DAQ-2025-001557

DAQE-AN108030002-25

{{$d1 }}

Tim Sexton
Utah Pacific Bridge & Steel
50 North Geneva Road
Lindon, UT 84042
[e-mail]

Dear Mr. Sexton:

Re: Approval Order: New Steel Fabrication Facility
Project Number: N108030002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
14, 2024. Utah Pacific Bridge & Steel must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Katie Andersen, 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. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:KA:jg

cc: Utah County 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

March 21, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN108030002-25
New Steel Fabrication Facility

Prepared By
Katie Andersen, Engineer
[phone]
[e-mail]

Issued to
Utah Pacific Bridge & Steel - Utah Pacific Steel

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

March 21, 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 ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-AN108030002-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Utah Pacific Bridge & Steel Utah Pacific Bridge & Steel - Utah Pacific Steel

Mailing Address Physical Address
50 North Geneva Road 50 North Geneva Road
Lindon, UT 84042 Lindon, UT 84042

Source Contact UTM Coordinates
Name: Tim Sexton 437,081 m Easting
Phone: [phone],465,658 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3441 (Fabricated Structural Metal)

SOURCE INFORMATION
General Description
Utah Pacific Bridge & Steel (UPBS) is located in Lindon, Utah County. UPBS fabricates steel bridge
girders from plate steel and wide flange beams. The plate steel is received on-site by rail, where front-end
loaders, forklifts, and cranes are used to move the steel during the fabrication process. The plate steel is
formed into girders via plasma or oxy-fuel cutting, welding, and sanding. Primers and finish paint coats
are applied as specified by the client. The final products are shipped off-site by truck.

NSR Classification
New Minor Source

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

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression 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), XXXXXX: National Emission Standards for Hazardous Air Pollutants Area
Source Standards for Nine Metal Fabrication and Finishing Source Categories
DAQE-AN108030002-25
Page 4

Project Description
UPBS is located in Lindon, Utah County. UPBS fabricates steel bridge girders from plate steel and wide
flange beams. The plate steel is received on-site by rail, where front-end loaders, forklifts, and cranes are
used to move the steel during the fabrication process. The plate steel is formed into girders via plasma or
oxy-fuel cutting, welding, and sanding. Primers and finish paint coats are applied as specified by the
client. The final products are shipped off-site by truck. UPBS applied for a Small Source Exemption, but
in the process of calculating the emission estimates, discovered that they do not qualify for a Small
Source Exemption. As they do not have a permit, UPBS is applying for an AO.

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 16.00
Carbon Monoxide 0.09
Nitrogen Oxides 4.10
Particulate Matter - PM10 4.65
Particulate Matter - PM2.5 4.17
Sulfur Dioxide 0.00
Volatile Organic Compounds 9.05

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 202
Manganese (TSP) (CAS #7439965) 12
Metal HAPs (CAS #MHAPS) 0
Methanol (CAS #67561) 24
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 120
Naphthalene (CAS #91203) 4
Toluene (CAS #108883) 6920
Xylenes (Isomers And Mixture) (CAS #1330207) 640
Change (TPY) Total (TPY)
Total HAPs 3.96

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]
DAQE-AN108030002-25
Page 5

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]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Utah Pacific Bridge & Steel
II.A.2 One (1) Blasting Unit (Pre-Weld Blasting) Media: Sand Control: Fully Enclosed, vents to Dust Collector II.A.3 Various Plasma Cutters Control: None
II.A.4 Various Hand, Robotic, and Sub Arc Welders II.A.5 Blasting Operations (Blast/Paint Shed) System: Blasting System and two (2) hand blasting guns Media: Steel Grit and Steel Shot Control: Enclosed, vents through ducting to the ground outside
II.A.6 Painting Operations Location: Blast/Paint Shed System: Paint tank system and two (2) airless spray guns in operation Control: Enclosed Location: Paint Shed System: Various airless spray guns Control: Enclosed
DAQE-AN108030002-25
Page 6

II.A.7 Emergency Generator Engine Fuel: Diesel Manufacture Date: June 7, 2006 Rating: 275 HP (205.3 kW) NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Dry Abrasive Blasting Operations Requirements
II.B.1.a The owner/operator shall only use abrasive blasting media that meets the definition of low dust abrasives with a free silica content of less than 1.0%. [R307-401-8]
II.B.1.a.1 The owner/operator shall maintain records of abrasive blasting media used on site. The records
shall contain:
A. The name of abrasive blasting media

B. The free silica content within the blasting media.
[R307-401-8]
II.B.1.b The owner/operator shall not consume more than 76,860 pounds of abrasive blasting media total per rolling 12-month period for all abrasive blasting operations combined. [R307-401-8]
II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall:
A. Record the quantity of abrasive media added to each blasting unit when
the abrasive media is added
B. Record the date when the abrasive media is added to each blasting unit
C. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months
D. Keep records of abrasive media used for all periods when the plant is in operation.

[R307-401-8]
II.B.1.c The owner/operator shall comply with all applicable requirements in R307-306: PM10 Nonattainment and Maintenance Areas: Abrasive Blasting for abrasive blasting operations. [R307-306]
II.B.1.d The owner/operator shall route all emissions from the Blasting Unit (Equipment ID II.A.2) to a working dust collector. [R307-401-8]
II.B.1.e The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the dust collector. [R307-401-8]
II.B.1.e.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]
DAQE-AN108030002-25
Page 7

II.B.1.e.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8] II.B.1.f During operation of the dust collector, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operations. [R307-401-8]

II.B.1.f.1 The owner/operator shall record the pressure drop at least once per operating week while the baghouse is operating. [R307-401-8]
II.B.1.f.2 The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification;
B. Manufacturer recommended static pressure drop for the unit;
C. Date of reading;
D. Daily static pressure drop readings.
[R307-401-8]

II.B.1.g At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]
II.B.1.g.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]
II.B.1.h The owner/operator shall not allow visible emissions from the dust collector to exceed 10% opacity. [R307-401-8] II.B.1.h.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:
9.02 tons per rolling 12-month period of VOCs

4.02 pounds per rolling 12-month period of naphthalene
23.70 pounds per rolling 12-month period of methanol
128.19 pounds per rolling 12-month period of MIBK

201.21 pounds per rolling 12-month period of ethylbenzene

643.73 pounds per rolling 12-month period of xylene

3.46 tons per rolling 12-month period of toluene

3.97 tons per rolling 12-month period of all HAPs combined.

[R307-401-8]

DAQE-AN108030002-25
Page 8

II.B.2.a.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] The volume consumed of each evaporative source may be determined by purchase orders. [R307-401-8] II.B.2.a.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.2.a.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 and/or the volume purchased in the last month 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.2.b The owner/operator shall comply with the applicable VOC content limit requirements as listed in
R307-350-5. [R307-350-5, R307-401-8]
II.B.3 Haul Roads and Fugitive Dust Source Requirements
II.B.3.a The owner/operator shall not allow visible emissions from haul roads and all other fugitive dust
sources to exceed 20% opacity on site and 10% opacity at the property boundary unless otherwise specified in this permit. [R307-309-5]

II.B.3.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas 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. [R307-309-5]
DAQE-AN108030002-25
Page 9

II.B.3.a.2 Opacity requirements for fugitive dust shall not apply when the wind speed exceeds 25 miles per hour if the owner/operator has implemented, and continues to implement, the accepted FDCP and administers at least one (1) of the following contingency measures: A. Pre-event watering B. Hourly watering C. Additional chemical stabilization, or D. Cease or reduce fugitive dust-producing operations E. Other contingency measures approved by the Director. [R307-309-5]
II.B.3.b The owner/operator shall use water application or other control options contained in R307-309 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads. Controls shall be applied to ensure the opacity limits in this AO are not exceeded.
[R307-309-5, R307-401-8]

II.B.3.b.1 The owner/operator shall keep and maintain records of water application for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made. [R307-309-5, R307-401-8]
II.B.3.c Within 30 days of the date of this AO, the owner/operator shall submit an FDCP in electronic or written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan
Permit Application Website. If a written FDCP is completed, it shall be submitted to the
Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with the source. [R307-309-6]

II.B.4 Emergency Generator Engine Requirements
II.B.4.a The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency generator engine shall be kept in a log and shall include the following: A. The date the emergency generator engine was used B. The duration of operation in hours C. The reason for the emergency generator engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency generator engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

DAQE-AN108030002-25
Page 10

II.B.4.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency generator engine. [R307-401-8] II.B.4.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated August 14, 2024 Incorporates Additional Information dated September 24, 2024 Incorporates Additional Information dated October 9, 2024

DAQE-AN108030002-25
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 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-IN108030002-25

February 12, 2025

Tim Sexton
Utah Pacific Bridge & Steel
50 North Geneva Road
Lindon, UT 84042
[e-mail]

Dear Mr. Sexton:

Re: Intent to Approve: New Steel Fabrication Facility
Project Number: N108030002

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order is issued.
The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in
the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Katie Andersen, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Katie Andersen, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:KA:jg

cc: Utah County 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

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN108030002-25
New Steel Fabrication Facility

Prepared By
Katie Andersen, Engineer
[phone]
[e-mail]

Issued to
Utah Pacific Bridge & Steel - Utah Pacific Steel

Issued On
February 12, 2025

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

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
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-IN108030002-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Utah Pacific Bridge & Steel Utah Pacific Bridge & Steel - Utah Pacific Steel

Mailing Address Physical Address
50 North Geneva Road 50 North Geneva Road
Lindon, UT 84042 Lindon, UT 84042

Source Contact UTM Coordinates
Name: Tim Sexton 437,081 m Easting
Phone: [phone],465,658 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3441 (Fabricated Structural Metal)

SOURCE INFORMATION
General Description
Utah Pacific Bridge & Steel (UPBS) is located in Lindon, Utah County. UPBS fabricates steel bridge
girders from plate steel and wide flange beams. The plate steel is received on-site by rail, where front-end
loaders, forklifts, and cranes are used to move the steel during the fabrication process. The plate steel is
formed into girders via plasma or oxy-fuel cutting, welding, and sanding. Primers and finish paint coats
are applied as specified by the client. The final products are shipped off-site by truck.
NSR Classification
New Minor Source

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

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression 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), XXXXXX: National Emission Standards for Hazardous Air Pollutants Area
Source Standards for Nine Metal Fabrication and Finishing Source Categories
DAQE-IN108030002-25
Page 4

Project Description
UPBS applied for a Small Source Exemption, but in the process of calculating the emission estimates,
discovered that they do not qualify for a Small Source Exemption. As they do not have a permit, UPBS is
applying for an Approval Order.

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 16.00
Carbon Monoxide 0.09
Nitrogen Oxides 4.10
Particulate Matter - PM10 4.65
Particulate Matter - PM2.5 4.17
Sulfur Dioxide 0.00
Volatile Organic Compounds 9.05

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 202
Manganese (TSP) (CAS #7439965) 12
Metal HAPs (CAS #MHAPS) 0
Methanol (CAS #67561) 24
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 120
Naphthalene (CAS #91203) 4
Toluene (CAS #108883) 6920
Xylenes (Isomers And Mixture) (CAS #1330207) 640
Change (TPY) Total (TPY)
Total HAPs 3.96

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.
A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in The Daily Herald on February 14, 2025. During the public comment period, the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

DAQE-IN108030002-25
Page 5

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.

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]

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.
II.A THE APPROVED EQUIPMENT
II.A.1 Utah Pacific Bridge & Steel
II.A.2 One (1) Blasting Unit (Pre-Weld Blasting) Media: Sand Control: Fully Enclosed, vents to Dust Collector
II.A.3 Various Plasma Cutters
Control: None
DAQE-IN108030002-25
Page 6

II.A.4 Various Hand, Robotic, and Sub Arc Welders
II.A.5 Blasting Operations (Blast/Paint Shed) System: Blasting System and two (2) hand blasting guns Media: Steel Grit and Steel Shot
Control: Enclosed, vents through ducting to the ground outside
II.A.6 Painting Operations Location: Blast/Paint Shed System: Paint tank system and two (2) airless spray guns in operation Control: Enclosed Location: Paint Shed System: Various airless spray guns Control: Enclosed II.A.7 Emergency Generator Engine
Fuel: Diesel
Manufacture Date: June 7, 2006 Rating 275 HP (205.3 kW)
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

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. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Dry Abrasive Blasting Operations Requirements
II.B.1.a The owner/operator shall only use abrasive blasting media that meets the definition of low dust abrasives with a free silica content of less than 1.0%. [R307-401-8] II.B.1.a.1 The owner/operator shall maintain records of abrasive blasting media used on site. The records shall contain: A. The name of abrasive blasting media B. The free silica content within the blasting media. [R307-401-8]
II.B.1.b The owner/operator shall not consume more than 76,860 pounds of abrasive blasting media total per rolling 12-month period for all abrasive blasting operations combined. [R307-401-8]
DAQE-IN108030002-25
Page 7

II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Record the quantity of abrasive media added to each blasting unit when the abrasive media is added B. Record the date when the abrasive media is added to each blasting unit B. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months C. Keep records of abrasive media used for all periods when the plant is in operation. [R307-401-8]
II.B.1.c The owner/operator shall comply with all applicable requirements in R307-306: PM10 Nonattainment and Maintenance Areas: Abrasive Blasting for abrasive blasting operations.
[R307-306]

II.B.1.d The owner/operator shall route all emissions from the Blasting Unit (Equipment ID II.A.2) to a working dust collector. [R307-401-8]
II.B.1.e The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the dust collector. [R307-401-8]

II.B.1.e.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
II.B.1.e.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]
II.B.1.f During operation of the dust collector, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.1.f.1 The owner/operator shall record the pressure drop at least once per operating week while the
baghouse is operating. [R307-401-8]

II.B.1.f.2 The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification; B. Manufacturer recommended static pressure drop for the unit; C. Date of reading; D. Daily static pressure drop readings. [R307-401-8]
II.B.1.g At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

II.B.1.g.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8]
II.B.1.h The owner/operator shall not allow visible emissions from the dust collector to exceed 10%
opacity. [R307-401-8]

DAQE-IN108030002-25
Page 8

II.B.1.h.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 VOC & HAP Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 9.02 tons per rolling 12-month period of VOCs 4.02 pounds per rolling 12-month period of naphthalene 23.70 pounds per rolling 12-month period of methanol 128.19 pounds per rolling 12-month period of MIBK 201.21 pounds per rolling 12-month period of ethylbenzene 643.73 pounds per rolling 12-month period of xylene 3.46 tons per rolling 12-month period of toluene 3.97 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.a.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]
The volume consumed of each evaporative source may be determined by purchase orders.

[R307-401-8]
II.B.2.a.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]
DAQE-IN108030002-25
Page 9

II.B.2.a.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 and/or the volume purchased in the last month 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.2.b The owner/operator shall comply with the applicable VOC content limit requirements as listed in
R307-350-5. [R307-350-5, R307-401-8]

II.B.3 Haul Roads and Fugitive Dust Source Requirements II.B.3.a The owner/operator shall not allow visible emissions from haul roads and all other fugitive dust
sources to exceed 20% opacity on site and 10% opacity at the property boundary unless
otherwise specified in this permit. [R307-309-5]
II.B.3.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas 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. [R307-309-5] II.B.3.a.2 Opacity requirements for fugitive dust shall not apply when the wind speed exceeds 25 miles per
hour if the owner/operator has implemented, and continues to implement, the accepted FDCP
and administers at least one (1) of the following contingency measures:
A. Pre-event watering
B. Hourly watering

C. Additional chemical stabilization, or
D. Cease or reduce fugitive dust producing operations

E. Other contingency measure approved by the Director.

[R307-309-5]

II.B.3.b The owner/operator shall use water application or other control options contained in R307-309 to minimize emissions from fugitive dust and fugitive emissions sources, including haul roads. Controls shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-309-5, R307-401-8]
DAQE-IN108030002-25
Page 10

II.B.3.b.1 The owner/operator shall keep and maintain records of water application for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made. [R307-309-5, R307-401-8] II.B.3.c Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic or written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan
Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with the source. [R307-309-6]

II.B.4 Emergency Generator Engine Requirements II.B.4.a The owner/operator shall not operate the emergency generator engine on site for more than 100
hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency generator engine shall be kept in a log and shall include the following: A. The date the emergency generator engine was used B. The duration of operation in hours C. The reason for the emergency generator engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency generator engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency generator engine. [R307-401-8] II.B.4.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated August 14, 2024 Incorporates Additional Information dated September 24, 2024 Incorporates Additional Information dated October 9, 2024
DAQE-IN108030002-25
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 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

Utah Pacific Bridge & Steel 10803 0002 - Page 1 of 2
[def:$signername|printname|req|signer1] [def:$signersig|sig|req|signer1] [def:$notarysig|sig|req|notary] [def:$date|date|req|notary] [def:$state|state|req|notary] [def:$county|county|req|notary] [def:$disclosure|disclosure|req|notary] [def:$seal|seal|req|notary]
State of Florida, County of Broward, ss:
Daily Herald
1200 Provo Towne Centre Blvd #1058
[phone]
ACCOUNT
#DESCRIPTION TIMES PROOF TOTAL
CHARGES
LoUT47wNfyEToIBC0zdM 1 .00 107.22
Rachel Cozart, being first duly sworn, deposes and says: That (s)he
is a duly authorized signatory of Column Software, PBC, duly
authorized agent of the Daily Herald, which is, and was at the times
of publication, hereinafter mentioned, a newspaper printed and
published in Provo, Utah County State of Utah and that the annexed
advertisement was published in said paper on:
Feb. 14, 2025
That said newspaper was regularly issued and circulated on those
dates. Same was also published online at utahlegals.com,
according to Section 45-1-101 -Utah Code Annotated, beginning on
the first date of publication, for at least 30 days thereafter and a
minimum of 30 days prior to the date of scheduled.
[$signersig ]
(Signed)______________________________________ [$seal]
VERIFICATION
State of Florida
County of Broward
Subscribed in my presence and sworn to before me on this: [$date]
[$notarysig ]
______________________________
Notary Public
[$disclosure]
See Proof on Next Page
AFFIDAVIT OF PUBLICATION
Notarized remotely online using communication technology via Proof.
02/19/2025
Utah Pacific Bridge & Steel 10803 0002 - Page 2 of 2
Daily Herald
Publication Name:
Daily Herald
Publication URL:
Publication City and State:
Provo, UT
Publication County:
Utah
Notice Popular Keyword Category:
Notice Keywords:
Utah pacific
Notice Authentication Number:
202502181022108123551
2892905420
Notice URL:
Back
Notice Publish Date:
Friday, February 14, 2025
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Utah Pacific Bridge & Steel Location: Utah Pacific Bridge & Steel- Utah Pacific
Steel - 50 North Geneva Road, Lindon, UT Project Description: Utah Pacific Bridge and Steel (UPBS) is located in Lindon, Utah County. UPBS
fabricates steel bridge girders from plate steel and wide flange beams. The plate steel is received on site by rail, where front-end loaders,
forklifts, and cranes are used to move the steel during the fabrication process. The plate steel is formed into girders via plasma or oxy-fuel
cutting, welding, and sanding. Primers and finish paint coats are applied as specified by the client. The final products are shipped off-site by
truck. UPBS applied for a Small Source Exemption, but in the process of calculating the emission estimates, discovered that they do not
qualify for a Small Source Exemption. As they do not have a permit, UPBS is applying for an Approval Order. The completed engineering
evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the
State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal,
estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air
Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before March
16, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will
be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an
issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient
information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: February
14, 2025 Legal Notice 13734 Published in the Daily Herald on February 14, 2025
Back

DAQE-NN108030002-25

February 12, 2025

The Daily Herald
Legal Advertising Dept
1555 N 200 W
Provo, UT 84601

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald on
February 14, 2025.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Mountainland Association of Governments

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

DAQE-NN108030002-25
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Utah Pacific Bridge & Steel
Location: Utah Pacific Bridge & Steel- Utah Pacific Steel – 50 North Geneva Road,
Lindon, UT
Project Description: Utah Pacific Bridge and Steel (UPBS) is located in Lindon, Utah County. UPBS
fabricates steel bridge girders from plate steel and wide flange beams. The plate
steel is received on site by rail, where front-end loaders, forklifts, and cranes are
used to move the steel during the fabrication process. The plate steel is formed
into girders via plasma or oxy-fuel cutting, welding, and sanding. Primers and
finish paint coats are applied as specified by the client. The final products are
shipped off-site by truck. UPBS applied for a Small Source Exemption, but in the
process of calculating the emission estimates, discovered that they do not qualify
for a Small Source Exemption. As they do not have a permit, UPBS is applying
for an Approval Order.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before March 16, 2025, will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: February 14, 2025

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN108030002
February 5, 2025

Tim Sexton
Utah Pacific Bridge & Steel
50 North Geneva Road
Lindon, UT 84042
[e-mail]

Dear Tim Sexton,

Re: Engineer Review: New Steel Fabrication Facility
Project Number: N108030002

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 permitting program. Utah Pacific Bridge
& Steel should complete this review within 10 business days of receipt.

Utah Pacific Bridge & Steel should contact Katie Andersen at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Katie Andersen at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment
period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by
the DAQ Director.

If Utah Pacific Bridge & Steel does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Utah Pacific Bridge & Steel 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

February 10, 2025
DAQE-

RN108030002 February 5, 2025 Tim Sexton
Utah Pacific Bridge & Steel 50 North Geneva Road Lindon, UT 84042
[e-mail] Dear Tim Sexton,
Re: Engineer Review: New Steel Fabrication Facility Project Number: N108030002 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 permitting program. Utah Pacific Bridge & Steel should complete this review within 10 business days of receipt. Utah Pacific Bridge & Steel should contact Katie Andersen at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Utah Pacific Bridge & Steel does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Utah Pacific Bridge & Steel 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 N108030002: Utah Pacific Bridge & Steel- Utah Pacific Steel February 5, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N108030002 Owner Name Utah Pacific Bridge & Steel Mailing Address 50 North Geneva Road
Lindon, UT, 84042 Source Name Utah Pacific Bridge & Steel- Utah Pacific Steel
Source Location 50 North Geneva Rd Lindon, UT 84042
UTM Projection 437,081 m Easting, 4,465,658 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3441 (Fabricated Structural Metal) Source Contact Tim Sexton Phone Number [phone] Email [e-mail] Billing Contact Tim Sexton Phone Number [phone]
Email [e-mail] Project Engineer Katie Andersen, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted August 14, 2024 Date of Accepted Application September 26, 2024

Engineer Review N108030002: Utah Pacific Bridge & Steel- Utah Pacific Steel February 5, 2025 Page 2
SOURCE DESCRIPTION General Description
Utah Pacific Bridge and Steel (UPBS) is located in Lindon, Utah County. UPBS fabricates steel bridge girders from plate steel and wide flange beams. The plate steel is received on site by rail, where front-end loaders, forklifts, and cranes are used to move the steel during the fabrication
process. The plate steel is formed into girders via plasma or oxy-fuel cutting, welding, and sanding. Primers and finish paint coats are applied as specified by the client. The final products are shipped off-site by truck. NSR Classification: New Minor Source Source Classification Located in the Southern Wasatch Front O3 NAA and Provo UT PM2.5 NAA Utah County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression 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), XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories Project Proposal
New Steel Fabrication Facility Project Description UPBS applied for a Small Source Exemption, but in the process of calculating the emission estimates, discovered that they do not qualify for a Small Source Exemption. As they do not have a permit, UPBS is applying for an Approval Order. EMISSION IMPACT ANALYSIS
The criteria pollutant and HAP emission rates do not exceed any modeling thresholds as defined by Utah Administrative Code (UAC) R307-410-4 and R307-410-5, respectively. Therefore, modeling is not required at this time. [Last updated October 17, 2024]

Engineer Review N108030002: Utah Pacific Bridge & Steel- Utah Pacific Steel February 5, 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 16.00 Carbon Monoxide 0.09
Nitrogen Oxides 4.10
Particulate Matter - PM10 4.65
Particulate Matter - PM2.5 4.17
Sulfur Dioxide 0.00
Volatile Organic Compounds 9.05 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 202
Manganese (TSP) (CAS #7439965) 12
Metal HAPs (CAS #MHAPS) 0
Methanol (CAS #67561) 24
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 120 Naphthalene (CAS #91203) 4 Toluene (CAS #108883) 6920
Xylenes (Isomers And Mixture) (CAS #1330207) 640
Change (TPY) Total (TPY)
Total HAPs 3.96
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N108030002: Utah Pacific Bridge & Steel- Utah Pacific Steel February 5, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding New Steel Fabrication Facility
The Utah Pacific Bridge and Steel (UPBS) facility generates PM10, PM2.5, NOx, CO, SO2, VOC, and HAPs emissions from welding, blasting, cutting, paint and primer application, curing, and fugitive road dust.
Welding and Cutting Welding and cutting processes produce PM10, PM2.5, NOx, and HAPs. Emissions from welding and cutting processes can be controlled by the following control technologies: best management practices, capture systems such as welding booths, hoods, torch fume extractors, and flexible ducts,
and collection systems such as high efficiency filters, electrostatic precipitators, particulate scrubbers, and activated carbon filters. Due to the large size of the girders being produced, UPBS requires flexibility in their welding and cutting processes. Thus, capture systems and collections
systems are infeasible. The DAQ has determined that following manufacturer procedure and best management practices as BACT for controlling emissions from welding and cutting processes. In addition, the source shall comply with the applicable requirements in MACT Subpart XXXXXX
National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. Complying with MACT Subpart XXXXXX includes submitting the proper initial notification forms, conducting the graduated VEO readings (if necessary), and submitting the required notification and observations as needed to the DAQ. Blasting Blasting activities create PM10 and PM2.5 emissions to clean and texturize metals. Emissions from blasting activities can be controlled by the following control technologies: Blast enclosures
controlled by baghouses, reclaim systems, drapes or curtains, water curtains, wet blasting, and the use of low dust abrasives. Due to the large size of materials and products at UPBS, water curtains and wet blasting are infeasible control technologies.
UPBS has two locations where blasting activities occur. The first is located at the south end of the main manufacturing building and occurs before the girders are manufactured. BACT for the blaster is enclosing the unit and controlling emissions with a dust collector, using low dust abrasives with a free silica content of less than 1.0%, and limiting visible emissions from abrasive blasting
operations to no more than 20% opacity.
The second location where blasting activities occur is on the north side of Blasting/Painting building. At this point in the production process, fully formed girders are blasted before painting and coating occur. The girders exceed 8 feet in length and are in unconfined abrasive blasting operations. The following is BACT for the unconfined abrasive blasting operations in a PM2.5 Nonattainment Area: the use of drapes or curtains to contain blasting media and debris, the use of low dust abrasives with a free silica content of less than 1.0%, best management practices to reduce excessive dust, and limiting visible emissions from abrasive blasting operations to less than 20% opacity. [Last updated October 31, 2024] 2. BACT review regarding New Steel Fabrication Facility (cont.) Painting, Coating, and Curing Painting, coating, and curing activities emit VOCs and HAPs. Emissions from these activities are
controlled by the following technologies: the use of low VOC paints and coatings, the use of high volume low pressure (HVLP) spray guns, solvent recycling, positive air flow booth with high

Engineer Review N108030002: Utah Pacific Bridge & Steel- Utah Pacific Steel February 5, 2025 Page 5
efficiency filters, and thermal oxidizers. These control technologies are technically feasible. UPBS paints and coats steel bridge girders that are typically larger than 8 feet in length. The paint booths
that UPBS operates are 2 large paint buildings. A positive air flow system for these buildings and for the size of girders produced would be cost intensive. It is economically infeasible to install and operate positive air flow booths to direct VOC and HAP streams to high efficiency filters or thermal oxidizers. The DAQ has determined that the use of low VOC paints and coatings, HVLP spray guns, and best management practices as BACT to control VOC and HAP emissions from painting, coating, and curing activities. As a part of BACT, UPBS must also comply with R307-350 Miscellaneous Metal Parts and Products Coatings. Road Dust Road dust is emitted in the form of PM10 and PM2.5 from unpaved surfaces. Emission from these activities are controlled by the following technologies: paving, road base and water suppression,
water suppression, and chemical suppression. All of these technologies are technically feasible. UPBS operates multiple buildings, and cranes and trailers are used to move the equipment between buildings. Paving is economically infeasible based on the emissions that would be reduced by paving the area (0.21 tpy PM10 and 0.02 tpy PM2.5 ). The DAQ has determined that the use of water suppression with road base and chemical suppression, as needed, as BACT to control PM10 and PM2.5 emissions from road dust. In addition, the DAQ considers BACT to be limiting visible emissions to 20% opacity on site and 10% opacity at the property boundary in accordance with R307-309. Diesel-Fired Emergency Generator Engine Diesel-Fired Generator engines emit PM2.5, NOx, SO2, and VOCs. These emissions are controlled
by the following methods: PM2.5 is controlled by catalyzed diesel particulate filters (85-90% control efficiency), diesel particulate filters (85-90% control efficiency), and diesel oxidation catalysts (20-50% control efficiency). The estimated PM2.5 emissions from the diesel-fired generator, based on 100 hours of
annual operation, is 0.03 tons per year. All technically feasible control technologies are economically infeasible. Therefore, BACT for controlling PM2.5 emissions is proper maintenance and operation of the diesel generator engine.
NOx is controlled by exhaust gas recirculation (25-50% control efficiency), turbocharging (3-35%
control efficiency), engine ignition timing retardation (20-45% control efficiency), and modifying the air-to-fuel ratio (7-8% control efficiency).The estimated NOx emissions from the diesel-fired generator engine is 0.43 tons per year. All technically feasible control technologies are
economically infeasible. Therefore, BACT for controlling NOx emissions is proper maintenance and operation of the diesel generator engine. SO2 is controlled by using ultra-low sulfur diesel fuel (15 ppm sulfur). This is a standard requirement under 40 CFR 63 Subpart ZZZZ. Therefore, BACT for controlling SO2 will be to use ultra-low sulfur diesel fuel.
VOCs are controlled by catalyzed diesel particulate filters (90% control efficiency) and diesel
oxidation catalysts (90% control efficiency). The estimated VOC emissions from the diesel generator engine are 0.03 tons per year. These feasible control technologies are economically infeasible. Therefore, BACT for controlling VOC emissions is proper maintenance and operation of the diesel generator engine. [Last updated November 21, 2024]

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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]

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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 NEW Utah Pacific Bridge and Steel
II.A.2 NEW One (1) Blasting Unit (Pre-Weld Blasting) Media: Sand Control: Fully Enclosed, vents to Dust Collector
II.A.3 NEW Various Plasma Cutters Control: None
II.A.4 NEW Various Hand, Robotic, and Sub Arc Welders
II.A.5 NEW Blasting Operations (Blast/Paint Shed) System: Blasting System and two (2) hand blasting guns Media: Steel Grit and Steel Shot Control: Enclosed, vents through ducting to the ground outside
II.A.6 NEW Painting Operations Location: Blast/Paint Shed System: Paint tank system and two (2) airless spray guns in operation Control: Enclosed
Location: Paint Shed System: Various airless spray guns Control: Enclosed

II.A.7 NEW Emergency Generator Engine Fuel: Diesel Manufacture Date: June 7, 2006 Rating 275 HP (205.3 kW) NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ

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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 NEW Dry Abrasive Blasting Operations Requirements
II.B.1.a NEW The owner/operator shall only use abrasive blasting media that meets the definition of low dust abrasives with a free silica content of less than 1.0%. [R307-401-8]
II.B.1.a.1
NEW
The owner/operator shall maintain records of abrasive blasting media used on site. The
records shall contain:
A. The name of abrasive blasting media
B. The free silica content within the blasting media. [R307-401-8]
II.B.1.b NEW The owner/operator shall not consume more than 76,860 pounds of abrasive blasting media total per rolling 12-month period for all abrasive blasting operations combined. [R307-401-8]
II.B.1.b.1 NEW To determine compliance with a rolling 12-month total, the owner/operator shall: A. Record the quantity of abrasive media added to each blasting unit when the abrasive
media is added
B. Record the date when the abrasive media is added to each blasting unit B. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months
C. Keep records of abrasive media used for all periods when the plant is in operation.
[R307-401-8]
II.B.1.c NEW The owner/operator shall comply with all applicable requirements in R307-306: PM10 Nonattainment and Maintenance Areas: Abrasive Blasting for abrasive blasting operations. [R307-306] II.B.1.d NEW The owner/operator shall route all emissions from the Blasting Unit (Equipment ID II.A.2) to a working dust collector. [R307-401-8]

II.B.1.e NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the dust collector. [R307-401-8]
II.B.1.e.1 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]

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II.B.1.e.2 NEW The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8]
II.B.1.f NEW During operation of the dust collector, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operations. [R307-401-8]
II.B.1.f.1 NEW The owner/operator shall record the pressure drop at least once per operating week while the baghouse is operating. [R307-401-8]
II.B.1.f.2
NEW
The owner/operator shall maintain the following records of the pressure drop readings:
A. Unit identification; B. Manufacturer recommended static pressure drop for the unit; C. Date of reading; D. Daily static pressure drop readings. [R307-401-8] II.B.1.g NEW At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]
II.B.1.g.1
NEW
The owner/operator shall maintain records of the pressure gauge calibrations and
replacements. [R307-401-8] II.B.1.h NEW The owner/operator shall not allow visible emissions from the dust collector to exceed 10% opacity. [R307-401-8]

II.B.1.h.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 NEW VOC & HAP Requirements
II.B.2.a NEW The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site:
9.02 tons per rolling 12-month period of VOCs 4.02 pounds per rolling 12-month period of naphthalene 23.70 pounds per rolling 12-month period of methanol 128.19 pounds per rolling 12-month period of MIBK 201.21 pounds per rolling 12-month period of ethylbenzene 643.73 pounds per rolling 12-month period of xylene
3.46 tons per rolling 12-month period of toluene 3.97 tons per rolling 12-month period of all HAPs combined. [R307-401-8]

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II.B.2.a.1 NEW 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]
The volume consumed of each evaporative source may be determined by purchase orders. [R307-401-8] II.B.2.a.2 NEW 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.2.a.3 NEW 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 and/or the volume
purchased in the last month 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.2.b NEW The owner/operator shall comply with the applicable VOC content limit requirements as listed in R307-350-5. [R307-350-5, R307-401-8]
II.B.3 NEW Haul Roads and Fugitive Dust Source Requirements
II.B.3.a NEW The owner/operator shall not allow visible emissions from haul roads and all other fugitive dust sources to exceed 20% opacity on site and 10% opacity at the property boundary unless
otherwise specified in this permit. [R307-309-5] II.B.3.a.1 NEW Visible emission determinations for fugitive dust from haul roads and operational areas 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. [R307-309-5]

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II.B.3.a.2 NEW Opacity requirements for fugitive dust shall not apply when the wind speed exceeds 25 miles per hour if the owner/operator has implemented, and continues to implement, the accepted FDCP and administers at least one (1) of the following contingency measures:
A. Pre-event watering B. Hourly watering C. Additional chemical stabilization, or D. Cease or reduce fugitive dust producing operations
E. Other contingency measure approved by the Director. [R307-309-5]
II.B.3.b NEW The owner/operator shall use water application or other control options contained in R307-309 to minimize emissions from fugitive dust and fugitive emissions sources, including haul roads. Controls shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-309-5, R307-401-8] II.B.3.b.1 NEW The owner/operator shall keep and maintain records of water application for all periods when the plant is in operation. The records shall include the following items:
A. Date and time treatments were made B. Number of treatments made. [R307-309-5, R307-401-8]
II.B.3.c
NEW
Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic
or written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall
comply with the FDCP for control of all fugitive dust sources associated with the source. [R307-309-6]
II.B.4 NEW Emergency Generator Engine Requirements
II.B.4.a
NEW
The owner/operator shall not operate the emergency generator engine on site for more than
100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.1
NEW
To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency generator engine shall be kept in a log and shall include the following:
A. The date the emergency generator engine was used
B. The duration of operation in hours C. The reason for the emergency generator engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]

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II.B.4.a.2 NEW To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency generator engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.b NEW The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency generator engine. [R307-401-8]
II.B.4.b.1 NEW The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.4.b.2
NEW
To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [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: Is Derived From NOI dated August 14, 2024
Incorporates Additional Information dated September 24, 2024 Incorporates Additional Information dated October 9, 2024
REVIEWER COMMENTS 1. Comment regarding New Steel Fabrication Facility: Utah Pacific Bridge and Steel (UPBS) has been inspected multiple times under the assumption that the source qualified as a pre-November 29, 1969, source. Based on the July 8, 2021 inspection, Compliance directed UPBS to work with the Minor Source NSR section to determine if an Approval Order is required for the site. UPBS applied for a Small Source Exemption on December 22, 2023 but found that their VOC emissions exceeded the Small Source Exemption thresholds. The purpose of this project is to issue UPBS an approval order. UPBS fabricates steel girders for the fabrication of highway overpasses. Steel plates are delivered by rail to the receiving yard and trucked to the fabrication building. The steel plates are cleaned in an
enclosed shot blasting unit that is vented to a dust collector. The steel plates are then cut and drilled on a large water bed plasma cutter. The girders are then formed by welding cut steel with submerged arc flux core and stick welding. The welded girders are moved to the yard where some are then moved into the Blast/Paint building to be blasted and painted. Finished girders are loaded onto haul trucks for shipment. [Last updated September 26, 2024] 2. Comment regarding Emission Estimates: UPBS has calculated their emissions using the following resources:
Welding Operations: AP-42 Table 12.19-1 and Table 12.19-2, assuming 4,410 hours of operation per year Blasting Operations: AP-42 Table 13.2.6-1, assuming blasting operations take place 8 hours a day
for 1,960 hours a year Cutting Operations: Emission of Fumes, Nitrogen Oxides, and Noise in Plasma Cutting of Stainless and Mild Steel, Bromsen B. et all. Assuming a average material thickness of 35 mm, and an
operation time of 8,760 hours per year Curing Operations: Safety Data Sheets of the various coatings and paints, assuming 8,760 hours of curing time
Road Dust: AP-42 Table 13.2.2-1, Table 13.2.2-2, Table 13.2.2-4, and Table 13.2.2-5. For conservative estimates, PM2.5 emissions were assumed to be equal to PM10 emissions for welding, cutting, and coating operations. [Last updated December 19, 2024]
3. Comment regarding Federal Rule Applicability: 40 CFR 60 Subpart IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
40 CFR 60 (NSPS) Subpart IIII applies to owners and operators of stationary compression ignition internal combustion engines that are constructed, reconstructed, or modified after July 11, 2025. UPBS owns and operates an emergency generator that was manufactured June 7, 2006. Therefore,

Engineer Review N108030002: Utah Pacific Bridge & Steel- Utah Pacific Steel February 5, 2025 Page 14
UPBS is subject to comply with NSPS Subpart IIII.
40 CFR 63 Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 40 CFR 63 (MACT) Subpart ZZZZ applies to owner and operators of stationary RICE at a major or area source of HAP emissions. UPBS owns and operates one diesel-fired engine to provide supplemental power to process operations that may occur in the yard. Therefore, UPBS is subject to
comply with MACT Subpart ZZZZ.
40 CFR 63 Subpart XXXXXX: National Emission Standards for Hazardous Air Pollutants Area
Source Standards for Nine Metal Fabrication and Finishing Source Categories 40 CFR 63 (MACT) Subpart XXXXXX applies to owners and operators of area sources that are
primarily engaged in the operations of one or more of the following: electrical and electronic equipment finishing operations, fabricated metal products, fabricated plate work, fabricated structural metal manufacturing, heating equipment, industrial machinery and equipment finishing operations, iron and steel forging, primary metal products manufacturing, and valves and pipe fittings. UPBS primarily engages in fabricated structural metal manufacturing for the construction of steel girders for highway overpasses. Therefore, UPBS is subject to comply with MACT Subpart
XXXXXX. [Last updated December 3, 2024] 4. Comment regarding State Rule Applicability:
R307-304: Solvent Cleaning R307-304 applies to solvent cleaning operations with Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, or Weber counties that use 55 gallons or more a year of VOC containing solvent products,
minus exempt materials, for solvent cleaning operations. UPBS uses an acetone-based solvent to clean paint guns and lines. Acetone is classified as an VOC-exempt solvent. Thus, the source is not subject to R307-304.
R307-305: Nonattainment and Maintenance Areas for PM10: Emission Standards
R307-305 applies to owners and operators of any source that is listed in Section IX, Part H of the state implementation plan or located in a PM10 nonattainment or maintenance area. UPBS is located in a PM10 maintenance area, and thus is subject to this subpart.
R307-306: PM10 Nonattainment and Maintenance Areas: Abrasive Blasting
R307-306 applies to any person who operates abrasive blasting equipment in a PM10 nonattainment or maintenance area. UPBS operates abrasive blasting equipment in a PM10 maintenance area. Thus, UPBS is subject to R307-306.
R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust R307-309 applies to all new or existing sources of fugitive dust one-quarter acre or greater and any sources of fugitive emissions located in PM10 or PM2.5 nonattainment or maintenance plan areas. UPBS is a source of fugitive PM10 and PM2.5 emissions located in a nonattainment area. Thus, UPBS is subject to R307-309. R307-350 Miscellaneous Metal Parts and Product Coatings R307-350 applies to miscellaneous metal parts and products coating operations located in Box Elder, Cache, Davis, Salt lake, Tooele, Utah, and Weber counties that use a combined 20 gallons or more of coating products and associated solvents per year. UPBS uses more than 20 gallons per year of coating products and associated solvents. Therefore, UPBS is subject to R307-350. [Last updated October 31, 2024]

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5. 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 source is not a major source nor a Title IV affected Source. The source is not subject to 40 CFR 61 (NESHAP). The source is subject to 40 CFR 60 (NSPS) Subpart IIII, 40 CFR 63 (MACT) Subpart ZZZZ, and Subpart XXXXXX. These subparts exempt a source from the obligation to obtain a Title V operating permit. Thus, Title V does not apply to the source. [Last updated December 3, 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
Emissions Summary
Company:Utah Pacific Bridge & SteelSite:Linden, Utah
PM10 PM2.5 SO2 NOX CO VOC HAP(ton/yr)(ton/yr)(ton/yr)(ton/yr)(ton/yr)(ton/yr)(ton/yr)Welding 0.11 0.11 --------0.01 Assume PM2.5=PM10Blasting0.50 0.05 ----------PM2.5 has emission factorsPlasma Cutting 0.17 0.17 --3.68 ------Assume PM2.5=PM10Coating Applications 3.80 3.80 ----------Assume PM2.5=PM10Curing----------9.02 3.96Road Dust 0.03 0.00 ------PM2.5 has emission factorsDiesel-Fired Engine 0.03 0.03 0.00 0.43 0.09 0.03 0.00 Assume PM2.5=PM10Total4.65 4.17 0.00 4.10 0.09 9.05 3.97
As a conservative estimate, PM2.5 equals PM10 when there are no PM2.5 emission factors available.
Controlled EmissionsSource
Welding Emissions Calculations
Process Material
UPBS
Usage
(lb/yr)
PM-10
(lb/10^3
lb)
PM10
(lb/yr)
PM10
(lb/hr)
Cr (10^-1
lb/10^3
lb)
Cr (lb/yr)
Co (10^-1
lb/10^3
lb)
Co (lb/yr)
Mn (10^-1
lb/10^3
lb)
Mn (lb/yr)
Ni (10^-1
lb/10^3
lb)
Ni (lb/yr)Total HAP
(lb/yr)
Welding SMAW e7018 1,575 18.4 28.98 0.06 0.0095 0.01 0.0016 10.3 1.6223 0.02 0.0032 1.6364WeldingSMAW e8018 810 17.1 13.85 0.17 0.0268 No Data 0.3 0.0243 0.51 0.0413 0.0924WeldingSAW Spoolarc 81 14,400 0.05 0.72 No Data No Data No Data No Data 0.0000WeldingSAW Subarc L61 11,664 0.05 0.58 No Data No Data No Data No Data 0.0000WeldingFCAW R70 ultra 5,184 15.1 78.28 0.04 0.0063 No Data 8.91 4.6189 0.05 0.0259 4.6512WeldingFCAW 71 ultra 8,640 12.2 105.41 0.02 0.0032 0.01 0.0086 6.62 5.7197 0.04 0.0346 5.7660Total227.82 0.05 0.0457 0.0102 11.9852 0.1049 12.1460
0.006073Notes:0.005993
US EPA AP 42, table 12.19-1, PM-10 Emission factors for welding operations 8.04E-05US EPA AP 42, table 12.19-2, Hazardous Air Pollutant (HAP) Emission factors for welding operationsPM10 lb/hr emission rate calculated assuming 4,410 hours of operation per year (18 hrs per day, 5 days per week, and 49 weeks per year).hours per year
Process Material
UPBS
Usage
(lb/hr)
Cr (10^-1
lb/10^3
lb)
Cr (lb/hr)
Co (10^-1
lb/10^3
lb)
Co (lb/hr)
Mn (10^-1
lb/10^3
lb)
Mn (lb/hr)
Ni (10^-1
lb/10^3
lb)
0 Total HAP
(lb/hr)
Welding SMAW e7018 2 0.06 0.00001 0.01 0.00000 10.3 0.00206 0.02 0.00000 0.00208WeldingSMAW e8018 2 0.17 0.00003 No Data 0.3 0.00006 0.51 0.00010 0.00020WeldingFCAW R70 ultra 5 0.04 0.00002 No Data 8.91 0.00446 0.05 0.00003 0.00450WeldingFCAW 71 ultra 5 0.02 0.00001 0.01 0.00001 6.62 0.00331 0.04 0.00002 0.00335Total0.00008 0.00001 0.00989 0.00015 0.01012
Emission Threshold Values (lb/hr)0.0002 0.001 0.01 0.0017
Blasting Emissions Calculations
Process Material UPBS PM-10 PM10 PM10 PM-2.5 PM2.5 PM2.5 Blasting Steel Shot S-330 36,000 13 468.00 1.3 46.80BlastingSteel Grit MG-50 40,320 13 524.16 1.3 52.42 Grit is in the blasting unit. Shot is in the Paint/ Blasting Garnet 540 0.69 0.37 0.69 0.37Total992.53 0.51 99.59 0.0576,860 tpy 0.5 tpy 0.05Notes:US EPA AP 42, Table 13.2.6-1, PM-10 Emission factors for abrasive blasting Same Table for PM2.5 EmissionsIt is estimated blasting operations take place 8 hours per day, 1,960 hours per year.
40320
Plasma Cutting Emissions Calculations
Process Material
UPBS
Estimate
d Cutting
Time
(min/year)
PM-10
(g/min)*
PM10
(lb/yr)
PM10
(lb/hr)
NOx
(l/min)
Total NOx
(lb/yr)**
Total NOx
(lb/hr)
Plasma Cutting (g/min methMild Steel 525600 0.30 347.62 0.04 4.60 7355.62 0.848760hr/yr 0.17 3.68Notes:Emission of Fumes, Nitrogen Oxides, and Noise in Plasma Cutting of Stainless and Mild Steel, Bromsen B. et al, IIW Document 1E-174-93, 1994* Assume 35mm average material thickness for cutting, semidry. 6 hours per working day cutting. Also assume fumes for 35mm mild steel would be the same as those for 35mm stainless steel. It is estimated pplasma cutting operations take place 6 hours per day, 1,470 hours per year.** Density: 8% @ 1.88 g/l (NO2) & 92% @ 1.34 g/l (NO) = 1.38 g/l
Coating Application Emissions Calculations
Over-Source Pollutant Spray(lb/yr)(lb/hr)(%)(ton/yr)(lb/hr)OSPaint Area PM-10 50,679 41.37 15 3.801 6.206
The annual coating application rate is conservatively estimated as the non VOC portion of the paint currently required multiplied by a safety factor of 1.3.Pounds per hour emission rate was calculated assuming 1,225 hours per year of operation (5 hr/day x 5 day/wk x 49 wk/yr).Paint is applied with an airless spray gun. Because of the large size of the surfaces being painted, overspray for the operation is estimated at 15 percent.
Production UncontrolledRateEmissions
PR ER
Curing Emissions Calculations
Product Product Product VOC VOCProductUsageDensityUsageDensityEmissions(gal/yr)(lb/gal)(lb/yr)(lb/gal)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)Carboguard 60 Part A 20 11.66 233 2.00 40 4.01 9.35 ------------0.10 0.23 17.00 39.65Carboguard 60 Part B 20 13.49 270 2.00 40 1.01 2.73 ----6.69 18.05 --------3.51 9.47Carboguard 890 Part A 39 10.74 419 1.79 70 1.71 7.17 ----------------7.17 30.04Carboguard 890 Part B 39 13.33 520 1.79 70 1.40 7.28 ------------3.32 17.26 5.82 30.25Carboguard 893 Part A 520 12.99 6,750 1.63 845 0.59 39.82 ------------4.48 302.40 1.43 96.52Carboguard 893 Part B 520 12.66 6,577 1.63 845 ------------------------Carboline Thinner 800 7.08 5,664 7.09 5,675 ----------------76.35 ######----Carbothane 133 HB Part A 51 12.08 621 3.20 164 3.36 20.87 ------------3.61 22.42 14.26 88.57Carbothane 133 HB Urathane Conv 9 8.75 75 3.20 27 2.38 1.78 ----------------10.06 7.54Carbothane 133 LH Part A 23 14.99 348 2.70 63 ----------------2.38 8.28 ----Carbothane 133 LH Urathane Conv 6 8.33 48 2.70 16 ------------------------Carbothane 133 LV Part A 139 13.16 1,831 1.76 245 1.04 19.05 ----------------3.62 66.30Carbothane 133 LV Urethane Conve 28 9.33 260 1.76 49 ------------------------Carbothane 134 HS Part A 633 11.49 7,273 2.40 1,521 0.42 30.55 ----------------1.02 74.19Carbothane 134 HS Urethane Conv 158 9.33 1,476 2.40 380 ------------------------Carbozinc 11 HS Activator 269 7.83 2,107 2.40 647 ------------------------Carbozinc 11 HS Base 27 10.49 282 2.40 65 ------------------------Carbozinc 859 Part A 530 ######5,742 2.72 1,443 0.61 35.03 ------------21.48 ######1.48 84.98Carbozinc 859 Part B 303 7.3295 2,221 2.72 824 0.62 13.77 ------------45.87 ######1.50 33.32Macropoxy 646-100 Part A 208 13.41 2,783 0.83 172 0.20 5.57 ----------------1.00 27.83Macropoxy 646-100 Part B 208 13.27 2,754 0.83 172 0.30 8.26 ----4.00 110.14 --------2.00 55.07Sher-loxane 800 Part A 305 10.89 3,319 0.77 235 ------------------------Sher-loxane 800 Part B 76 8.22 626 0.77 59 ------------------------Zinc-Clad II Part A 38 10.66 402 2.80 106 ------------1.00 4.02 --------Zinc-Clad II Part B 38 6.91 260 2.80 106 ----9.10 23.70 ----------------
Total 5,005 52,861 13,877 201.21 23.70 128.19 4.02 ######643.73HAP Total (lb/yr)######
VOCEmission Rate Emissions(lb/hr)(lb/hr)(lb/hr)(lb/hr)(lb/hr)(lb/hr)(lb/hr)Average 1.58 0.02 0.00 0.01 0.00 0.79 0.07Maximum0.06 0.08 0.11 0.01 0.71 0.25
The average lb/hr emission rates were calculated assuming 8760 hours of cure timeThe maximum lb/hr emission rates were calculated assuming both that the product with the highest individual HAP percentage was applied at a rate of 3 gal/hr and that the cure time is 24 hours.
Emission Threshold Values (lb/hr)4.429 14.201 4.764 2.674 3.843 4.429
Xylene
Xylene100-41-4 1330-20-7
Ethylbenzene100-41-4 67-56-1 108-10-1 91-20-3 108-88-3 1330-20-7
67-56-1 108-10-1
Methanol MIBK Naphthalene Toluene
91-20-3 108-88-3EthylbenzeneMethanolMIBKNaphthaleneToluene
Road Dust Emissions Calculations
ControlPollutantEfficiency(%)(ton/yr)(lb/hr)(ton/yr)(lb/hr)(g/sec)CEFront-end Loader PM10 85 0.04 0.00 0.01 0.00 0.0000TrucksPM10850.18 4.45 0.03 0.67 0.08410.21 0.03
Front-end Loader PM2.5 85 0.00 0.00 0.00 0.00 0.0000TrucksPM2.5 85 0.02 0.44 0.00 0.07 0.0084Total0.02 0.00
(ton/yr)(ton/hr)(ft/trip)(vmt/load)(vmt/yr)(vmt/hr)
Forklifts 500 1,320 0.25 63 0.00Front-end Loaders 7,500 2,640Trucks8,000 100 3,168 0.60 192 2.40
Particle MeanSizeSurface Silt Vehicle Vehicle Vehicle EmissionPollutantMultiplierContentWeightCapacityWeightFactor(%)(ton)(ton/load)(ton)(lb/vmt)k s W EFForkliftsPM101.5 4.8 10 2 11 1.18Frontend Loaders PM10 1.5 4.8 10 25 22.5 1.63TrucksPM101.5 4.8 17.5 25 30 1.85
Trucks PM2.5 0.15 4.8 10 2 11 0.12Front-end Loader PM2.5 0.15 4.8 17.5 25 30 0.19
Source
Production Length of DistanceSourceRateTripTraveled
ER ER
PR LT DT
Uncontrolled ControlledSourceEmissionsEmissions
Source of Data:
Particle Size Multiplier:Table 13.2.2-2Surface Silt Content:Table 13.2.2-1Vehicle Weight:Utah Pacific Bridge and SteelVehicle Capacity:Utah Pacific Bridge and SteelEmission Factor:AP-42, Fifth Edition, Section 13.2.2, 11/06Unpaved RoadsPages 13.2.2-4 & 13.2.2-5Production Rate :Utah Pacific Bridge and SteelLength of Trip:Utah Pacific Bridge and SteelDistance Traveled:CalculatedControl Efficiency:DAQ MemorandumEmission Rate:Calculated
Notes:
The Average Vehicle Weight (W) is the average of the loaded and empty vehicle weight.The control efficiency is estimated based on gravel roads, watering, and the application of chemical surfacants.
7,000 BTU/hp-hrEquipment DetailsRating 275 hp = (205.3 kw)Table 3.3-1Operational Hours 100 hours/year <600 hpSulfur Content 15 ppm or 0.0015%lb/hp-hr lb/hr Ton/yearCheck EF x S lb/hp-hr lb/hr Ton/year CheckNox - Uncontrolled 0.031 8.53 0.43 Match 0.024 6.60 0.33
Criteria Pollutant
EmissionStandards(g/hp-hr)
Emission Factor(lb/hp-hr)
EmissionRate(lbs/hr)
Total(tons/year)Reference Nox - Controlled 0.013 3.58 0.18NOX0.031 8.53 0.43 CO 6.68E-03 1.84 0.09 Match 5.50E-03 1.51 0.08CO6.68E-03 1.84 0.09 SO2 2.05E-03 0.56 0.03 8.09E-03 1.21E-05 0.00 0.00 Match Used>600 hp to allow for sulfur content of fuelPM102.20E-03 0.61 0.03 PM10 2.20E-03 0.61 0.03 Match 0.0007 0.19 0.01 Table 3.3-1 does not allow for a sulfur content.PM2.5 2.20E-03 0.61 0.03 CO2 1.15E+00 316 16 Match 1.16 319 16 To be more representatvie, Table 3.4-1 was used for all engine sizes.
VOC 2.51E-03 0.69 0.03 Aldehydes 4.63E-04 Not used, included in HAP below.SO2 1.21E-05 0.00 0.00 AP-42 Table 3.4-1 TOC 2.51E-03 0.69 0.03 7.05E-04 0.19 0.01 for engines >600 hp, TOC is 91% VOC & 9% methaneHAP0.01 0.00 See Below VOC 2.51E-03 0.69 0.03 Match 91%6.42E-04 0.18 0.01MethaneMatch9%6.35E-05 0.02 0.00
Green House Gas Pollutant
Global Warming Potential
Emission Factor(lb/hp-hr)
EmissionRate(lbs/hr)
Total(tons/year)Reference Exhaust 2.47E-03CO2 (mass basis)1 1.15E+00 316 16 Evaporative 0.00Methane (mass basis)25 0 0 Crankcase 4.41E-05CO2e16Refueling0.00
Hazardous Air Pollutant
EmissionRate(lbs/hr)
Total(tons/year)Reference HAP
Table 3.3-2<600 hp(lb/MMBtu)lb/hp-hr lb/hr Ton/year Check
Table 3.4-3>600 hp(lb/MMBtu)lb/hp-hr lb/hr Ton/year CheckBenzene9.33E-04 1.80E-03 8.98E-05 Benzene 9.33E-04 6.53E-06 1.80E-03 8.98E-05 Match 7.76E-04 5.43E-06 1.49E-03 7.47E-05Toluene4.09E-04 7.87E-04 3.94E-05 Toluene 4.09E-04 2.86E-06 7.87E-04 3.94E-05 Match 2.81E-04 1.97E-06 5.41E-04 2.70E-05Xylenes2.85E-04 5.49E-04 2.74E-05 Xylenes 2.85E-04 2.00E-06 5.49E-04 2.74E-05 Match 1.93E-04 1.35E-06 3.72E-04 1.86E-051,3-Butadiene 3.91E-05 7.53E-05 3.76E-06 1,3-Butadiene 3.91E-05 2.74E-07 7.53E-05 3.76E-06 MatchFormaldehyde1.18E-03 2.27E-03 1.14E-04 Formaldehyde 1.18E-03 8.26E-06 2.27E-03 1.14E-04 Match 7.89E-05 5.52E-07 1.52E-04 7.59E-06Acetaldehyde7.67E-04 1.48E-03 7.38E-05 Acetaldehyde 7.67E-04 5.37E-06 1.48E-03 7.38E-05 Match 2.52E-05 1.76E-07 4.85E-05 2.43E-06Acrolein9.25E-05 1.78E-04 8.90E-06 Acrolein 9.25E-05 6.48E-07 1.78E-04 8.90E-06 Match 7.88E-06 5.52E-08 1.52E-05 7.58E-07Naphthalene8.48E-05 1.63E-04 8.16E-06 Naphthalene 8.48E-05 5.94E-07 1.63E-04 8.16E-06 Match 1.30E-04 9.10E-07 2.50E-04 1.25E-05Acenaphthylene5.06E-06 9.74E-06 4.87E-07 Acenaphthylene 5.06E-06 3.54E-08 9.74E-06 4.87E-07 Match 9.23E-06 6.46E-08 1.78E-05 8.88E-07Acenaphthene1.42E-06 2.73E-06 1.37E-07 Acenaphthene 1.42E-06 9.94E-09 2.73E-06 1.37E-07 Match 4.68E-06 3.28E-08 9.01E-06 4.50E-07Fluorene2.92E-05 5.62E-05 2.81E-06 Fluorene 2.92E-05 2.04E-07 5.62E-05 2.81E-06 Match 1.28E-05 8.96E-08 2.46E-05 1.23E-06Phenanthrene2.94E-05 5.66E-05 2.83E-06 Phenanthrene 2.94E-05 2.06E-07 5.66E-05 2.83E-06 Match 4.08E-05 2.86E-07 7.85E-05 3.93E-06Anthracene1.87E-06 3.60E-06 1.80E-07 Anthracene 1.87E-06 1.31E-08 3.60E-06 1.80E-07 Match 1.23E-06 8.61E-09 2.37E-06 1.18E-07Fluoranthene7.61E-06 1.46E-05 7.32E-07 Fluoranthene 7.61E-06 5.33E-08 1.46E-05 7.32E-07 Match 4.03E-06 2.82E-08 7.76E-06 3.88E-07Pyrene4.78E-06 9.20E-06 4.60E-07 Pyrene 4.78E-06 3.35E-08 9.20E-06 4.60E-07 Match 3.71E-06 2.60E-08 7.14E-06 3.57E-07Benz(a)anthracene 1.68E-06 3.23E-06 1.62E-07 Benz(a)anthracene 1.68E-06 1.18E-08 3.23E-06 1.62E-07 Match 6.22E-07 4.35E-09 1.20E-06 5.99E-08Chrysene3.53E-07 6.80E-07 3.40E-08 Chrysene 3.53E-07 2.47E-09 6.80E-07 3.40E-08 Match 1.53E-06 1.07E-08 2.95E-06 1.47E-07Benzo(b)fluoranthene 9.91E-08 1.91E-07 9.54E-09 Benzo(b)fluoranthene 9.91E-08 6.94E-10 1.91E-07 9.54E-09 Match 1.11E-06 7.77E-09 2.14E-06 1.07E-07Benzo(k)fluoranthene 1.55E-07 2.98E-07 1.49E-08 Benzo(k)fluoranthene 1.55E-07 1.09E-09 2.98E-07 1.49E-08 Match 2.18E-07 1.53E-09 4.20E-07 2.10E-08Benzo(a)pyrene 1.88E-07 3.62E-07 1.81E-08 Benzo(a)pyrene 1.88E-07 1.32E-09 3.62E-07 1.81E-08 Match 2.57E-07 1.80E-09 4.95E-07 2.47E-08Indeno(1,2,3-cd)pyrene 3.75E-07 7.22E-07 3.61E-08 Indeno(1,2,3-cd)pyrene 3.75E-07 2.63E-09 7.22E-07 3.61E-08 Match 4.14E-07 2.90E-09 7.97E-07 3.98E-08Dibenz(a,h)anthracene 5.83E-07 1.12E-06 5.61E-08 Dibenz(a,h)anthracene 5.83E-07 4.08E-09 1.12E-06 5.61E-08 Match 3.46E-07 2.42E-09 6.66E-07 3.33E-08Benzo(g,h,l)perylene 4.89E-07 9.41E-07 4.71E-08 Benzo(g,h,l)perylene 4.89E-07 3.42E-09 9.41E-07 4.71E-08 Match 5.56E-07 3.89E-09 1.07E-06 5.35E-08
AP-42 Table 3.3-1& Table 3.4-1
Emission Factor(lb/MMBtu)
AP-42 Table 3.3-2,Table 3.4-3, &Table 3.4-4
(1,3-Butadiene will not popluate if the engine size is greater than 600 hp. AP-42 does not list 1,3-Butadiene for engines greater than 600 hp.)
Diesel-Fired Engines
Emergency Engines should equal 100 hours of operation per year
Table 3.4-1>600 hp
Manufacturer Data,AP-42 Table 3.3-1,& Table 3.4-1
Page 10 of Version 1.1 February 21, 2019
Katie Andersen <[e-mail]>
Additional Information Request
17 messages
Katie Andersen <[e-mail]>Tue, Sep 10, 2024 at 12:15 PM
To: Tim Sexton <[e-mail]>
Hello Tim,
Thank you for allowing Chad and myself to tour the facility! It was a great help to get a better idea of the process to build
the girders.
I've been working on the approval order for the Utah Pacific Bridge and Steel facility. Based on the notes I took, I have
some additional questions for you.
1. Are there specific names used by UPBS to designate buildings/equipment? I'd like to use the same names in the
permit. Additionally, please send me an equipment list with the designated names of the equipment and where they are
located.
2. Does UPBS use a reclaim system, or reclaim, the blasting media? I seem to recall that the blasting unit on the south
side of the main building has a reclaim system. What about the blasting in the Paint/Blast Building?
3. Will you please send me blasting media documentation so I can verify the media you are using with the calculations
you supplied?
If you have any questions, please let me know.
Cheers,
Katie Andersen
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Tim Sexton <[e-mail]>Tue, Sep 10, 2024 at 3:22 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
Thanks for coming by our facility. It was good meeting you and Chad in person.

10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…1/8
Please see below on your requests:

1. Are there specific names used by UPBS to designate buildings/equipment? I'd like to use the same names in the
permit. Additionally, please send me an equipment list with the designated names of the equipment and where they are
located.
Building Names:
1. Office Building
2. Fabrication shop (this is our main building)
3. Blast/Paint Shed (located just to the west of the north end of the fabrication shop)
4. New Paint Shed (located further west from our fabrication shop)

We have a pretty extensive list of equipment. Would it make sense to send you only the equipment related to our
submission (blast equipment, paint guns, weld equipment, etc.) as apposed to our entire equipment list?

2. Does UPBS use a reclaim system, or reclaim, the blasting media? I seem to recall that the blasting unit on the south
side of the main building has a reclaim system. What about the blasting in the Paint/Blast Building?
Yes, on our blast unit in the south end of our building, we have a dust collection system that also captures stray grit. In
addition, that machine has a collection system at the bottom of the machine that recaptures most of the media used in the
process. In the paint/blast building, we have a dust exhaust system that does not recapture media. The grit that falls to
the metal floor of that blast booth is recaptured in a pit with a bucket elevator.

3. Will you please send me blasting media documentation so I can verify the media you are using with the calculations
you supplied?
Please see attached.

Regards,
Tim

Tim Sexton, PE – CEO
Utah Pacific Bridge & Steel
Office: 801-785-3557
Cell: 563-514-2323
Visit our website at UtahPacificBridge.com
[Quoted text hidden]
3 attachments
10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…2/8
amasteel-us-2023.pdf
178K
amasteel-steel-grit.pdf
113K
amasteel-steel-shot.pdf
115K
Katie Andersen <[e-mail]>Tue, Sep 10, 2024 at 4:25 PM
To: Tim Sexton <[e-mail]>
Tim,
Thank you for the quick response!
An equipment list dealing with equipment related to the submission would be great.
Thanks,
Katie
[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Sep 23, 2024 at 9:48 AM
To: Tim Sexton <[e-mail]>
Hi Tim,
I just want to make sure that I haven't missed an email from you. I haven't yet received an equipment list.
Please send it to me when you get a chance!
Cheers,
Katie Andersen
[Quoted text hidden]
Tim Sexton <[e-mail]>Mon, Sep 23, 2024 at 9:50 AM
To: Katie Andersen <[e-mail]>
Hi Katie,
Thanks for checking back. We are putting the list together and hope to have it to you by the end of the day
tomorrow.

Regards,
Tim
[Quoted text hidden]
Tim Sexton <[e-mail]>Tue, Sep 24, 2024 at 4:09 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
Attached is our equipment list. Please let me know if you need anything else at this point.

10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…3/8
Thanks,
Tim

From: Kae Andersen <[e-mail]>
Sent: Monday, September 23, 2024 9:49 AM
[Quoted text hidden]
[Quoted text hidden]
Equipment list.xlsx
10K
Katie Andersen <[e-mail]>Tue, Sep 24, 2024 at 4:13 PM
To: Tim Sexton <[e-mail]>
Tim,
Thank you! I will let you know if I have any other questions!
Cheers,
Katie
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, Sep 26, 2024 at 12:38 PM
To: Tim Sexton <[e-mail]>
Tim,
Looking over that equipment list, I didn't see a diesel-fired engine listed. The previous compliance inspection noted an
"existing, limited-use, diesel-fired engine" that is estimated to have a rating of 251-275 hp and ran for 100 hours in 2020 to
"provide supplemental power in case of a power outage for a source process that, once started, cannot be interrupted". If
I remember correctly, you mentioned that this engine moves around on the property.
Though the engine may move, if it stays on the property for a year or more, the DAQ considers the engine to be
stationary. Will you send me the manufacturer specifications (specifically the rating and manufacture date or installation
date) and fill out the attached form so that the emissions can be included in the permit? If the manufacturer specification
list unit specific emission standards, you can enter those in yellow column. Otherwise, you only need to enter the rating
and the hours of operation.
I appreciate your assistance!
Cheers,
Katie Andersen
[Quoted text hidden]
Engine - Diesel Fuel.xlsx
76K
Tim Sexton <[e-mail]>Mon, Sep 30, 2024 at 1:43 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
Just to clarify, I believe the unit referenced below is a mobile generator that we use for field work in our yard
(and occasionally on jobsites). I am not aware of us having used it as backup power for our shop in any
instances. Does this change the requirement at all?
10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…4/8

Thanks and regards,
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Oct 1, 2024 at 10:25 AM
To: Christine Bodell <[e-mail]>
I just want to make sure I'm thinking clearly. Even if the generator moves around on the property, they should still account
for the emissions from the unit for when they use it to do field work in their yard, right? Just because they don't use it in
the shop as backup doesn't mean they don't need to incorporate it.
Cheers,
Katie
---------- Forwarded message ---------
From: Tim Sexton <[e-mail]>
Date: Mon, Sep 30, 2024 at 1:44 PM
Subject: RE: Additional Information Request
To: Katie Andersen <[e-mail]>
Hi Katie,
Just to clarify, I believe the unit referenced below is a mobile generator that we use for field work in our yard
(and occasionally on jobsites). I am not aware of us having used it as backup power for our shop in any
instances. Does this change the requirement at all?

Thanks and regards,
Tim

From: Kae Andersen <[e-mail]>
Sent: Thursday, September 26, 2024 12:38 PM
To: Tim Sexton <[e-mail]>
Subject: Re: Addional Informaon Request

Tim,

Looking over that equipment list, I didn't see a diesel-fired engine listed. The previous compliance inspection noted an
"existing, limited-use, diesel-fired engine" that is estimated to have a rating of 251-275 hp and ran for 100 hours in 2020 to
"provide supplemental power in case of a power outage for a source process that, once started, cannot be interrupted". If
I remember correctly, you mentioned that this engine moves around on the property.

Though the engine may move, if it stays on the property for a year or more, the DAQ considers the engine to be
stationary. Will you send me the manufacturer specifications (specifically the rating and manufacture date or installation
date) and fill out the attached form so that the emissions can be included in the permit? If the manufacturer specification
list unit specific emission standards, you can enter those in yellow column. Otherwise, you only need to enter the rating
and the hours of operation.

10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…5/8
I appreciate your assistance!
Cheers,
Katie Andersen

--
[Quoted text hidden]
Christine Bodell <[e-mail]>Tue, Oct 1, 2024 at 11:08 AM
To: Katie Andersen <[e-mail]>
Yes, I would consider it stationary for the purpose of this project if its on site for > 1 year. Let me know what the source
does and I can help with a response, if needed.
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Oct 1, 2024 at 1:00 PM
To: Tim Sexton <[e-mail]>
Hi Tim,
That does not change the requirements since it is still a generator that is being used on site. We'll need to add it to the
equipment list and add the emissions to the estimate.
Please fill out and send me the spreadsheet I sent you, along with the manufacturer specifications.
Thank you!
Katie Andersen
[Quoted text hidden]
Tim Sexton <[e-mail]>Wed, Oct 2, 2024 at 5:56 PM
To: Katie Andersen <[e-mail]>
Thanks, Katie. I’ll track down the information on the machine and should have a response to you tomorrow.

Regards,
[Quoted text hidden]
Tim Sexton <[e-mail]>Thu, Oct 3, 2024 at 5:18 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
Our diesel-fired generator was manufactured by United Power Products on 06/07/06. It is Part # STP
NT150B and has a rating of 275 HP. I don’t have any other emissions data for the generator. Attached is
the Excel file.

Thanks and regards,
Tim
10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…6/8

From: Tim Sexton
Sent: Wednesday, October 2, 2024 5:56 PM
To: Kae Andersen <[e-mail]>
Subject: RE: Addional Informaon Request

Thanks, Katie. I’ll track down the information on the machine and should have a response to you tomorrow.
[Quoted text hidden]
Engine - Diesel Fuel_UPBS.xlsx
76K
Katie Andersen <[e-mail]>Fri, Oct 4, 2024 at 9:52 AM
To: Tim Sexton <[e-mail]>
Tim,
Thank you for providing this information! I've updated the emission estimate that was provided in the NOI application. In
reviewing the calculations, I made some adjustments that I'd like to confirm with you. I found that AP-42 Table 13.2.6-1
also contained PM2.5 emission factor information for Blasting activities. I've included PM2.5 emissions from blasting. I
also changed the assumption that PM2.5 is 50% of PM10. For conservative estimates, we like to assume that PM2.5
equals PM10 when we cannot find emission factors for PM2.5. I've made this adjustment in the spreadsheet.
Would you mind taking a look at this updated spreadsheet and let me know if you have any issues with the changes I've
made? If there are no issues, these values will become the permitted emissions.
Cheers,
Katie
PTE UPBS
[Quoted text hidden]
Tim Sexton <[e-mail]>Mon, Oct 7, 2024 at 4:31 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
I’m currently reviewing the file you sent back and will plan to have a response to you tomorrow or
Wednesday.
[Quoted text hidden]
Tim Sexton <[e-mail]>Wed, Oct 9, 2024 at 4:17 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
I’ve reviewed the modifications you made to the calculations and agree with them, based on the
conservative assumption you use that PM2.5 = PM 10.

10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…7/8
Regards,
[Quoted text hidden]
10/10/24, 10:03 AM State of Utah Mail - Additional Information Request
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7233513283378088376&simpl=msg-a:r-38908870415435…8/8
Area Brand Model Quantity
Blasting Blastec Wheelabrator 9709 1
Blasting Clemco blasting System CBC-05106 1
Blasting BAABS Blasting guns 422-01P 2
Paint King Paint tank A0792 1
Paint Graco Paint Guns Extreme x30 2
Cutting Kinetic Plasma cutter 3725 1
Welding Dart Welder 2102 1
Welding Miller Welders DC1000 9
Welding Miller Welders Big Blue 600 3
Welding Lincoln DC1000 12
Welding Lincoln DC600 7
Welding ESAB Avenger 2 1
Mobile United Power Products NT150B 1
Use
Sand Blast flat sheets of steel Added.
blast formed girders before painting Added.
Guns used with Clemco System Added.
Paint system for holding Mixed paint Added.
Used with King system to apply paint Added.
Used to Cut Steel Plate Added.
Welder used for welding on formed girders Added.
Locational Welding Added.
Locational Welding Added.
Locational Welding Added.
Locational Welding Added.
Sub-Arc flange-to-web welds Added.
diesel fired generator for mobile welding in the yard, rating is 275 HP

Chemical Composition

Carbon ……………………. .80 - 1.2% Sulfur ………………………. .05% max
Manganese ……………….. .60 – 1.2% Phosphorus ……………….. .05% max
Silicon ……………………… .40% min

Microstructure: Tempered Martensite
Shape: Angular
Density: 7.3 gm / cc

(in)(mm)G10 G12 G14 G16 G18 G25 G40 G50 G80 G120
7 0.1110 2.80 All Pass
8 0.0937 2.36 All Pass
10 0.0787 2.00 80% min All Pass
12 0.0661 1.70 90% min 80% min All Pass
14 0.0555 1.40 90% min 80% min All Pass
16 0.0469 1.18 90% min 75% min All Pass
18 0.0394 1.00 85% min 75% min All Pass
20 0.0331 0.850
25 0.0278 0.710 85% min 70% min All Pass
30 0.0234 0.600
35 0.0197 0.500
40 0.0165 0.425 80% min 70% min All Pass
45 0.0139 0.355
50 0.0117 0.300 80% min 65% min All Pass
80 0.0070 0.180 75% min 65% min
120 0.0049 0.125 75% min 60% min
140 0.0041 0.106
170 0.0035 0.090
200 0.0029 0.075 70% min
U.S. Sieve
Size
Sieve Opening SAE J-444 Shot Screening Specifications
Technical Data Sheet
AMASTEEL High Carbon Cast Steel Grit
Sizing

Product Specifications

General Appearance: No more than 40% of the grit particles shall have objectionable characteristics
Particle Shape: No more than 5% round or half-round particles for hard grits. No more than 10% round or
half-round particles for soft grits.
Shrinkage: No more than 10% of the particles shall contain shrinkage: defined as an internal cavity
with an irregular dendritic surface whose area is greater than 40% of the particle area
Cracks: No more than 40% of the particles shall contain major cracks: defined as a linear
discontinuity whose length is greater than 3 times its width and is radial in direction

SAE J-1993
SAE J-444
SAE J-1993
Hardness: S Hardness: 40 – 51 HRC
M Hardness: 47 – 56 HRC
L Hardness: 54 – 61 HRC
H Hardness: 60 HRC minimum

Ervin Industries
P.O. Box 1168
Ann Arbor, MI 48106
Toll Free 800.748.0055
Phone: [phone] Fax: [phone]
www.ervinindustries.com

Chemical Composition

Carbon ……………………. .80 - 1.2% Silicon ……………………… .4% min
Manganese Sulfur ………………………. .05% max
S-70 - S-110 ………….. .35 - 1.2% Phosphorus ……………….. .05% max
S-170 ………………….. .50 - 1.2%
S-230 & larger ………… .60 - 1.2%
Microstructure: Tempered Martensite
Shape: Round
Density: 7 gm / cc

(in)(mm)S780 S660 S550 S460 S390 S330 S280 S230 S170 S110 S70
7 0.1110 2.80 All Pass
8 0.0937 2.36 All Pass
10 0.0787 2.00 85% min All Pass All Pass
12 0.0661 1.70 97% min 85% min 5% max All Pass
14 0.0555 1.40 97% min 85% min 5% max All Pass
16 0.0469 1.18 97% min 85% min 5% max All Pass
18 0.0394 1.00 96% min 85% min 5% max All Pass
20 0.0331 0.850 96% min 85% min 10% max All Pass
25 0.0278 0.710 96% min 85% min 10% max
30 0.0234 0.600 96% min 85% min All Pass
35 0.0197 0.500 97% min 10% max
40 0.0165 0.425 85% min All Pass
45 0.0139 0.355 97% min 10% max
50 0.0117 0.300 80% min
80 0.0070 0.180 90% mion 80% min
120 0.0049 0.125 90% min
U.S.
Sieve
Size
Sieve Opening SAE J-444 Shot Screening Specifications
Technical Data Sheet
AMASTEEL High Carbon Cast Steel Shot
Sizing

Product Specifications

General Appearance: No more than 20% of the particles shall have objectionable characteristics
Particle Shape: No more than 5% of the particles shall be elongated. An elongated particle is one whose
length is in excess of twice the maximum particle width.
Voids: No more than 10% of the particles contain objectionable voids: defined as an internal hole
that is larger than 10% of the cross section area of the particle
Shrinkage: No more than 10% of the particles contain objectionable shrinkage: defined as an internal
cavity with an irregular dendritic surface whose area is larger than 40% of the particle area
Cracks: No more than 15% of the particles shall contain objectionable cracks: defined as a linear
discontinuity whose length is greater than 3 times its width and radial in orientation

SAE J-827
SAE J-444
SAE J-827
Hardness: S (standard): 40 – 51 HRC
M Hardness: 47 – 56 HRC
L Hardness: 54 – 61 HRC
H Hardness: 60 HRC minimum

Ervin Industries
P.O. Box 1168
Ann Arbor, MI 48106
Toll Free 800.748.0055
Phone: [phone] Fax: [phone]
www.ervinindustries.com

Page 1/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
55.2.3
1 Identification
2 Hazard(s) identification
Classification of the substance or mixture
The product is not classified, according to the Globally Harmonized System (GHS).
Label elements
GHS label elements Void
Hazard pictograms Void
Signal word Void
Hazard statements Void
Classification system:
NFPA ratings (scale 0 - 4)
Health = 0
Fire = 0
Reactivity = 0
HMIS-ratings (scale 0 - 4)
Health = 0
Fire = 0
Reactivity = 0
Other hazards
Results of PBT and vPvB assessment
PBT:Not applicable.
vPvB:Not applicable.
3 Composition/information on ingredients
Chemical characterization: Mixtures
Description:Mixture: consisting of the following components.
Dangerous components:
carbon7440-44-0 0.80-1.20%
manganese7439-96-5 0.35-1.20%
silicon7440-21-3 0.40-1.50%
sulfur7704-34-9 <0.05%
Nickel7440-02-0 <0.2%
(Contd. on page 2)
US
Product identifier
Trade name: AMASTEEL
Details of the supplier of the safety data sheet
Manufacturer/Supplier:
Ervin Industries, Inc.
3893 Research Park Drive
Ann Arbor, MI 48108-2217
Phone: [phone]/Fax: [phone]
[e-mail]
http://www.ervinindustries.com
Information department:
Quality Assurance Department
(mo-thu: 8 a.m.-4 p.m., fr: 8 a.m. - 1 p.m.)
Emergency telephone number: Phone: [phone]/Fax: [phone]
EUPCS: PC-TEC-12
Page 2/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 1)
55.2.3
7723-14-0 red phosphorus <0.05%
4 First-aid measures
Description of first aid measures
General information:No special measures required.
After inhalation:
Supply fresh air; consult doctor in case of complaints.
In case of unconsciousness place patient stably in side position for transportation.
After skin contact:
Rinse with warm water.
If skin irritation continues, consult a doctor.
After eye contact:
Rinse opened eye for several minutes under running water.
Consult a doctor.
After swallowing:
Rinse out mouth and then drink plenty of water.
If symptoms persist consult doctor.
Information for doctor:
Most important symptoms and effects, both acute and delayed No further relevant information available.
Indication of any immediate medical attention and special treatment needed
No further relevant information available.
5 Fire-fighting measures
Extinguishing media
Suitable extinguishing agents:
CO2, sand, extinguishing powder. Do not use water.
Use fire fighting measures that suit the environment.
For safety reasons unsuitable extinguishing agents:Water
Special hazards arising from the substance or mixture
Product is not flammable.
Fine metal dust removed as a waste stream and / or contamination during the blasting process,
poses a small minor risk of causing a fire or explosion.
Advice for firefighters
Protective equipment:No special measures required.
6 Accidental release measures
Personal precautions, protective equipment and emergency procedures
Scrap and debris can cause slip and fall hazards. It is recommended that floors and work areas be kept clean at all
times.
floors and work areas clean at all times.
Environmental precautions:No special measures required.
Methods and material for containment and cleaning up:Pick up mechanically.
Reference to other sections
See Section 7 for information on safe handling.
See Section 8 for information on personal protection equipment.
See Section 13 for disposal information.
None
None
(Contd. on page 3)
US
Page 3/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 2)
55.2.3
Protective Action Criteria for Chemicals
PAC-1:
7439-96-5 manganese 3 mg/m³
7440-21-3 silicon 45 mg/m³
7440-44-0 carbon 6 mg/m³
7723-14-0 red phosphorus 0.27 mg/m³
7440-02-0 Nickel 6 mg/m³
PAC-2:
7439-96-5 manganese 5 mg/m³
7440-21-3 silicon 100 mg/m³
7440-44-0 carbon 330 mg/m³
7723-14-0 red phosphorus 3 mg/m³
7440-02-0 Nickel 330 mg/m³
PAC-3:
7439-96-5 manganese 1,800 mg/m³
7440-21-3 silicon 630 mg/m³
7440-44-0 carbon 2,000 mg/m³
7723-14-0 red phosphorus 18 mg/m³
7440-02-0 Nickel 2,000 mg/m³
7 Handling and storage
Handling:
Precautions for safe handling
Take special care to prevent the product from leaking. Exercise special care when
removing the tie-down straps that are part of the bulk pallet shipments.
Information about protection against explosions and fires:No special measures required.
Conditions for safe storage, including any incompatibilities
Storage:
Requirements to be met by storerooms and receptacles:No special requirements.
Information about storage in one common storage facility:Not required.
Further information about storage conditions:None.
Storage class:13
Specific end use(s)No further relevant information available.
8 Exposure controls/personal protection
Additional information about design of technical systems:No further data; see item 7.
Control parameters
Components with limit values that require monitoring at the workplace:
The following constituents are the only constituents of the product which have a PEL, TLV or other recommended
exposure limit.
At this time, the other constituents have no known exposure limits.
(Contd. on page 4)
US
Page 4/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 3)
55.2.3
7439-96-5 manganese
PEL Ceiling limit value: 5 mg/m³
as Mn
REL Short-term value: 3 mg/m³
Long-term value: 1 mg/m³
fume, as Mn
TLV Long-term value: 0.02* 0.1** mg/m³
as Mn; A4, *respirable **inhalable fraction
7440-21-3 silicon
PEL Long-term value: 15* 5** mg/m³
*total dust **respirable fraction
REL Long-term value: 10* 5** mg/m³
*total dust **respirable fraction
TLV TLV withdrawn
Regulatory information
PEL: Guide to Occupational Exposure Values (OSHA PELs)
REL: Guide to Occupational Exposure Values (NIOSH RELs)
TLV: Guide to Occupational Exposure Values (TLV)
Additional information:The lists that were valid during the creation were used as basis.
Exposure controls
Personal protective equipment:
Breathing equipment:
Use suitable respiratory protective device in case of insufficient ventilation.
Filter P2
Protection of hands:Leather gloves
Material of gloves Recommended thickness of the material: - mm
Penetration time of glove material Value for the permeation: Level -
Eye protection:Safety glasses
Body protection:Protective work clothing
9 Physical and chemical properties
Information on basic physical and chemical properties
General Information
Appearance:
Form:Solid
Odor:Odorless
Odor threshold:Not determined.
pH-value:Not applicable.
Change in condition
Melting point/Melting range:1500 °C (2,732 °F) (~2700 °F)
Boiling point/Boiling range:3000 °C (5,432 °F) (~5400 °F)
Flash point:Not applicable.
Flammability (solid, gaseous):Not determined.
Decomposition temperature:Not determined.
Auto igniting:Product is not selfigniting.
Danger of explosion:Product does not present an explosion hazard.
(Contd. on page 5)
US
Page 5/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 4)
55.2.3
Explosion limits:
Lower:Not determined.
Upper:Not determined.
Vapor pressure:Not applicable.
Density at 20 °C (68 °F):7.8 g/cm³ (65.09 lbs/gal)
Relative density Not determined.
Vapor density Not applicable.
Evaporation rate Not applicable.
Solubility in / Miscibility with
Water:Insoluble.
Partition coefficient (n-octanol/water):Not determined.
Viscosity:
Dynamic:Not applicable.
Kinematic:Not applicable.
Solvent content:
VOC content:0.00 %
Solids content:100.0 %
Other information No further relevant information available.
10 Stability and reactivity
Reactivity No further relevant information available.
Chemical stability
Thermal decomposition / conditions to be avoided:No decomposition if used according to specifications.
Possibility of hazardous reactions No dangerous reactions known.
Conditions to avoid No further relevant information available.
Incompatible materials:No further relevant information available.
Hazardous decomposition products:No dangerous decomposition products known.
11 Toxicological information
Information on toxicological effects
Acute toxicity:
Primary irritant effect:
on the skin:No irritant effect.
on the eye:No irritating effect.
Sensitization:
Examination nickel release in accordance with DIN EN 1811: 2012-10: done
Sample Number 2016-00916
<0.1 g per cm2 and week
therefore no sensitization detected
Additional toxicological information:
The product is not subject to classification according to internally approved calculation methods for preparations:
When used and handled according to specifications, the product does not have any harmful effects according to our
experience and the information provided to us.
Carcinogenic categories
IARC (International Agency for Research on Cancer)
7440-02-0 Nickel 1
(Contd. on page 6)
US
Page 6/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 5)
55.2.3
NTP (National Toxicology Program)
7440-02-0 Nickel R
OSHA-Ca (Occupational Safety & Health Administration)
None of the ingredients is listed.
12 Ecological information
Toxicity
Aquatic toxicity:No further relevant information available.
Persistence and degradability No further relevant information available.
Behavior in environmental systems:
Bioaccumulative potential No further relevant information available.
Mobility in soil No further relevant information available.
Additional ecological information:
General notes:Not hazardous for water.
Results of PBT and vPvB assessment
PBT:Not applicable.
vPvB:Not applicable.
Other adverse effects No further relevant information available.
13 Disposal considerations
Uncleaned packagings:
Recommendation:
Disposal must be made according to official regulations.
completely emptied packaging in 25kg paper bag: paper recycling
completely emptied packaging in big bags: commercial waste disposal
completely emptied packaging in steel barrels: metal recycling
14 Transport information
UN-Number
DOT, ADR, ADN, IMDG, IATA Void
UN proper shipping name
DOT, ADR, ADN, IMDG, IATA Void
Transport hazard class(es)
DOT, ADR, ADN, IMDG, IATA
Class Void
Packing group
DOT, ADR, IMDG, IATA Void
Environmental hazards:Not applicable.
Special precautions for user Not applicable.
Transport in bulk according to Annex II of
MARPOL73/78 and the IBC Code Not applicable.
(Contd. on page 7)
US
Page 7/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 6)
55.2.3
UN "Model Regulation":Void
15 Regulatory information
Safety, health and environmental regulations/legislation specific for the substance or mixture
Sara
Section 355 (extremely hazardous substances):
7723-14-0 red phosphorus
Section 313 (Specific toxic chemical listings):
7439-96-5 manganese
7723-14-0 red phosphorus
TSCA (Toxic Substances Control Act):
All components have the value ACTIVE.
Hazardous Air Pollutants
7439-96-5 manganese
7723-14-0 red phosphorus
Proposition 65
Warning: This product can expose you to chemicals including Nickel, which is known to the State of California to
cause cancer. For more information go to www.P65Warnings.ca.gov
Chemicals known to cause cancer:
7440-02-0 Nickel
Chemicals known to cause reproductive toxicity for females:
None of the ingredients is listed.
Chemicals known to cause reproductive toxicity for males:
None of the ingredients is listed.
Chemicals known to cause developmental toxicity:
None of the ingredients is listed.
Cancerogenity categories
EPA (Environmental Protection Agency)
7439-96-5 manganese D
7723-14-0 red phosphorus D
TLV (Threshold Limit Value)
None of the ingredients is listed.
NIOSH-Ca (National Institute for Occupational Safety and Health)
None of the ingredients is listed.
GHS label elements Void
Hazard pictograms Void
Signal word Void
Hazard statements Void
National regulations:
Information about limitation of use:Employment restrictions concerning young persons must be observed.
Water hazard class:Generally not hazardous for water.
(Contd. on page 8)
US
Page 8/8
Safety Data Sheet
acc. to OSHA HCS
Printing date 01/15/2023 Reviewed on 05/11/2022
Trade name: Amasteel
(Contd. of page 7)
55.2.3
Chemical safety assessment:A Chemical Safety Assessment has not been carried out.
16 Other information
This information is based on our present knowledge. However, this shall not constitute a guarantee for any specific
product features and shall not establish a legally valid contractual relationship.
Motivo da mudança:
Version 2: 28.05.2015: Section 5.1 Extinguishing agents; 8.1 AGW measuring method.
Version 3: 06.09.2015: Section 1, 15, adaptation to the regulation 453/2015/EC, 830/2015/EU, 18/2012/EU
Version 4: 05.03.2016: Section 1.3
Version 5: 19.06.2016: Section 13
Version 6: 07.06.2019: Section 3, 8
Version 7: 16.02.2020: Section 13
Version 8: 18.02.2021: Section 1, 13, 15
Version 9: 11.05.2022: Section 2, 8, 15
Contact:Dr. W. Assmann
Date of preparation / last revision 01/15/2023
Abbreviations and acronyms:
ADR: Accord relatif au transport international des marchandises dangereuses par route (European Agreement Concerning the International Carriage of
Dangerous Goods by Road)
IMDG: International Maritime Code for Dangerous Goods
DOT: US Department of Transportation
IATA: International Air Transport Association
EINECS: European Inventory of Existing Commercial Chemical Substances
ELINCS: European List of Notified Chemical Substances
CAS: Chemical Abstracts Service (division of the American Chemical Society)
NFPA: National Fire Protection Association (USA)
HMIS: Hazardous Materials Identification System (USA)
VOC: Volatile Organic Compounds (USA, EU)
PBT: Persistent, Bioaccumulative and Toxic
vPvB: very Persistent and very Bioaccumulative
NIOSH: National Institute for Occupational Safety
OSHA: Occupational Safety & Health
TLV: Threshold Limit Value
PEL: Permissible Exposure Limit
REL: Recommended Exposure Limit
* Data compared to the previous version altered.Amasteel
Safety Data Sheet:AMASTEEL
US
Cirrus Consulting, LLC
Cirrus Consulting, LLC Phone: [phone] Westbrook Loop [e-mail] Pea Ridge, Arkansas 72751
August 14, 2024
Utah Division of Air Quality
Post Office Box 144820
Salt Lake City, Utah 84114
Re: Notice of Intent for Utah Pacific Bridge and Steel
Dear Madam/Sir,
On behalf of Utah Pacific Bridge and Steel, Cirrus Consulting, LLC submits the attached Notice of Intent to permit the steel fabrication facility in Lindon, Utah.
Thank you for your assistance. For additional information, please contact Tim Sexton of Utah
Pacific Bridge and Steel at [phone], or by email at [e-mail].
Sincerely,
CIRRUS CONSULTING, LLC
James W. Newby
Attachment
Notice of Intent
c: Tim Sexton, Utah Pacific Bridge and Steel

NOTICE OF INTENT
for
UTAH PACIFIC BRIDGE & STEEL
LINDON, UTAH COUNTY, UTAH
August 14, 2024
Submitted To:
Utah Division of Air Quality
Prepared By:
Cirrus Consulting, LLC
2611 Westbrook Loop Pea Ridge, Arkansas 72751
[phone]

Notice of Intent Page i Utah Pacific Bridge & Steel
August 14, 2024

Table of Contents
INTRODUCTION
SOURCE IDENTIFICATION INFORMATION
NOI APPLICATION INFORMATION
ATTACHMENT 1 – Form 2 – Company information/Notice of Intent (NOI)
ATTACHMENT 2 – Form 3 – Process Information
ATTACHMENT 3 – Form 5 – Emissions Information Criteria/GHGs/HAPs
ATTACHMENT 4 - Calculations
ATTACHMENT 5 – Form 1 – Notice of Intent (NOI) Application Checklist
ATTACHMENT 6 – Site Plan

Notice of Intent Page 1 Utah Pacific Bridge & Steel
August 14, 2024

INTRODUCTION
In accordance with R307-400 of the Utah Air Quality Rules, Utah Pacific Bridge and Steel submits this Notice of Intent (NOI) to permit their facility in Lindon, Utah. The facility manufactures steel products. It was recently determined that the facility can no longer operate as an insignificant source. Volatile organic compound (VOC) emissions
from the coating operations now exceed 5 tons per year.
SOURCE IDENTIFICATION INFORMATION
See Form 2 in Attachement 1 for the company name, mailing address, physical address, telephone number, company contact (with name, mailing address and phone number), source universal transverse mercator coordinates and source standard industrial classification.
The facility is a minor source for all pollutants. There are no current permits. It is
located in Utah County, which is a non-attainment area for PM2.5 and ozone and a maintenance area for PM10. The facility is subject to R307-306 (PM10 Nonattainment and Maintenance Areas: Abrasive Blasting) and R307-350 (Miscellaneous Metal Parts and Products Coatings). Note that R307-304 (Solvent Cleaning) does not apply becazuse
R307-350 applies. The plant is also subject to 40 Code of Federal Regulations, Part 63,
Subpart XXXXXX (National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories).
NOI APPLICATION INFORMATION
See Form 3 in Attachement 2 for a detailed description of the project and processes, fuels, raw materials, and products consumed/produced, description of equipment used in the process and operating schedule. Note that the facility is equipped with front-end
loaders (2X), fork lifts (5X), and mobile cranes (5X).
There are no changes to the process, production rates, etc. A site plan is provided in Attachement 6. Building dimensions can be determined from the scale on the plan. The facility is not equipped with stacks.
Best Available Control Technology (BACT) Analysis
Because of the size of the steel structures being produced, and given the relatively low annual emissions rates, it is not economically feasible to physically control the particulate and VOC emissions associated with cutting, welding blasting and coating application. A majority of the steel does not fit within the existing structure, so the building would have to be enlarged. The volumetric flow through any type of capture device would have to be
very large in order to provide an adequate air turnover rate within the structure.
Notice of Intent Page 2 Utah Pacific Bridge & Steel
August 14, 2024

The types of coatings applied to the steel are typically determined by the agencies, and while Utah Pacific has some choice in the selection, that choice is very limited. Note, however, that Utah Pacific will comply with the coating limitations in R307-350 and
Subpart XXXXXX.
Utah Pacific will comply with the abrasive blasting requirements of R307-306.
Road dust will be controlled using gravel, watering and the application of chemical surfacants, as needed.
Emissions Related Information
See Form 5 in Attachment 3 for a summary of emissions from the facility. Also see the
calculations provided in Attachment 4 for a complete description of emissions from the facility. Note that because of its extremely low vapor pressure, emissions from diesel storage are assumed to be insignificant.
The Excel workbook used to prepare the calculations is being provided with this NOI.
Also, the product safety data sheets used for the calculations are being provided.
Emissions Impact Analysis
Emissions from the facility are below the thresholds for modeling. Particulate and VOC emissions are less than 5 tpy and 40 tpy, respectively. HAP emissions are less than the emission threshold values. See the calculations in Attachement 4.
Nonattainment/Maintenance Areas
Not applicable, as the emission increases at the facility are less than the thresholds requiring emissions offsets.
Major Sources in Attainment or Unclassified Areas (PSD)
Not applicable, as the facility is a Prevention of Significant Deterioration (PSD) minor
source.
Signature on Application
See Form 2 in Attachement 1.

Notice of Intent Utah Pacific Bridge & Steel
August 14, 2024

ATTACHMENT 1
FORM 2 – COMPANY INFORMATION / NOTICE OF INTENT (NOI)

1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
Notice of Intent Utah Pacific Bridge & Steel
August 14, 2024

ATTACHMENT 2
FORM 3 – PROCESS INFORMATION

Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information - For New Permit ONLY
1.Name of process:2.End product of this process:
3.Process Description*:
Operating Data
4.Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5.Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6.Maximum Hourly production (indicate units.):
_____________
7.Maximum annual production (indicate units):
________________
8.Type of operation:
Continuous Batch Intermittent
9.If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
tons steel tons steel
See calculations in Attachment 4
Notice of Intent Utah Pacific Bridge & Steel
August 14, 2024

ATTACHMENT 3
FORM 5 – EMISSIONS INFORMATION CRITERIA/GHGs/HAPs

Page 1 of 1
Company_______Utah Pacific_____
Site __Lindon, Utah____________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Notice of Intent Utah Pacific Bridge & Steel
August 14, 2024

ATTACHMENT 4
CALCULATIONS

Emissions Summary
Company:Utah Pacific Bridge & SteelSite:Linden, Utah
Controlled EmissionsSourcePM10PM2.5 SO2 NOX CO VOC
(ton/yr)(ton/yr)(ton/yr)(ton/yr)(ton/yr)(ton/yr)
Welding 0.11 0.06 --------
Blasting 0.50 0.25 --------
Plasma Cutting 0.03 0.01 --0.62 ----
Coating Applications 3.80 1.90 --------
Curing ----------9.02
Road Dust 0.03 0.00 ------
--
Total 4.47 2.22 0.00 0.62 0.00 9.02
For welding, blasting, plasma cutting, and coating applications, there were no emission factors available for PM2.5.
It was estimated PM2.5 emissions are 50 % of PM10 emissions.
Welding Emissions Calculations
Process Material
UPBS
Usage
(lb/yr)
PM-10
(lb/10^3 lb)PM10 (lb/yr)PM10
(lb/hr)
Cr (10^-1
lb/10^3 lb)Cr (lb/yr)Co (10^-1
lb/10^3 lb)Co (lb/yr)Mn (10^-1
lb/10^3 lb)Mn (lb/yr)Ni (10^-1
lb/10^3 lb)Ni (lb/yr)Total HAP
(lb/yr)
Welding SMAW e7018 1,575 18.4 28.98 0.06 0.0095 0.01 0.0016 10.3 1.6223 0.02 0.0032 1.6364WeldingSMAW e8018 810 17.1 13.85 0.17 0.0268 No Data 0.3 0.0243 0.51 0.0413 0.0924WeldingSAW Spoolarc 81 14,400 0.05 0.72 No Data No Data No Data No Data 0.0000WeldingSAW Subarc L61 11,664 0.05 0.58 No Data No Data No Data No Data 0.0000WeldingFCAW R70 ultra 5,184 15.1 78.28 0.04 0.0063 No Data 8.91 4.6189 0.05 0.0259 4.6512WeldingFCAW 71 ultra 8,640 12.2 105.41 0.02 0.0032 0.01 0.0086 6.62 5.7197 0.04 0.0346 5.7660Total227.82 0.05 0.0457 0.0102 11.9852 0.1049 12.1460
Notes:
US EPA AP 42, table 12.19-1, PM-10 Emission factors for welding operations
US EPA AP 42, table 12.19-2, Hazardous Air Pollutant (HAP) Emission factors for welding operationsPM10 lb/hr emission rate calculated assuming 4,410 hours of operation per year (18 hrs per day, 5 days per week, and 49 weeks per year).hours per year
Process Material
UPBS
Usage
(lb/hr)
Cr (10^-1
lb/10^3 lb)Cr (lb/hr)Co (10^-1
lb/10^3 lb)Co (lb/hr)Mn (10^-1
lb/10^3 lb)Mn (lb/hr)Ni (10^-1
lb/10^3 lb)0 Total HAP
(lb/yr)
Welding SMAW e7018 2 0.06 0.00001 0.01 0.00000 10.3 0.00206 0.02 0.00000 0.00208
Welding SMAW e8018 2 0.17 0.00003 No Data 0.3 0.00006 0.51 0.00010 0.00020WeldingFCAW R70 ultra 5 0.04 0.00002 No Data 8.91 0.00446 0.05 0.00003 0.00450
Welding FCAW 71 ultra 5 0.02 0.00001 0.01 0.00001 6.62 0.00331 0.04 0.00002 0.00335Total0.00008 0.00001 0.00989 0.00015 0.01012
Emission Threshold Values (lb/hr)0.0002 0.001 0.01 0.0017
Blasting Emissions Calculations
Process Material
UPBS
Usage
(lb/year)
PM-10
(lb/10^3 lb)PM10 (lb/yr)PM10
(lb/hr)
Blasting Steel Shot S-330 36,000 13 468.00BlastingSteel Grit MG-50 40,320 13 524.16BlastingGarnet5400.69 0.37Total992.53 0.51
Notes:
US EPA AP 42, Table 13.2.6-1, PM-10 Emission factors for abrasive blastingIt is estimated blasting operations take place 8 hours per day, 1,960 hours per year.
Plasma Cutting Emissions Calculations
Process Material
UPBS
Estimated
Cutting
Time
(min/year)
PM-10
(g/min)*PM10 (lb/yr)PM10
(lb/hr)NOx (l/min)Total NOx
(lb/yr)**
Total NOx
(lb/hr)
Plasma Cutting (g/min method)Mild Steel 88200 0.30 58.33 0.04 4.60 1234.33 0.84
Notes:
Emission of Fumes, Nitrogen Oxides, and Noise in Plasma Cutting of Stainless and Mild Steel, Bromsen B. et al, IIW Document 1E-174-93, 1994* Assume 35mm average material thickness for cutting, semidry. 6 hours per working day cutting. Also assume fumes for 35mm mild steel would be the same as those for 35mm stainless steel. It is estimated pplasma cutting operations take place 6 hours per day, 1,470 hours per year.** Density: 8% @ 1.88 g/l (NO2) & 92% @ 1.34 g/l (NO) = 1.38 g/l
Coating Application Emissions Calculations
Production Over-Uncontrolled
Source Pollutant Rate Spray Emissions
(lb/yr)(lb/hr)(%)(ton/yr)(lb/hr)
PR OS ER
Paint Area PM-10 50,679 41.37 15 3.801 6.206
The annual coating application rate is conservatively estimated as the non VOC portion of the paint currently required multiplied by a safety factor of 1.3.
Pounds per hour emission rate was calculated assuming 1,225 hours per year of operation (5 hr/day x 5 day/wk x 49 wk/yr).Paint is applied with an airless spray gun. Because of the large size of the surfaces being painted, overspray for the operation is estimated at 15 percent.
Curing Emissions Calculations
Product Product Product VOC VOCProductUsageDensityUsageDensityEmissions(gal/yr)(lb/gal)(lb/yr)(lb/gal)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)(%)(lb/yr)Carboguard 60 Part A 20 11.66 233 2.00 40 4.01 9.35 ------------0.10 0.23 17.00 39.65Carboguard 60 Part B 20 13.49 270 2.00 40 1.01 2.73 ----6.69 18.05 --------3.51 9.47Carboguard 890 Part A 39 10.74 419 1.79 70 1.71 7.17 ----------------7.17 30.04Carboguard 890 Part B 39 13.33 520 1.79 70 1.40 7.28 ------------3.32 17.26 5.82 30.25Carboguard 893 Part A 520 12.99 6,750 1.63 845 0.59 39.82 ------------4.48 302.40 1.43 96.52Carboguard 893 Part B 520 12.66 6,577 1.63 845 ------------------------Carboline Thinner 800 7.08 5,664 7.09 5,675 ----------------76.35 4324.25 ----Carbothane 133 HB Part A 51 12.08 621 3.20 164 3.36 20.87 ------------3.61 22.42 14.26 88.57Carbothane 133 HB Urathane Converter 9 8.75 75 3.20 27 2.38 1.78 ----------------10.06 7.54
Carbothane 133 LH Part A 23 14.99 348 2.70 63 ----------------2.38 8.28 ----
Carbothane 133 LH Urathane Converter 6 8.33 48 2.70 16 ------------------------
Carbothane 133 LV Part A 139 13.16 1,831 1.76 245 1.04 19.05 ----------------3.62 66.30
Carbothane 133 LV Urethane Converter 28 9.33 260 1.76 49 ------------------------
Carbothane 134 HS Part A 633 11.49 7,273 2.40 1,521 0.42 30.55 ----------------1.02 74.19
Carbothane 134 HS Urethane Converter 158 9.33 1,476 2.40 380 ------------------------
Carbozinc 11 HS Activator 269 7.83 2,107 2.40 647 ------------------------Carbozinc 11 HS Base 27 10.49 282 2.40 65 ------------------------Carbozinc 859 Part A 530 10.8277 5,742 2.72 1,443 0.61 35.03 ------------21.48 1233.38 1.48 84.98Carbozinc 859 Part B 303 7.3295 2,221 2.72 824 0.62 13.77 ------------45.87 1018.81 1.50 33.32Macropoxy 646-100 Part A 208 13.41 2,783 0.83 172 0.20 5.57 ----------------1.00 27.83Macropoxy 646-100 Part B 208 13.27 2,754 0.83 172 0.30 8.26 ----4.00 110.14 --------2.00 55.07Sher-loxane 800 Part A 305 10.89 3,319 0.77 235 ------------------------Sher-loxane 800 Part B 76 8.22 626 0.77 59 ------------------------Zinc-Clad II Part A 38 10.66 402 2.80 106 ------------1.00 4.02 --------Zinc-Clad II Part B 38 6.91 260 2.80 106 ----9.10 23.70 ----------------
Total 5,005 52,861 13,877 201.21 23.70 128.19 4.02 6,927.03 643.73HAP Total (lb/yr)7,927.89
VOCEmission Rate Emissions(lb/hr)(lb/hr)(lb/hr)(lb/hr)(lb/hr)(lb/hr)(lb/hr)Average 1.58 0.02 0.00 0.01 0.00 0.79 0.07Maximum0.06 0.08 0.11 0.01 0.71 0.25
The average lb/hr emission rates were calculated assuming 8760 hours of cure time
The maximum lb/hr emission rates were calculated assuming both that the product with the highest individual HAP percentage was applied at a rate of 3 gal/hr and that the cure time is 24 hours.
Emission Threshold Values (lb/hr)4.429 14.201 4.764 2.674 3.843 4.429
Xylene
100-41-4
MIBK Naphthalene TolueneMethanolEthylbenzene
1330-20-767-56-1 108-10-1 91-20-3 108-88-3
100-41-4 67-56-1 108-10-1MIBK NaphthaleneMethanolEthylbenzene 1330-20-791-20-3 108-88-3Toluene Xylene
Road Dust Emissions Calculations
Control Uncontrolled Controlled
Source Pollutant Efficiency Emissions Emissions
(%)(ton/yr)(lb/hr)(ton/yr)(lb/hr)(g/sec)
CE ER ER
Front-end Loader PM10 85 0.04 0.00 0.01 0.00 0.0000
Trucks PM10 85 0.18 4.45 0.03 0.67 0.0841
0.21 0.03
Front-end Loader PM10 85 0.00 0.00 0.00 0.00 0.0000TrucksPM10850.02 0.44 0.00 0.07 0.0084Total0.02 0.00
Production Length of DistanceSourceRateTripTraveled(ton/yr)(ton/hr)(ft/trip)(vmt/load)(vmt/yr)(vmt/hr)PR LT DTForklifts5001,320 0.25 63 0.00Front-end Loaders 7,500 2,640
Trucks 8,000 100 3,168 0.60 192 2.40
Particle Mean
Size Surface Silt Vehicle Vehicle Vehicle Emission
Source Pollutant Multiplier Content Weight Capacity Weight Factor
(%)(ton)(ton/load)(ton)(lb/vmt)
k s W EF
Forklifts PM10 1.5 4.8 10 2 11 1.18
Frontend Loaders PM10 1.5 4.8 10 25 22.5 1.63
Trucks PM10 1.5 4.8 17.5 25 30 1.85
Trucks PM2.5 0.15 4.8 10 2 11 0.12
Front-end Loader PM2.5 0.15 4.8 17.5 25 30 0.19
Road Dust Emissions Calculations
Source of Data:
Particle Size Multiplier:Table 13.2.2-2Surface Silt Content:Table 13.2.2-1Vehicle Weight:Utah Pacific Bridge and Steel
Vehicle Capacity:Utah Pacific Bridge and Steel
Emission Factor:AP-42, Fifth Edition, Section 13.2.2, 11/06
Unpaved Roads
Pages 13.2.2-4 & 13.2.2-5
Production Rate :Utah Pacific Bridge and Steel
Length of Trip:Utah Pacific Bridge and Steel
Distance Traveled:Calculated
Control Efficiency:DAQ Memorandum
Emission Rate:Calculated
Notes:
The Average Vehicle Weight (W) is the average of the loaded and empty vehicle weight.
The control efficiency is estimated based on gravel roads, watering, and the application of chemical surfacants.
Notice of Intent Utah Pacific Bridge & Steel
August 14, 2024

ATTACHMENT 5
FORM 1 – NOTICE OF INTENT (NOI) APPLICATION CHECKLIST

Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
Notice of Intent Utah Pacific Bridge & Steel
August 14, 2024

ATTACHMENT 6
SITE PLAN
Utah Pacific Bridge & Steel
50 N. Geneva RD., Lindon, UT

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Scale
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