall store all VOC-containing materials and VOC-laden rags in covered containers, except when in use. [R307-401-8] II.B.2 Haul Roads and Fugitive Dust Sources shall be subject to the following II.B.2.a Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. [R307-401-8] II.B.2.a.1 Visible emissions determinations for traffic sources shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8] II.B.2.b The owner/operator shall comply with the fugitive dust control plan received on January 6, 2010, for control of all dust sources associated with the source. [R307-401-8] II.B.3 Welding, Painting, Blasting, and Cutting operations shall be subject to the following
II.B.3.a The owner/operator shall control emissions from each wet plasma cutter using a water table. A water table shall be used during all periods of wet plasma cutting. [R307-401-8] II.B.3.b Visible emissions from the painting, welding, and laser cutter operations shall not exceed 10% opacity. [R307-401-8] II.B.3.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.3.c The owner/operator shall comply with R307-206. Emission Standards: Abrasive Blasting. [R307-401-8]
Commented [DA1]: Condition requiring water table for control.

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 8
II.B.3.d The owner operator shall vent the exhaust from abrasive blasting operation a baghouse. The baghouse shall be in operation during all periods of abrasive blasting. [R307-401-8] II.B.3.d.1 The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the abrasive blasting operation equipment baghouse. Static pressure differential across the fabric filter shall be between 2 to 4 inches of water column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The reading shall be accurate to within plus or minus 1.0 inch of water column. The instrument shall be calibrated according to the manufacturer's instructions. [R307-401-8] II.B.3.e The owner/operator shall maintain the self-cleaning cartridge filter dust filtration system as specified by the manufacturer for proper function. Dust that is removed from the air stream that collects in the system's container shall be periodically emptied. The air filter shall be replaced frequently enough to prevent the automatic flow alarm from sounding and the unit from shutting down. The flow setting for the filtration system set by the manufacturer shall not be altered to prevent the alarm from sounding or the unit shutting down. [R307-401-8]

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN132620008-23 dated November 2, 2023 Is Derived From NOI dated October 29, 2024 Incorporates Additional Information dated October 31, 2024 Incorporates Additional Information dated November 8, 2024 Incorporates Additional Information dated January 30, 2025
REVIEWER COMMENTS 1. Comment regarding Reduction in Air Pollutants: St. George Steel has requested to replace one (1) dry plasma cutting table with two (2) wet plasma cutting tables. The dry plasma table that has been replaced was incorrectly labeled as "Laser Cutter Table" (Condition II.A.7 in DAQE-AN132620008-23) in the previous AO. The source has also requested that the "Automated Laser Cutter" (Condition II.A.6 in DAQE-AN132620008-23) be updated to "Beamline Plasma Cutter" to more accurately describe the equipment. Emission estimates use cutting parameters provided by the source and PM10/2.5 and NOx emission factors from "Emission of Fume, Nitrogen Oxides and Noise in Plasma Cutting of Stainless and Mild Steel" by Broman B. et al, The Swedish Institute of Production Engineering Research, ITW Document 1E-174-93, March 1994. The two (2) wet plasma cutting tables combined are estimated to produce 0.06 tons per year (tpy) of PM10 and PM2.5 and 0.64 tpy of NOx. The one (1) dry plasma cutting table was estimated to produce 0.06 tpy of PM10 and PM2.5 and 2.79 tpy of NOx using the same cutting parameters. Because this equipment change does not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant this qualifies for a Reduction in Air Pollutants under UAC Code R307-401-12. Because the existing Summary of Emissions suggests the facility produces 0.02 tpy of NOx, substantially less than the 2.79 tpy of NOx estimated from the old dry plasma cutting table, the Summary of Emissions has not been changed. The DAQ recommends that the source recalculate site-wide emissions next AO modification. [Last updated February 5, 2025] 2. Comment regarding Federal Subpart Applicability: NSPS Subpart SS The facility is not subject to 40 CFR 60, Subpart SS (Standards of Performance for Industrial Surface Coating: Large Appliances). The provisions of NSPS Subpart SS only apply to facilities which produce large appliance products. Large appliance products include any metal range, oven, microwave oven, refrigerator, freezer, washer, dryer, dishwasher, water heater, or trash compactor manufactured for household, commercial, or recreational use. These products are not manufactured at the St. George Steel Facility MACT Subpart MMMM The facility is not subject to 40 CFR 63, Subpart MMMM (National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products). The

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 10
provisions of MACT Subpart MMMM only apply to major sources. MACT Subpart NNNN The facility is not subject to 40 CFR 63, Subpart NNNN (National Emission Standards for Hazardous Air Pollutants: Surface Coating of Large Appliances). The provisions of MACT Subpart NNNN only apply to major sources. MACT Subpart XXXXXX The facility is subject to 40 CFR 63, Subpart XXXXXX (National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories). The provisions of MACT Subpart XXXXXX apply to area sources engaging in the operations of one of nine source categories, including fabricated metal products. Metal fabrication or finishing operations means dry abrasive blasting, machining, spray painting, or welding. Since these operations occur, the facility is subject to the subpart. [Last updated January 14, 2025] 3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. This facility is not subject to 40 CFR 60 (NSPS) regulations or 40 CFR 61 (NESHAP) regulations. The facility is subject to 40 CFR 63 (MACT) Subpart XXXXXX, however this subpart specifically exempts the source from obtaining a Title V permit. Therefore, Title V does not apply to this source. [Last updated January 14, 2025]

Engineer Review N132620009: St. George Steel, LLC January 21, 2025 Page 11
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds
Metal Density (Mild Steel)0.283 lb/in^3 Metal Density (Mild Steel)
Cut Thickness 0.25 in Cut Thickness
Kerf 0.125 in Kerf
Cut Speed 130 in/min Cut Speed
Cut Speed 7,800 in/hr Cut Speed
Annual Hours of Operation 4,680 hours/year Annual Hours of Operation
PM2.5/PM10 EF 0.1 g/min PM2.5/PM10 EF
PM2.5/PM10 EF 0.0132 lb/hr PM2.5/PM10 EF
Control Efficency 0 %Control Efficency
PM2.5/PM10 Emissions 0.03 ton/year PM2.5/PM10 Emissions
NOx EF 0.5 l/min NOx EF
NOx EF 1.025 g/min NOx EF
NOx Emissions 0.1356 lb/hr NOx Emissions
NOx Emissions 0.32 ton/year NOx Emissions
Nitrogen Oxide 46 g/mol
Nitrogen Oxide 2.05 g/l
In 2022, St. George Steel replaced a 25 plasma table with baghouse control (II.A.7 in DAQE-
AN136260008-23) with a 30' plasma table with water table control An existing 40' plasma table
Operating Parameters of 30' Plasma Cutter w/ Water Table Operating Parameters of 40
0.283 lb/in^3 Metal Density (Mild Steel)0.283 lb/in^3
0.25 in Cut Thickness 0.25 in
0.125 in Kerf 0.125 in
130 in/min Cut Speed 130 in/min
7,800 in/hr Cut Speed 7,800 in/hr
4,680 hours/year Annual Hours of Operation 4,680 hours/year
0.1 g/min PM2.5/PM10 EF 20 g/min
0.0132 lb/hr PM2.5/PM10 EF 2.6455 lb/hr
0 %Control Efficency 99 %
0.03 ton/year PM2.5/PM10 Emissions 0.06 ton/year
0.5 l/min NOx EF 4.4 l/min
1.025 g/min NOx EF 9.02 g/min
0.1356 lb/hr NOx Emissions 1.1931 lb/hr
0.32 ton/year NOx Emissions 2.79 ton/year
0' Plasma Cutter w/ Water Table Operating Parameters of 25' Plasma Cutter w/ Filter
Dungan Adams <[e-mail]>
RE: Air Quality Inspection - Additional Information Required
27 messages
Mike Housley <[e-mail]>Tue, Oct 29, 2024 at 2:10 PM
To: Connor Kijowski <[e-mail]>
Cc: Cody Jones <[e-mail]>, Dungan Adams <[e-mail]>
Connor
I did reach out to Dungan Adams and left a message. I gave him my cell phone number so he can easily
return my call to discuss the best method forward.

Also attached is our formal reply so that you can recognize our response.
I don’t have Mr. Gilgen email so I will mail a copy of this as well.

Let me know if you have any questions or suggestions.

Best regards

Mike Housley
Managing Partner
T: [phone] ext. 3325
C: [phone]
E: [e-mail]
W. www.stgeorgesteel.com
1301 East 700 North, St. George, UT 84770

1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…1/12
From: Connor Kijowski <[e-mail]>
Sent: Thursday, October 24, 2024 3:18 PM
To: Mike Housley <[e-mail]>
Subject: Re: Air Quality Inspecon - Addional Informaon Required

Mike,

Attached is the Compliance Advisory as mentioned in my previous email. There will also be a hard copy sent via USPS.

To begin the permitting process and resolve the compliance advisory, reach out to Dungan Adams, your assigned
engineer from the Division of Air Quality. Inform him that you received this compliance advisory and would like assistance
to submit a Notice of Intent to receive an updated Approval Order. If you reach out via email, include me in that
correspondence. His contact information is below:

[e-mail]
385-290-2474

Please respond to this email and reach out to Dungan within 10 business days. If you have any questions, feel free to
contact me and I'd be happy to assist.

Best,
Connor Kijowski

On Thu, Sep 26, 2024 at 1:08 PM Mike Housley <[e-mail]> wrote:
Connor I will review and get back to you
Thanks

Mike Housley

Sent from my Verizon, Samsung Galaxy smartphone
Get Outlook for Android

From: Connor Kijowski <[e-mail]>
Sent: Thursday, September 26, 2024 10:48:03 AM
To: Mike Housley <[e-mail]>
Subject: Air Quality Inspection - Additional Information Required
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…2/12

Good Morning Mike,

I have some follow up questions from my air quality inspection on July 11th. It relates to the recently installed plasma
cutters/water table systems that were discovered during the site visit to replace the laser cutters found in Condition
II.A.6 of your current air permit (attached for your reference).

My manager brought to my attention that these plasma cutters need to be evaluated by our permitting team to verify if
they need to be included on an updated permit as they may lead to emissions in excess of what is allotted in your
current air permit.

To formally start this process, I will issue a compliance advisory letter. This letter is essentially an official request for
additional information and you can email a response directly to me. Look for this letter in the next week or so and we
can go from there. I am happy to discuss this via phone as well if you have any questions.

Thank you,

--
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov

--
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…3/12
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov

SGS Compliance Advisory Response.docx
34K
Mike Housley <[e-mail]>Tue, Oct 29, 2024 at 2:22 PM
To: Connor Kijowski <[e-mail]>
Cc: Cody Jones <[e-mail]>, Dungan Adams <[e-mail]>
Connor
Sorry, here is a signed copy

Thanks
Mike Housley
[Quoted text hidden]
SGS Complaince Advisory Response .pdf
44K
Dungan Adams <[e-mail]>Tue, Oct 29, 2024 at 4:08 PM
To: Connor Kijowski <[e-mail]>
Cc: Mike Housley <[e-mail]>, Cody Jones <[e-mail]>
Hi Connor,
I just spoke with Mike and wanted to make sure everyone is on the same page about the required action for St. George
Steel.
Based on my conversation with Mike, it sounds like the plasma cutter equipment change made in 2022 resulted in an
emission reduction. The current Approval Order also has some equipment language which needs to be updated. Is there
any other action that needs to be addressed from compliance? Unless there are other concerns that you bring up, my
plan is to get emission calculations for the new equipment and start an Administrative Amendment project for a Reduction
In Air Pollutants (R307-401-12).
Thanks,
Dungan
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…4/12
[Quoted text hidden]
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Connor Kijowski <[e-mail]>Tue, Oct 29, 2024 at 4:27 PM
To: Dungan Adams <[e-mail]>
Cc: Mike Housley <[e-mail]>, Cody Jones <[e-mail]>
Hi Dungan,
That sounds good; I believe this addresses all the items related to the compliance advisory.
Thanks,
Connor
[Quoted text hidden]
Connor Kijowski <[e-mail]>Tue, Oct 29, 2024 at 4:28 PM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>, Dungan Adams <[e-mail]>
Received. Thanks, Mike. You do not need to mail a hard copy to Mr. Gilgen. I will pass it along via email.
Thanks,
Connor
[Quoted text hidden]
Mike Housley <[e-mail]>Tue, Oct 29, 2024 at 4:30 PM
To: Connor Kijowski <[e-mail]>
Cc: Cody Jones <[e-mail]>, Dungan Adams <[e-mail]>
Thanks Connor.
I think It is already out in the mail 😊

Best regards
Mike Housley

From: Connor Kijowski <[e-mail]>
Sent: Tuesday, October 29, 2024 4:29 PM
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…5/12
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>; Dungan Adams <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
Connor Kijowski <[e-mail]>Tue, Oct 29, 2024 at 4:31 PM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>, Dungan Adams <[e-mail]>
You're too quick! Thanks, Mike.
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Oct 30, 2024 at 2:18 PM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>, Connor Kijowski <[e-mail]>
Hi Mike,
The main thing I need to update St. George Steel's (SGS) permit is emission estimates of the plasma cutters. However,
before we get to the emission estimates, I want to determine what equipment is currently on site and make sure it is
labeled correctly. This is currently the equipment list in SGS's AO:
1. Abrasive Blasting Operation
Baghouse manufactured by Hoffman, rated at 50 hp
2. High Volume Low Pressure (HVLP) Spray Guns
3. Natural Gas-fired Comfort Heaters
4. Metal Inert Gas (MIG) Welding and Cutting
5. Automated Laser Cutter
Cartridge filter unit
6. Laser Cutter Table
Baghouse manufactured by Donaldson, rated at 15 hp

Please advise how this equipment list should be updated-- we want this list to accurately reflect the equipment on site and
use whatever naming you think is most appropriate.
Regarding the equipment replacement that occured in 2022, I believe the original plasma cutter (incorrectly labeled as the
automated laser cutter with cartridge filter unit) was replaced with a new plasma cutter with a water table. Is this correct?
Thanks,
Dungan
[Quoted text hidden]
[Quoted text hidden]
Mike Housley <[e-mail]>Thu, Oct 31, 2024 at 8:36 AM
To: Dungan Adams <[e-mail]>
Cc: Cody Jones <[e-mail]>, Connor Kijowski <[e-mail]>
Dungan
I went out and got some specific information on the equipment so we can label it correctly in the updated
documents.
Hopefully this will correct the language on the AO. I did my best to specify the correct description.

Thank you for your help in this matter.

1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…6/12
Let me know if you have any questions

Best regards
Mike Housley

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 30, 2024 2:19 PM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>; Connor Kijowski <[e-mail]>
Subject: Re: Air Quality Inspecon - Addional Informaon Required

Hi Mike,

The main thing I need to update St. George Steel's (SGS) permit is emission estimates of the plasma cutters. However,
before we get to the emission estimates, I want to determine what equipment is currently on site and make sure it is
labeled correctly. This is currently the equipment list in SGS's AO:

1. Abrasive Blasting Operation
Baghouse manufactured by Hoffman, rated at 50 hp
Abrasive Blasting Operation, Dust Collector, Cartridge Hoffman, 50 HP
2. High Volume Low Pressure (HVLP) Spray Guns OK
3. Natural Gas-fired Comfort Heaters OK
4. Metal Inert Gas (MIG) Welding and Cutting OK
5. Automated Laser Cutter
Cartridge filter unit
Plasma Cutter (At Beamline)
Dust Collector, Cartridge Donaldson 5 HP
6. Laser Cutter Table
Plasma Cutter 46’ with a water table.
Plasma Cutter 30’ with water table
[Quoted text hidden]
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Oct 31, 2024 at 2:07 PM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>, Connor Kijowski <[e-mail]>
Mike,
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…7/12
I want to confirm that the facility operates three (3) plasma cutters in total: one (1) with dust collector control and two (2)
with water table control.
Can you also explain specifically what equipment was replaced in 2022?
Thanks,
Dungan
[Quoted text hidden]
Mike Housley <[e-mail]>Thu, Oct 31, 2024 at 9:07 PM
To: Dungan Adams <[e-mail]>
Cc: Cody Jones <[e-mail]>, Connor Kijowski <[e-mail]>
Dungan
That is correct.
We replaced a 25’ plasma table that had a dust collection system. I believe it had a HP baghouse . I still
have the baghouse, but we don’t have a use for it. We will probably just sell it. This table and contents have
been disposed of.

In 2022, We put in a 30’ Plasma system in its place and put the water table under that one. The machine
was dormant for about a year while we get it set up and operational.

Let me know if you have any further questions
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Nov 1, 2024 at 1:11 PM
To: Connor Kijowski <[e-mail]>
Hey Connor,
Could you send me the compliance evaluation from your inspection on July 11, 2024 and the compliance advisory
(DAQC-1066-24) when you get the chance? I wasn't able to find either in laserfiche.
Thanks,
Dungan
[Quoted text hidden]
Connor Kijowski <[e-mail]>Fri, Nov 1, 2024 at 1:17 PM
To: Dungan Adams <[e-mail]>
Sure, no problem. Here are those documents. The compliance evaluation hasn't been approved yet so that is why it is not
in Laserfische and I am only attaching the draft document. I am unsure why the Compliance Advisory hasn't been
uploaded yet. Let me know if you need anything else.
Thanks,
Connor
[Quoted text hidden]
DAQC-CI132620001-24.pdf
4021K
Connor Kijowski <[e-mail]>Fri, Nov 1, 2024 at 1:17 PM
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…8/12
To: Dungan Adams <[e-mail]>
Sorry here's the compliance advisory as well.
[Quoted text hidden]
C-1066-24 - signed.pdf
405K
Dungan Adams <[e-mail]>Fri, Nov 1, 2024 at 1:20 PM
To: Connor Kijowski <[e-mail]>
Thanks!
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Nov 7, 2024 at 12:35 PM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>
Hi Mike,
I think it will be relatively straightforward to show that the new plasma cutter with the water table produces less emissions
than the plasma cutter with the baghouse that was replaced. Since compliance missed this equipment replacement for a
few years and only recently determined this was a compliance issue, I can do all of the emission calculations showing that
this equipment change qualifies for a reduction in air pollutants.
Can you provide estimates of the follow for the current 30' plasma cutter with water table:
- Type of steel cut (mild, stainless, something else)
- Thickness of steel cut
- Kerf / width of cut
- Cutting speed
- Annual hours of operation of plasma cutter
Since the equipment change was made many years ago, I am going to assume that the old and new plasma cutters had
roughly the same operating parameters. If you know that they were dramatically different, please let me know. Also, let me
know if you have any questions or if you are struggling to estimate any of these values.
Thanks,
Dungan
[Quoted text hidden]
Mike Housley <[e-mail]>Fri, Nov 8, 2024 at 8:33 AM
To: Dungan Adams <[e-mail]>
Cc: Cody Jones <[e-mail]>
Dungan
I talked to our operators here and this is what we have on the Plasma tables

Both tables (30’ and 40’) run on the same parameters.

-The water tables cuts mild steel 85% and Stainless Steel 15%
-Thickness cut between 1/8” and 1”. (mostly ¼” and the average is ¼“)
- Cut kerf is 1/8”
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:18142803951711845…9/12
- Cut speed is 110 – 150 inches per minute (varies based on amp setting). The average is 130
inches per minute.
- Annual hours of plasma operation = 4,680 hours per table (18 hrs/day x 5 days/wk x 52
wks/yr) The actual number of hours that the plasma is cutting is much less than this, but the
plasma cutter could be on this many hours.

Let me know if you need more from me.
I am traveling next week but will check email each night and reply as soon as possible.
[Quoted text hidden]
Connor Kijowski <[e-mail]>Fri, Nov 8, 2024 at 10:28 AM
To: Dungan Adams <[e-mail]>
Hey Dungan,
Can you let me know when you determine whether this equipment change qualifies for a reduction in pollutants or if a new
AO is necessary so I can close out the Compliance Advisory?
Thanks!
Connor
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Nov 8, 2024 at 11:21 AM
To: Connor Kijowski <[e-mail]>
Connor,
I just got some operating parameters for the plasma cutter and spoke with Mike Housley at St. George Steel. The
replacement of the plasma cutter with a baghouse (II.A.7 in AO DAQE-AN13262008-23) with a plasma cutter with a water
table should not result in any emission increase and therefore would qualify for a reduction in air pollutants.
I will let you know if anything changes, but I am working on emission calculations now and then will update the active AO
DAQE-AN13262008-23 under an administrative amendment.
Thanks,
Dungan
[Quoted text hidden]
Connor Kijowski <[e-mail]>Fri, Nov 8, 2024 at 11:23 AM
To: Dungan Adams <[e-mail]>
Okay, thanks. I really appreciate the update.
[Quoted text hidden]
Mike Housley <[e-mail]>Thu, Jan 2, 2025 at 11:27 AM
To: Dungan Adams <[e-mail]>
Cc: Cody Jones <[e-mail]>
Dungan
Happy new year.

I wanted to circle back and see if this is completed or if there is more to do to get it closed out.
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:1814280395171184…10/12
It seems like last we spoke you said you had what you needed but I haven’t seen anything more.

Let me know when you get a chance to review and advise next steps if any.

Best regards

Mike Housley
Managing Partner
T: [phone] ext. 3325
C: [phone]
E: [e-mail]
W. www.stgeorgesteel.com
1301 East 700 North, St. George, UT 84770

[Quoted text hidden]
Connor Kijowski <[e-mail]>Thu, Jan 2, 2025 at 1:44 PM
To: Dungan Adams <[e-mail]>
Hey Dungan,
Can you provide an update on the status of this administrative amendment?
Thanks!
Connor
On Fri, Nov 8, 2024 at 11:22 AM Dungan Adams <[e-mail]> wrote:
[Quoted text hidden]
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Jan 14, 2025 at 11:55 AM
To: Alan Humpherys <[e-mail]>
Hi Alan,
Compliance just reminded me about this Administrative Amendment project for St. George Steel to address a compliance
advisory that I had forgotten about. Could you set up the project when you get the chance. The Site ID is 13262.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Jan 14, 2025 at 11:57 AM
To: Connor Kijowski <[e-mail]>
1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1814280395171184570&simpl=msg-f:1814280395171184…11/12
Hi Connor,
Thanks for following up, this project fell off my radar. I believe I have everything I need from Mike and SGS and I will get
the amendment wrapped up quickly.
Thanks,
Dungan
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Dungan Adams <[e-mail]>Tue, Jan 14, 2025 at 11:58 AM
To: Mike Housley <[e-mail]>
Cc: Cody Jones <[e-mail]>
Hi Mike,
I believe I have everything I need and I will let you know if any questions or concerns arise. Thanks for your patience.
Thanks,
Dungan
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Alan Humpherys <[e-mail]>Tue, Jan 14, 2025 at 1:35 PM
To: Dungan Adams <[e-mail]>
I've assigned Tim as the peer. Please let me know if you have any questions.
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--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Connor Kijowski <[e-mail]>Wed, Jan 15, 2025 at 6:18 AM
To: Dungan Adams <[e-mail]>
No problem. Thanks for the update!
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1/21/25, 4:09 PM State of Utah Mail - RE: Air Quality Inspection - Additional Information Required
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