DAQ-2025-000189

DAQE-AN107940040-25

{{$d1 }}

Jared Ellison
McWane Ductile - Utah
2550 South Industrial Parkway
Provo, UT 84606
[e-mail]

Dear Mr. Ellison:

Re: Approval Order: Modification of Approval Order DAQE-AN107940038-23 to Replace Cast
Machine
Project Number: N107940040

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
21, 2024. McWane Ductile - Utah must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Jacob Hurley, 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:JH:jg

cc: Utah County Health Department
EPA Region 8

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

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

January 8, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN107940040-24
Modification of Approval Order DAQE-AN107940038-23
to Replace Cast Machine

Prepared By
Jacob Hurley, Engineer
[phone]
[e-mail]

Issued to
McWane Ductile – Utah

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

January 8, 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 ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-AN107940040-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
McWane Ductile - Utah McWane Ductile – Utah

Mailing Address Physical Address
2550 South Industrial Parkway 2550 South Industrial Parkway
Provo, UT 84606 Provo, UT 84606

Source Contact UTM Coordinates
Name: Christy Seiger-Webster 446,300 m Easting
Phone: [phone],449,800 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 3321 (Gray & Ductile Iron Foundries)

SOURCE INFORMATION
General Description
McWane Ductile - Utah (MDU) produces various sizes of ductile iron products in Utah County that are
used in water distribution and infrastructure systems. The ductile iron production process includes
melting, core preparation, casting, annealing, lining, coating, and special lining operations. MDU is a
major source of PM2.5, CO, and VOC.

NSR Classification
Administrative Amendment

Source Classification
Located in Southern Wasatch Front O3 NAA, Utah County PM10 Maintenance Area, Provo UT PM2.5
NAA
Utah County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN107940040-25
Page 4

MACT (Part 63), ZZZZZ: National Emission Standards for Hazardous Air Pollutants for Iron
and Steel Foundries Area Sources
Title V (Part 70) Major Source

Project Description
MDU has notified intent to replace an existing casting machine with a new casting machine. The existing
equipment will be disposed of as scrap, and the casting process will stay the same. The casting machines
are used to produce ductile iron products such as pipes and utility pole sections.

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 136037.92
Carbon Monoxide 0 116.94
Nitrogen Oxides 0 87.04
Particulate Matter - PM10 0 84.01
Particulate Matter - PM10 (Fugitives) 0 39.45
Particulate Matter - PM2.5 0 79.24
Particulate Matter - PM2.5 (Fugitives) 0 34.70
Sulfur Dioxide 0 36.58
Volatile Organic Compounds 0 174.69

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 8561
Methanol (CAS #67561) 0 31
Naphthalene (CAS #91203) 0 490
Phenol (CAS #108952) 0 275
Xylenes (Isomers And Mixture) (CAS #1330207) 0 3440
Change (TPY) Total (TPY)
Total HAPs 0 6.40

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]
DAQE-AN107940040-25
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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 five-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 five years. [R307-415-6b] 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 of the new equipment in Section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Provo Manufacturing Plant Plant Wide
II.A.2 Cupola Including activated carbon injection system, baghouse, and CO burner system II.A.3 Desulfurization System Includes fume hood with baghouse
II.A.4 Ductile Treatment System Includes fume hood with baghouse II.A.5 Annealing Oven Used for seal-coat removal: single top-discharge stack
II.A.6 Core Sand Silo Control: bin vent II.A.7 Charge Handling and Casting Operations (NEW) Includes casting operations baghouse & five casting machines
DAQE-AN107940040-25
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II.A.8 Three Natural Gas-Fired Heaters Two 3.0 MMBtu/hr heaters - one each in the pipe drying and pipe curing areas One 2.0 MMBtu/hr heater in the pipe curing area II.A.9 Cement Lining Cement Silo
Control: bin vent
II.A.10 Cement Lining Sand Silos Two silos Control: bin vents II.A.11 Pipe Coating
Control: dry filter pads
II.A.12 Special Lining Shot Blasts Control: baghouse II.A.13 Special Lining Application

II.A.14 Special Lining Painter II.A.15 Reagent Silo for Cupola Baghouse
Control: bin vent

II.A.16 Cooling Towers Associated with compressors 10, 11, 12, and three cooling towers associated with casting machines identified in II.A.7 II.A.17 Diesel-Fired Emergency Recuperator Generator
550 hp emergency generator

II.A.18 Portable Limespar Silos
II.A.19 Hot-Box Core Making

II.A.20 Poles Building Includes: painting controlled by paint arrestor filters, wet cutting and drilling, and welding
II.A.21 Pole Flange Saw Building Includes: pole flange saw and baghouse

II.A.22 Pipe Cleaning Oven Blow Out Control: cyclone/baghouse for pipe cleaning system
II.A.23 Miscellaneous Equipment
Includes: storage piles; pipe cutting, grinding, and welding (saw rail and welding area baghouse);
and hot metal transfer

II.A.24 Natural Gas-Fired Generators Three miscellaneous natural gas-fired emergency generators Ratings: 32.8 bhp 27 bhp 10.06 bph (7.5 kW)
DAQE-AN107940040-25
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II.A.25 Diesel-Fired Emergency Generator Cummins 464 hp emergency generator II.A.26 Zinc Thermal Spray Process Control: cartridge collector baghouse

II.A.27 Cold-Cure Core Making Controls: bin vent and packed-bed scrubber

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Source Wide Conditions
II.B.1.a The owner/operator shall not exceed the following production and/or consumption limits: A. 85 tons of iron melted per hour B. 205,000 tons of iron melted per rolling 12-month period C. 18 hours of operation of special lining operations and hot-box core-making process per day D. 3,012.5 hours of operation of the hot-box core making process per rolling 12-month period E. 15.9 pounds of seal-coat removed per day, and 1,850 pounds of seal-coat removed per rolling 12-month period F. 63.29 MMBtu/hr maximum heat input into the annealing oven furnace G. 3,241 tons of zinc wire used in the zinc coating process per rolling 12-month period. [R307-401-8]
DAQE-AN107940040-25
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II.B.1.a.1 To demonstrate compliance with these limits, the owner/operator shall maintain a production log as follows: A. The amount of seal-coat removed in the annealing oven shall be recorded each day B. Production/consumption shall be determined by daily plant production records C. Records of production/consumption shall be kept for all periods when the plant is in operation D. The records of production/consumption shall be kept on a daily basis E. For the hourly limitation, the recorded daily production value shall be divided by the operating hours of the day and compared to the limitation F. Monthly totals shall be determined as of the 20th day of each month. Each month's total shall be added to the previous 11 months' total to determine a 12-month rolling total G. Total heat input shall be determined by an hourly gas flow meter, natural gas vendor supplier records, and/or the owner/operator's own testing. [R307-401-8]
II.B.1.b Visible emissions from the following emission points shall not exceed the following values:
A. All baghouses - 10% opacity
B. Casting area hoods fugitive emissions - 15% opacity

C. 10% opacity at the property boundary
D. 20% for all diesel-fired emergency generators
E. All other points - 15% opacity.

[40 CFR 60]
II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Opacity observations of emissions from fugitive sources shall be conducted according to 58 FR 61640 Method 203A. [40 CFR 60]
II.B.1.c The owner/operator shall comply with R307-309, Nonattainment and Maintenance Areas for
PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. The owner/operator shall comply with its latest FDCP. [R307-309]

II.B.1.d The owner/operator shall adhere to the following limits: A. Emissions of VOCs to the atmosphere from the cupola, product coating, and related operations shall not exceed 174.69 tons per rolling 12-month period B. Emissions of all HAPs to the atmosphere from the cupola, product coating, and related operations shall not exceed 6.39 tons per rolling 12-month period. [R307-401-8]
DAQE-AN107940040-25
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II.B.1.d.1 Compliance with each limitation shall be determined on a rolling 12-month total. By the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months. The VOC and HAP emissions from pipe coating and associated operations shall be determined by maintaining a record of VOC- and HAP-emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC- and HAPs-emitting material, such as pipe coatings B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC and HAP in each material used D. Gallons of each VOC- and HAP-emitting material used E. The amount of VOC and individual HAP emitted monthly by each material used shall be calculated by the following procedure or equivalent method approved by the Director: VOC = [% VOC by Weight]/100 x [Density (lb/gal)] x [Gal Consumed x (1 ton/2000 lb)] HAP = [% HAP by Weight]/100 x [Density (lb/gal)] x [Gal Consumed x ( 1 ton/2000 lb)] F. The total amount of VOC or HAP emitted monthly from all materials used G. The amount of VOC and HAP emitted monthly from combustion processes shall be estimated based on production or operations data. The amount of natural gas burned in the cupola combustor shall be quantified each month and multiplied by the latest AP-42 emission factor to determine the monthly cupola VOC emissions H. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. [R307-150]
II.B.2 Conditions on the Cupola
II.B.2.a Emissions of CO to the atmosphere from the cupola baghouse shall not exceed 0.80 lbs/ton of iron melted. [R307-401-8]
II.B.2.a.1 To demonstrate compliance with the CO emission limit, the owner/operator shall conduct emission testing once every two years. The Director may require the owner/operator to perform
an emission test at any time. All stack testing shall be performed as outlined in Section II.B.3.
[R307-165-2, R307-401-8]

II.B.2.b Emissions of NOx to the atmosphere from the cupola baghouse shall not exceed 33 lbs/hr. [R307-401-8]
II.B.2.b.1 To demonstrate compliance with the NOx emission limit, the owner/operator shall conduct
emission testing once every two years. The Director may require the owner/operator to perform
an emission test at any time. All stack testing shall be performed as outlined in Section II.B.3.
[R307-165-2, R307-401-8]

DAQE-AN107940040-25
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II.B.2.c Emission of NOx to the atmosphere from the cupola bag house shall not exceed 52 tons per rolling 12 months. By the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months based on the following equation. Total NOx = (SUHR * SUEF) + (SSHR * SSEF) + (SDHR * SDEF) Where: SUHR = hours of startup operation during the most recent 12 months SUEF = emission factor for startup operating phase (2.21 lb/hr) SSHR = hours of steady-state operation during the most recent 12 months SSEF = emission factor for steady-state operating phase. The emission factor shall be set using the most recent stack test. SDHR = hours of shutdown operation during the most recent 12 months. SDEF = emission factor for shutdown operation phase (21.2 lbs/hr) For purposes of this condition, startup, steady-state, and shutdown operating phases shall be monitored and recorded to the nearest tenth of an hour and shall have the following meanings: Startup operating phase means the time period commencing when blast air (that is, high-temperature air applied to initiate burning) is first put to the coke bed and ending with first iron (that is, the time that molten iron is first seen through the tuyeres). Steady-state operating phase means the time period commencing with the first iron and ending when the cupola cap is lowered. Shutdown operating phase means the time period commencing when the cupola cap is lowered and ending when the last iron is taken from the cupola. [R307-401-8]
II.B.2.d Emissions of SO2 to the atmosphere from the cupola baghouse shall not exceed 20.7 lbs/hr. [40 CFR 60, R307-401-8]

II.B.2.d.1 To demonstrate compliance with the SO2 emission limit, the owner/operator shall conduct emission testing once every two years. The Director may require the owner/operator to perform an emission test at any time. All stack testing shall be performed as outlined in Section II.B.3. [R307-165-2, R307-401-8]
DAQE-AN107940040-25
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II.B.2.e Emission of SO2 to the atmosphere from the cupola baghouse shall not exceed 35.58 tons per rolling 12 months. By the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months based on the following equation. Total SO2 = (SUHR * SUEF) + (SSHR * SSEF) + (SDHR * SDEF) Where: SUHR = hours of start-up operation during the most recent 12 months SUEF = emission factor for start-up operating phase (2.5 lb/hr) SSHR = hours of steady-state operation during the most recent 12months SSEF = emission factor for steady-state operating phase. The emission factor shall be set using the most recent stack test. SDHR = hours of shutdown operation during the most recent 12 months SDEF = emission factor for shutdown operation phase (50 lb/hr) For purposes of this condition, start-up, steady-state, and shutdown operating phases shall be monitored and recorded to the nearest tenth of an hour and shall have the following meanings: Start-up operating phase means the time period commencing when blast air (that is, high-temperature air applied to initiate burning) is first put to the coke bed and ending with "first iron" (that is, the time that molten iron is first seen through the tuyeres). Steady-state operating phase means the time period commencing with the first iron and ending when the cupola cap is lowered. Shutdown operating phase means the time period commencing when the cupola cap is lowered and ending when the last iron is taken from the cupola. [R307-401-8] II.B.3 Emission Testing and Monitoring Requirements
II.B.3.a Notification At least 30 days prior to conducting an emission test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include: A. The date, time, and place of the proposed test B. The proposed test methodologies C. The stack to be tested D. The procedures to be used E. Any deviation from an EPA-approved test method F. Explanation of any deviation from an EPA-approved test method If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]
II.B.3.b Testing
The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject emission test data if the test did not follow the approved source test protocol
or if Director was not provided an opportunity to have an observer present at the test.
[R307-165-5, R307-401-8]

DAQE-AN107940040-25
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II.B.3.c Standard Conditions & Emission Limit Parameters A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Concentration (ppmdv) - 3% oxygen, dry basis D. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.3.d Test Conditions The owner/operator shall conduct all tests while the source is operating at no less than 90% of
the maximum production rate achieved in the previous three years, unless otherwise specified in the approved source test protocol. If the desired production rate is not achieved at the time of the
test, the maximum production rate shall be 110% of the tested achieved rate, but not more than
the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. The owner/operator shall request a
higher production rate when necessary. Testing at no less than 90% of the higher rate shall be
conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum allowable production rate is
achieved. During the tests, the owner/operator shall burn fuels or combinations of fuels, use raw
materials, and maintain process conditions representative of normal operations. In addition, the owner/operator shall operate under any other relevant conditions that the Director specifies.
[R307-165-4, R307-401-8]

II.B.3.e Reporting Within 60 days after completing an emission test, the owner/operator shall submit a copy of the test results to the Director. [R307-401-8] II.B.3.f Possible Rejection of Test Results
The Director may reject emissions test data if they are determined to be incomplete, inadequate,
not representative of operating conditions specified for the test, or if the Director was not provided an opportunity to have an observer present at the test. [R307-165-5]

II.B.3.g Test Methods When performing emission 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. [R307-165-5] II.B.3.g.1 CO
40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]
II.B.3.g.2 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.3.g.3 SO2
40 CFR 60, Appendix A, Method 6; Method 6C; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.4 Conditions on Special Lining Application
II.B.4.a Epoxy linings or other specialty coatings shall be applied in accordance with R307-350-6
Application Methods. [R307-401-8, R307-350]

DAQE-AN107940040-25
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II.B.4.b Records of paint and epoxy lining application shall be maintained in a supervisor log. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per calendar year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.5.a.1 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each diesel-fired emergency engine. Natural gas-fired emergency engines shall use only pipeline quality natural gas as fuel. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less.
[R307-401-8]
II.B.5.b.2 To demonstrate compliance with the fuel sulfur requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN107940038-23 dated May 30, 2023 Is Derived From NOI dated October 21, 2024

DAQE-AN107940040-25
Page 14

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-

RN107940040 December 19, 2024 Jared Ellison
McWane Ductile - Utah 2550 South Industrial Parkway Provo, UT 84606
[e-mail] Dear Jared Ellison,
Re: Engineer Review: Modification of Approval Order DAQE-AN107940038-23 to Replace Cast Machine Project Number: N107940040 Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this document to be considered as the application for a Title V administrative amendment, a Title V Responsible Official must sign the next page. Please contact Jacob Hurley at [phone] if you have any questions or concerns about the ER. If you accept the contents of this ER, please email this signed cover letter to Jacob Hurley at [e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If McWane Ductile - Utah does not respond to this letter within 10 business days, the project will move forward without your approval. If you have concerns that we cannot resolve, 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 N107940040: McWane Ductile - Utah December 19, 2024 Page 1
OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be considered as an application to administratively amend your Title V Permit, the Responsible Official, as
defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL. If you do not want the Engineer Review to be considered as an application to administratively amend your Operating Permit only the approval signature above is required. Failure to have the Responsible Official sign below will not delay the Approval Order, but will require submittal of a separate Operating Permit Application to revise the Title V permit in accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit Application Due Dates clarifies the required due dates for Title V operating permit applications and can be viewed at:
https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality “Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided for this Approval Order are true, accurate and complete and request that this Approval Order be considered as an application to administratively amend the Operating Permit.” Responsible Official _________________________________________________ (Signature & Date) Print Name of Responsible Official _____________________________________

Engineer Review N107940040: McWane Ductile - Utah December 19, 2024 Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N107940040 Owner Name McWane Ductile - Utah
Mailing Address 2550 South Industrial Parkway Provo, UT, 84606
Source Name McWane Ductile - Utah Source Location: 2550 South Industrial Parkway
Provo, UT 84606 UTM Projection 446,300 m Easting, 4,449,800 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 3321 (Gray & Ductile Iron Foundries) Source Contact Christy Seiger-Webster Phone Number [phone] Email [e-mail]
Billing Contact Christy Seiger-Webster Phone Number 801.623.4224 Email [e-mail]
Project Engineer Jacob Hurley, Engineer Phone Number [phone]
Email [e-mail] Notice of Intent (NOI) Submitted October 21, 2024 Date of Accepted Application November 26, 2024

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SOURCE DESCRIPTION General Description
McWane Ductile - Utah (MDU) produces various sizes of ductile iron products in Utah County that are used in water distribution and infrastructure systems. The ductile iron production process includes melting, core preparation, casting, annealing, lining, coating, and special lining
operations. MDU is a major source of PM2.5, CO and VOC. NSR Classification: Administrative Amendment Source Classification Located in Southern Wasatch Front O3 NAA, Utah County PM10 Maint Area, Provo UT PM2.5 NAA, Utah County Airs Source Size: A
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), ZZZZZ: National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries Area Sources Title V (Part 70) Major Source
Project Proposal Modification of Approval Order DAQE-AN107940038-23 to Replace Cast Machine Project Description McWane Ductile - Utah (MDU) has notified intent to replace an existing casting machine with a new casting machine. The existing equipment will be disposed of as scrap and the casting process will stay the same. The casting machines are used to produce ductile iron products such as pipes
and utility pole sections. EMISSION IMPACT ANALYSIS
This is an administrative amendment with no change in emissions. No modeling required per R307-410-4 and R307-410-5. [Last updated December 3, 2024]

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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 136037.92 Carbon Monoxide 0 116.94
Nitrogen Oxides 0 87.04
Particulate Matter - PM10 0 84.01
Particulate Matter - PM10 (Fugitives) 0 39.45
Particulate Matter - PM2.5 0 79.24
Particulate Matter - PM2.5 (Fugitives) 0 34.70 Sulfur Dioxide 0 36.58 Volatile Organic Compounds 0 174.69

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 8561
Methanol (CAS #67561) 0 31
Naphthalene (CAS #91203) 0 490 Phenol (CAS #108952) 0 275 Xylenes (Isomers And Mixture) (CAS #1330207) 0 3440
Change (TPY) Total (TPY)
Total HAPs 0 6.40

Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units 1. BACT review regarding project not required
No BACT review required as no change to process. Exemption per R307-401-12. [Last updated December 4, 2024]
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 five (5) years. [R307-415-6b] 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]

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I.8 NEW The owner/operator shall submit documentation of the status of construction of the new equipment in Section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of
this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

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 Provo Manufacturing Plant
Plant Wide II.A.2 Cupola Including activated carbon injection system, bag house and CO burner system

II.A.3 Desulfurization System Includes fume hood with baghouse II.A.4 Ductile Treatment System Includes fume hood with baghouse
II.A.5 Annealing Oven Used for seal-coat removal - single top-discharge stack
II.A.6 Core Sand Silo Control: bin vent
II.A.7 NEW Charge Handling and Casting Operations Includes casting operations baghouse & 5 casting machines
II.A.8 Three Natural Gas-Fired Heaters
Two 3.0 MMBtu/hr heaters - one each in the pipe drying and pipe curing areas One 2.0 MMBtu/hr heater in the pipe curing area
II.A.9 Cement Lining Cement Silo Control: bin vent
II.A.10 Cement Lining Sand Silos Two silos Control: bin vents

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II.A.11 Pipe Coating Control: dry filter pads
II.A.12 Special Lining Shot Blasts Control: baghouse
II.A.13 Special Lining Application II.A.14 Special Lining Painter
II.A.15 Reagent Silo for Cupola Baghouse Control: bin vent

II.A.16 Cooling Towers Associated with compressors 10, 11, 12 and 3 cooling towers associated with casting machines identified in II.A.7

II.A.17 Diesel-Fired Emergency Recuperator Generator 550 hp emergency generator II.A.18 Portable Limespar Silos
II.A.19 Hot-Box Core Making

II.A.20 Poles Building Includes: painting controlled by paint arrestor filters, wet cutting and drilling, and welding II.A.21 Pole Flange Saw Building Includes: pole flange saw and baghouse

II.A.22 Pipe Cleaning Oven Blow Out Control: cyclone/baghouse for pipe cleaning system
II.A.23 Miscellaneous Equipment Includes: storage piles; pipe cutting, grinding and welding (saw rail and welding area baghouse); and hot metal transfer II.A.24 Natural Gas-Fired Generators Three miscellaneous natural gas-fired emergency generators Ratings: 32.8 bhp, 27 bhp, 10.06 bph (7.5 kW) II.A.25 Diesel-Fired Emergency Generator Cummins 464 hp emergency generator

II.A.26 Zinc Thermal Spray Process Control: cartridge collector baghouse
II.A.27 Cold-Cure Core Making Controls: bin vent and packed-bed scrubber

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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 Source Wide Conditions II.B.1.a The owner/operator shall not exceed the following production and/or consumption limits: 1. 85 tons of iron melted per hour 2. 205,000 tons of iron melted per rolling 12-month period 3. 18 hours of operation of special lining operations and hot-box core making process per day
4. 3,012.5 hours of operation of the hot-box core making process per rolling 12-month period
5. 15.9 pounds of seal-coat removed per day, and 1,850 pounds of seal-coat removed per
rolling 12-month period 6. 63.29 MMBtu/hr maximum heat input into the annealing oven furnace.
7. 3,241 tons of zinc wire used in the zinc coating process per rolling 12-month period.
[R307-401-8] II.B.1.a.1 To demonstrate compliance with these limits the owner/operator shall maintain a production log as follows:
1. The amount of seal-coat removed in the annealing oven shall be recorded each day. 2. Production/consumption shall be determined by daily plant production records. 3. Records of production/consumption shall be kept for all periods when the plant is in operation.
4. The records of production/consumption shall be kept on a daily basis. 5. For the hourly limitation, the recorded daily production value shall be divided by the operating hours of the day and compared to the limitation.
6. Monthly totals shall be determined as of the 20th day of each month. Each month's total shall be added to the previous 11 months' total to determine a 12-month rolling total.
7. Total heat input shall be determined by an hourly gas flow meter, natural gas vendor
supplier records, and/or the owner/operator's own testing. [R307-401-8]

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II.B.1.b Visible emissions from the following emission points shall not exceed the following values:
1. All baghouses - 10% opacity
2. Casting area hoods fugitive emissions - 15% opacity 3. 10% opacity at the property boundary 4. 20% for all diesel-fired emergency generators 5. All other points - 15% opacity. [40 CFR 60] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Opacity observations of emissions from fugitive sources
shall be conducted according to 58 FR 61640 Method 203A. [40 CFR 60] II.B.1.c The owner/operator shall comply with R307-309, Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. The owner/operator shall comply with its latest FDCP. [R307-309] II.B.1.d The owner/operator shall adhere to the following limits: 1. Emissions of VOCs to the atmosphere from the cupola, product coating and related operations shall not exceed 174.69 tons per rolling 12-month period. 2. Emissions of all HAPs to the atmosphere from the cupola, product coating and related operations shall not exceed 6.39 tons per rolling 12-month period. [R307-401-8]

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II.B.1.d.1 Compliance with each limitation shall be determined on a rolling 12-month total. By the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months.
The VOC and HAP emissions from pipe coating and associated operations shall be determined by maintaining a record of VOC and HAP emitting materials used each month. The record shall include the following data for each material used: 1. Name of the VOC and HAPs emitting material, such as pipe coatings. 2. Density of each material used (pounds per gallon).
3. Percent by weight of all VOC and HAP in each material used.
4. Gallons of each VOC and HAP emitting material used. 5. The amount of VOC and individual HAP emitted monthly by each material used shall be calculated by the following procedure or equivalent method approved by the Director:
VOC = [% VOC by Weight]/100 x [Density (lb/gal)] x [Gal Consumed x (1 ton/2000 lb)]
HAP = [% HAP by Weight]/100 x [Density (lb/gal)] x [Gal Consumed x ( 1 ton/2000 lb)] 6. The total amount of VOC or HAP emitted monthly from all materials used. 7. The amount of VOC and HAP emitted monthly from combustion processes shall be estimated based on production or operations data. The amount of natural gas burned in the cupola combustor shall be quantified each month and multiplied by the latest AP-42 emission factor to determine the monthly cupola VOC emissions. 8. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. [R307-150]
II.B.2 Conditions on the Cupola
II.B.2.a Emissions of CO to the atmosphere from the cupola bag house shall not exceed 0.80 lbs/ton of iron melted. [R307-401-8] II.B.2.a.1 To demonstrate compliance with the CO emission limit, the owner/operator shall conduct emission testing once every two (2) years. The Director may require the owner/operator to
perform an emission test at any time. All stack testing shall be performed as outlined in Section II.B.3. [R307-165-2, R307-401-8]
II.B.2.b Emissions of NOx to the atmosphere from the cupola bag house shall not exceed 33 lbs/hr.
[R307-401-8] II.B.2.b.1 To demonstrate compliance with the NOx emission limit, the owner/operator shall conduct emission testing once every two (2) years. The Director may require the owner/operator to perform an emission test at any time. All stack testing shall be performed as outlined in Section II.B.3. [R307-165-2, R307-401-8]

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II.B.2.c Emission of NOx to the atmosphere from the cupola bag house shall not exceed 52 tons per rolling 12-months. By the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months based on the following equation. Total NOx = (SUHR * SUEF) + (SSHR * SSEF) + (SDHR * SDEF) Where: SUHR = hours of startup operation during the most recent 12 months
SUEF = emission factor for startup operating phase (2.21 lb/hr)
SSHR = hours of steady-state operation during the most recent 12-months
SSEF = emission factor for steady-state operating phase. The emission factor shall be set using the most recent stack test.
SDHR = hours of shutdown operation during the most recent 12 months.
SDEF = emission factor for shutdown operation phase (21.2 lbs/hr)
For purposes of this condition startup, steady-state and shutdown operating phases shall be monitored and recorded to the nearest tenth of an hour and shall have the following meanings:
Startup operating phase means the time period commencing when blast air (that is, high
temperature air applied to initiate burning) is first put to the coke bed and ending with first iron (that is, the time that molten iron is first seen through the tuyeres). Steady-state operating phase means the time period commencing with the first iron and ending when the cupola cap is lowered. Shutdown operating phase means the time period commencing when the cupola cap is lowered and ending when the last iron is taken from the cupola. [R307-401-8]
II.B.2.d Emissions of SO2 to the atmosphere from the cupola baghouse shall not exceed 20.7 lbs/hr. [40 CFR 60, R307-401-8]
II.B.2.d.1 To demonstrate compliance with the SO2 emission limit, the owner/operator shall conduct emission testing once every two (2) years. The Director may require the owner/operator to perform an emission test at any time. All stack testing shall be performed as outlined in Section II.B.3. [R307-165-2, R307-401-8]

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II.B.2.e Emission of SO2 to the atmosphere from the cupola bag house shall not exceed 35.58 tons per rolling 12- months. By the 20th day of each month, a new 12-month total shall be calculated using data from the previous 12 months based on the following equation. Total SO2 = (SUHR * SUEF) + (SSHR * SSEF) + (SDHR * SDEF) Where: SUHR = hours of start-up operation during the most recent 12 months SUEF = emission factor for start-up operating phase (2.5 lb/hr) SSHR = hours of steady-state operation during the most recent 12-months SSEF = emission factor for steady-state operating phase. The emission factor shall be set
using the most recent stack test. SDHR = hours of shutdown operation during the most recent 12 months SDEF = emission factor for shutdown operation phase (50 lb/hr) For purposes of this condition, start-up, steady-state and shutdown operating phases shall be monitored and recorded to the nearest tenth of an hour and shall have the following meanings:
Start-up operating phase means the time period commencing when blast air (that is, high
temperature air applied to initiate burning) is first put to the coke bed and ending with "first iron" (that is, the time that molten iron is first seen through the tuyeres). Steady-state operating phase means the time period commencing with the first iron and ending
when the cupola cap is lowered. Shutdown operating phase means the time period commencing when the cupola cap is lowered and ending when the last iron is taken from the cupola. [R307-401-8]
II.B.3 Emission Testing and Monitoring Requirements
II.B.3.a Notification At least 30 days prior to conducting an emission test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include: 1. The date, time, and place of the proposed test 2. The proposed test methodologies 3. The stack to be tested 4. The procedures to be used
5. Any deviation from an EPA-approved test method
6. Explanation of any deviation from an EPA-approved test method
If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]

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II.B.3.b Testing The owner/operator shall conduct testing according to the approved source test protocol. The Director may reject emission test data if the test did not follow the approved source test
protocol or if Director was not provided an opportunity to have an observer present at the test. [R307-165-5, R307-401-8]
II.B.3.c Standard Conditions & Emission Limit Parameters 1. Temperature - 68 degrees Fahrenheit (293 K)
2. Pressure - 29.92 in Hg (101.3 kPa)
3. Concentration (ppmdv) - 3% oxygen, dry basis 4. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.3.d Test Conditions The owner/operator shall conduct all tests while the source is operating at no less than 90% of the maximum production rate achieved in the previous three (3) years, unless otherwise
specified in the approved source test protocol. If the desired production rate is not achieved at the time of the test, the maximum production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum
production rate shall remain in effect until successfully tested at a higher rate. The owner/operator shall request a higher production rate when necessary. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum allowable production rate is achieved. During the tests, the owner/operator shall burn fuels or combinations of fuels, use raw materials, and maintain process conditions representative of normal operations. In addition, the owner/operator shall operate under any other relevant conditions that the Director specifies. [R307-165-4, R307-401-8]
II.B.3.e Reporting
Within 60 days after completing an emission test, the owner/operator shall submit a copy of the test results to the Director. [R307-401-8]
II.B.3.f Possible Rejection of Test Results
The Director may reject emissions test data if they are determined to be incomplete, inadequate, not representative of operating conditions specified for the test, or if the Director was not provided an opportunity to have an observer present at the test. [R307-165-5]

II.B.3.g Test Methods When performing emission 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. [R307-165-5] II.B.3.g.1 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

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II.B.3.g.2 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

II.B.3.g.3 SO2 40 CFR 60, Appendix A, Method 6; Method 6C; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.4 Conditions on Special Lining Application
II.B.4.a Epoxy Linings or other specialty coatings shall be applied in accordance with R307-350-6 -
Application Methods. [R307-401-8, R307-350]
II.B.4.b Records of paint and epoxy lining application shall be maintained in a supervisor log. [R307-401-8]
II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per calendar year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.5.a.1 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.5.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each diesel-fired emergency engine. Natural gas-fired emergency engines shall use only pipeline quality natural gas as fuel. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.5.b.2 To demonstrate compliance with the fuel sulfur requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN107940038-23 dated May 30, 2023
Is Derived From Source submitted NOI dated October 21, 2024
REVIEWER COMMENTS

1. Comment regarding emissions: No change in emissions. Replacement of one casting machine with newer casting machine. Existing casting machine to be scrapped. [Last updated December 3, 2024] 2. Comment regarding casting machines: Five casting machines were under Condition II.A.16 when it is more appropriate to be under Condition II.A.7. [Last updated December 5, 2024] 3. Comment regarding source classification: Added in O3 NAA and PM 10 Maintenance area. [Last updated December 4, 2024]

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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

McWane Ductile – Utah
PO Box 12192550 South Industrial Parkway
Provo, Utah 84601
801.373.6910www.mcwaneductile.com

October 21, 2024

Mr. Bryce Bird, Director
Division of Air Quality
Department of Environmental Quality
PO Box 144820
Salt Lake City, Utah
84114-4820

RE: Notification for Cast Machine Replacement

Dear Mr. Bird:

This letter is to notify you of McWane Ductile – Utah’s (MDU) intent to replace an existing cast
machine with a new cast machine. The new machine is designed to produce cast products at about
seventeen percent (17%) more than the existing equipment.
Review of the last ten (10) years of iron production revealed that the years 2017 and 2018 had the
highest average iron production – 86,200 tons per year. Current market conditions indicate that an
iron production of 60,000 ton per year with an optimistic 3% annual increase would be a realistic
iron production approach. The difference in iron production is a drop of 26,200 tons per year, as a
result, the expected criteria emissions would also decrease, and the difference fall into the negative
zone with no significant increase. This comparison is shown below in Table I.

Table I. Iron Melted Criteria Emissions
PM10 PM2.5 SO2 NOx VOC CO
Baseline – Average of 2017-2018 Iron
Melted (tons) 86,188
Emission Factor (lb/ton) 0.0445 0.0445 0.46 0.93 0.07 0.8
Baseline Emissions (tons) 1.92 1.92 19.8 40.1 3.02 34.5
Projected Actual Production (tons) 63,650
Projected Actual Emissions (tons) 1.42 1.42 14.6 29.6 2.23 25.5
Projected less baseline emissions
(tons) (0.501) (0.501) (5.18) (10.5) (0.789) (9.01)

MDU operates five (5) cast machines and operates them according to market demand. To determine
the impact of the proposed machine replacement, a review of the cast production output was also
conducted for the specific machine. A similar, ten-year review was conducted, and it was discovered
that the machine being replaced had a maximum production or utilization year in 2021 with just
over 19,440 tons. Emissions were calculated for this machine for 2021 and then with the projected
seventeen percent increase to see the difference in emissions from increased utilization of this
specific equipment. This comparison is viewed in Table II
Notification for Cast Machine Replacement
October 21, 2024
McWane Ductile – Utah
Page 2 of 3

Table II. Casting Machine Utilization Criteria Emissions
PM10 PM2.5 SO2 NOx VOC CO
Baseline – 2021 Casting Usage(tons) 19,443
Emission Factor (lb/ton) 0.09 0.09 NA NA 0.032 0.00052
Baseline Emissions (tons) 0.875 0.875 NA NA 0.311 0.0051
Projected Actual Usage (tons) 22,748
Projected Actual Emissions (tons) 1.02 1.02 NA NA 0.364 0.0059
Projected less baseline emissions
(tons) 0.149 0.149 NA NA 0.053 8.59E-04
The increase in emissions is extremely small for the single unit, less than five-hundred pounds. An
attachment is provided with full notes.
After a discussion with Mr. John Jenks in your division, MDU believes the best fit for this permit
change is under R307-401-11, Replacement-in-Kind Equipment. In lieu of filing a specific notice of
intent (NOI), MDU is providing the following information as outlined in R307-401-11.1.
(a) The new cast machine has the capability of producing the seventeen percent more casted product as
the existing machine being replaced. However, total iron produced for any given day is distributed
up to four other cast machines according to market demand and is currently allowed in the NSR and
Title V permits.
(b) The number of emission units will not change. A single cast machine will be replaced with a single
cast machine.
(c) No additional air contaminants are emitted as the single and overall process remains the same.
(d) The cast machine is functionally equivalent to the existing cast machine it is replacing.
(e) The replacement does not change the fundamental design parameters of the casting process and
has no impact on the pollution control equipment.
(f) The new machine will physically replace the existing machine, and the existing machine will be sent
for scrap.
(g) The replacement does not trigger NSPS or NESHAPs.
(h) The replacement equipment does not violate any other provision of Title R307.

We note that no changes to either the current AO or Title V permits are requested or required. The
facility’s Approval Order makes reference to “casting operations” (reference Condition II.A.7) and
the facility’s Title V permit lists “casting operations” (reference Condition II.A.15). Neither specifies
a condition other than those applying to facility-wide.
Approval Order Language (DAQE-AN107940038-23)
II.A.7 Charge Handling and Casting Operations – Includes casting operations baghouse.
Title V Operating Permit Language (4900017004, Rev 11/08/2022)
II.A.15 Miscellaneous – Storage piles, grinding, hot metal transfer, charge handling and
casting operations, and casting operations baghouse (share the same baghouse with
Emission Unit Desulfurization and Ductile System).
Determine Highest Production Period
Year Annual (tons)
24-mo Period
Avg (tons)
Annual
(tons)
24-mo Period
Avg (tons)
2014 66,556 65,851 8,467 10,397
2015 65,146 80,721 12,327 11,593
2016 96,296 80,717 10,859 9,735
2017 65,139 86,188 8,612 12,337
2018 107,237 83,642 16,063 15,036
2019 60,046 60,051 14,009 13,015
2020 60,056 74,770 12,022 14,092
2021 89,485 73,883 16,162 17,803
2022 58,280 78,446 19,443 17,664
2023 98,612 — 15,886 —
Highest cupola production occurred in 2017-2018.
Highest cast machine usage occurred 2021-2022.
Projected Production (tons)
Year 1 Iron Melted 2 Cast Machine
2025 60,000 22,748
2026 61,800
2027 63,654
Notes
1 - Market prediction. 60,000 with an optimistic increase of 3% each year.
2 - 17% increase, based from highest production year, 2022, to be conservative.
Iron Melted Cast Machine Usage
Compare Criteria Emission Generation
Iron Melted
Average of 2017-2018 (tons) 86,188 Baseline
APM10 BPM2.5 CSOx DNOx EVOC FCO
Emission Factor (lb/ton) 0.0445 0.0445 0.46 0.93 0.07 0.8
Baseline emissions (tons)1.92 1.92 19.8 40.1 3.02 34.5
Projected production (highest tons)63,654
Projected actual emissions (tons)1.42 1.42 14.6 29.60 2.23 25.5
Projected less baseline emissions (tons)(0.501) (0.501) (5.18) (10.5) (0.789) (9.01)
All projected actual emissions are negative. None have a significant increase.
Notes
A - Results of 2023 NESHAPS PM test (0.0089 lb/ton • 5 = 0.0445 lb/.ton) with safety factor of 5 applied. Assumed all PM is PM10.
B - Results of 2023 NESHAPS PM test (0.0089 lb/ton • 5 = 0.0445 lb/.ton) with safety factor of 5 applied. Assumed all PM is PM2.5.
C - Maximum observed SO2 emission factor observed from compliance tested with a safety factor of 2. (0.23 lb/ton • 2 = 0.46 lb/ton)
D - Maximum observed NOx emission factor observed from compliance tested with a safety factor of 2. (0.415 lb/ton • 2 = 0.93 lb/ton)
E - Emission factor from vendor guantee, M-25a
F - Title V Permit Limit(s): CO - II.B.2.a
Compare Criteria Emission Generation
Cast Machine Usage
Use 2022 (tons) 19,443 Baseline
GPM10 GPM2.5 HSO2 HNOx JVOC KCO
Emission Factor (lb/ton) 0.09 0.09 NA NA 0.032 0.00052
Baseline emissions (tons)0.875 0.875 NA NA 0.311 0.0051
Projected production (highest tons)
Projected actual emissions (tons)1.02 1.02 NA NA 0.364 0.0059
Projected less baseline emissions (tons) 0.149 0.149 NA NA 0.053 8.59E-04
All projected actual emissions summed are less than 0.5 tons. None have a significant increase.
Notes
G - Keramida letter to John Pleasant dated 4/27/2006, project number 11314. Assume all PM10 is PM2.5.
H - SO2 and NOx emissions are not expected from the casting process.
J - Keramida letter to John Pleasant dated 4/27/2006, project number 11314; assumes VOC = organic HAPs
K - RMT letter to USEPA dated January 29, 2001 and MDU internal review.
22,748
M)
McWANE I IRON STRONG
DUCTILE
November 20, 2024
Mr. Bryce Bird, Director
Division of Air Quality
Department of Environmental Quality
PO Box 144820
Salt Lake City, Utah
84114-4820
RE: REVISED Notification for Cast Machine Replacement
Dear Mr. Bird:
McWane Ductile -Utah
PO Box 1219
2550 South Industrial Parkway
Provo, Utah 84601
801.373.6910
www.mcwaneductile.com
McWane Ductile -Utah (MDU) believes clarification is needed regarding the cast machine replacement
notification letter dated October 21, 2024. After discussion with Jacob Hurley in your division, MDU
recognizes that the October 21, 2024, letter included data that pertained to a subset of the permitted
emissions unit.
MDU operates up to a total of five (5) cast machines on any given day casting ductile products, pipes and
utility pole sections. All five cast machines together are considered as a single emissions unit and emissions
analysis for emissions increases should be completed across the emissions unit (all cast machines, see
Table I) and not by an individual machine (Table II was for an individual machine).
In the interest of clarity, the notification dated October 21, 2024, is revised as follows to reflect the proposed
changes to the emission unit only.
MDU intends to replace a single cast machine with a new machine. The new machine is functionally equivalent to
the existing machine. After a discussion with Mr. John Jenks in your division, MDU believes the best fit for this
permit change is under R307-401-11, Replacement-in-Kind Equipment. As detailed below, this replacement
satisfies the replacement-in-kind equipment criteria outlined in R307-401-11, and a notice of intent (NOi) and
approval order is therefore not required. In lieu of filing an NOi and accordance with the Replacement-in-Kind
procedures, MDU is providing the following information as outlined in R307-401-11.l.
(a) The casting emissions unit (5 cast machines) with the replacement machine has the capability of
producing the same amount of product as the existing casting unit with the old machine.
(b) The number of casting machines within the permitted emission unit will not change. A single cast
machine will be replaced with a single cast machine.
(c) No additional air contaminants are emitted from the casting emission unit as the single and overall
process remains the same.
(d) The cast machine is functionally equivalent to the existing cast machine it is replacing.
(e) The replacement does not change the fundamental design parameters of the casting process and has no
impact on the pollution control equipment.
(f) The new machine will physically replace the existing machine, and the existing machine will be sent for
scrap.
(g) The replacement does not trigger NSPS or NESHAPs.
(h) The replacement equipment does not violate any other provision of Title R307.
Revised Notification for Cast Machine Replacement
November 20, 2024
McWane Ductile -Utah
Page 2 of 2
The table below provides the emissions changes from the casting emission unit with future production. A review
of the last ten (10) years of iron production revealed that the years 2017 and 2018 had the highest average iron
production -86,200 tons per year. Current market conditions indicate that an iron production of 60,000 ton per
year with an optimistic 3% annual increase would be a realistic iron production approach. The difference in iron
production is a drop of 26,200 tons per year, as a result, the expected criteria emissions would also decrease, and
the difference fall into the negative zone with no significant increase.
Iron Casting Criteria Emissions
PM10 PM2.s S02 NO, voe co
Baseline - 2017-2018 Average Casting Usage (tons) 86,188
Emission Factor (lb/ton) 0.09· 0.09· 0 0 0.032· 0.00052b
Baseline Emissions (tons) 3.87 3.87 0 0 1.38 0.0224
Projected Actual Usage (tons) 63,650
Projected Actual Emissions (tons) 2.86 2.86 0 0 1.02 0.0165
Projected less baseline emissions (tons) (1.01) (1.01) 0 0 (0.361) (0.00586)
A - Keramida letter to John Pleasant dated 4/27/2006, project number 11314, Casting uses DIPRA additive factors for
inoculation, transfer/casting.
B - RMT letter to USEPA dated January 29, 2001, and MDU internal review.
MDU notes that no changes to either the current AO or Title V permits are requested or required. The facility's Approval
Order references to "casting operations" (reference Condition II.A. 7) and the facility's Title V permit lists "casting
operations" (reference Condition I1.A.15). Neither specifies a condition other than those applying to facility-wide.
Approval Order Language {DAQE-AN107940038-23)
I1.A.7 Charge Handling and Casting Operations -Includes casting operations baghouse.
Title V Operating Permit Language (4900017004, Rev 11/08/2022)
I1.A.15 Miscellaneous-Storage piles, grinding, hot metal transfer, charge handling and casting operations, and casting
operations baghouse (share the same baghouse with Emission Unit Desulfurization and Ductile System).
MDU requests confirmation that the proposed replacement satisfies the provisions of R307-410-11. If you
have any questions regarding the cast machine replacement, please contact our Environmental Manager,
Christy Seiger-Webster at [e-mail].
I certify that, based on information and belief formed after a reasonable inquiry, the statements made in this report are true, accurate, and complete.
Vice President and General Manager McWane Ductile - Utah
Cc:File