DAQ-2024-009604

DAQE-AN161020003-24

{{$d1 }}

Austin Payne
Steves and Sons, Incorporated
203 Humble Avenue
San Antonio, TX 78225
[e-mail]

Dear Mr. Payne:

Re: Approval Order: Modification to Approval Order DAQE-AN161020001-22 to Increase Adhesive
Usage and Emissions
Project Number: N161020003

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
April 1, 2024. Steves and Sons, Incorporated must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Dungan Adams, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well
as the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

cc: Bear River 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

July 26, 2024

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-AN161020003-24
Modification to Approval Order DAQE-AN161020001-22 to
Increase Adhesive Usage and Emissions

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

Issued to
Steves and Sons, Incorporated - Door Manufacturing Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

July 26, 2024
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 ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN161020003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Steves and Sons, Incorporated Steves and Sons, Incorporated - Door
Manufacturing Plant

Mailing Address Physical Address
203 Humble Avenue 1080 North Main Street
San Antonio, TX 78225 Brigham City, UT 84302

Source Contact UTM Coordinates
Name: Austin Payne 415,500 m Easting
Phone: [phone] Ext 1394 4,598,250 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2431 (Millwork)

SOURCE INFORMATION
General Description
Steves and Sons, Incorporated (Steves) operates a wood door manufacturing facility in Brigham City in
Box Elder County. The door manufacturing processes include woodworking, adhesive applications, and
painting operations. Particulate emissions generated from woodworking operations are controlled by
baghouses and cyclones. Particulate emissions from paint booths are controlled with filters. Natural gas
consumption is limited to 70.4 million scf per year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: B

Applicable Federal Standards
None

DAQE-AN161020003-24
Page 4

Project Description
The source has requested to increase adhesive usage at the facility by 661,440 lbs per year. VOC and
HAP emissions are updated to reflect the increases in adhesive usage.

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4230.00
Carbon Monoxide 0 2.96
Nitrogen Oxides 0 3.52
Particulate Matter - PM10 0 9.26
Particulate Matter - PM2.5 0 9.26
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 6.95 34.52

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 40 220
Glycol Ethers (CAS #EDF109) 2260 10340
Hexane (CAS #110543) 0 127
Methanol (CAS #67561) 660 3020
Vinyl Acetate (CAS #108054) 120 540
Change (TPY) Total (TPY)
Total HAPs 1.54 7.12

SECTION I: GENERAL PROVISIONS

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

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

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

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

DAQE-AN161020003-24
Page 5

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

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

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

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 The Brigham City Facility
Wood Door Manufacturing Facility

II.A.2 Wood Working Operations
Two (2) sets of cyclones and baghouses, each set includes a cyclone and a baghouse in series

II.A.3 Adhesive Applications
One (1) automated spreader (minimum 65% transfer efficiency)

II.A.4 Primer Applications
Two (2) paint booths with HVLP sprayers (minimum 65% transfer efficiency)

II.A.5 Various Natural gas Combustion Equipment
Including space heaters, door heaters, and hot water heaters, each rated less than 5 MMBtu/hr
Exempt equipment; for information only

DAQE-AN161020003-24
Page 6

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

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

A. All natural gas combustion equipment - 10% opacity.

B. All baghouse stacks - 10% opacity.

C. All paint booth stacks - 10% opacity.

D. All other points - 10% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to
40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not consume more than 70.4 million scf of natural gas per rolling
12-month period. [R307-401-8]

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

A. Determine natural gas consumption by monthly billing statements from the utility
company.

B. Use the monthly billing statements to calculate a new rolling 12-month total by the
20th day of each month using data from the previous 12 months.

C. Keep the natural gas consumption records for all periods the plant is in operation.

[R307-401-8]

II.B.2 Requirements for Wood Working Operations
II.B.2.a The owner/operator shall install and operate two (2) dust collection and removal systems, each of
which consists of a cyclone and a baghouse in series. All exhaust air from the woodworking
operations, including door sizing, routing, sawing, and grinding, shall be routed through the
cyclone-baghouse systems before being vented to the atmosphere. [R307-401-8]

II.B.2.b The owner/operator shall install and operate a magnehelic pressure gauge to measure the static
pressure drop across each baghouse. [R307-401-8]

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

II.B.2.c The owner/operator shall maintain the static pressure drop across each baghouse during operation
between 1 and 4 inches of water column. [R307-401-8]

II.B.2.c.1 The owner/operator shall record the pressure drop at least once per operating day. [R307-401-8]

DAQE-AN161020003-24
Page 7

II.B.2.c.2 The pressure drop records shall be kept for all periods the plant is in operation. [R307-401-8]

II.B.3 Adhesive Application Requirements
II.B.3.a The owner/operator shall comply with the applicable requirements and limitations in R307-342,
Adhesive and Sealants. [R307-342]

II.B.4 Primer Application Requirements
II.B.4.a The owner/operator shall comply with the applicable requirements and limitations in R307-349,
Flat Wood Paneling Coatings. [R307-349]

II.B.4.b The owner/operator shall install and operate a set of paint arrestor particulate filters for each
paint booth to control particulate emissions. All air exiting the booths shall pass through this
control system before being vented to the atmosphere (outside building/operation). The filters
shall be maintained and replaced according to the manufacturer's instructions. [R307-401-8]

II.B.5 VOC and HAP Requirements
II.B.5.a The owner/operator shall not emit more than the following from evaporative sources (adhesive
and primer applications) on site:

34.32 tons per rolling 12-month period of VOCs.

0.11 tons per rolling 12-month period of formaldehyde.

5.17 tons per rolling 12-month period of glycol ethers.

1.51 tons per rolling 12-month period of methanol.

0.27 tons per rolling 12-month period of vinyl acetate.

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

[R307-401-8]

II.B.5.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]

*18% of formaldehyde, vinyl acetate, and glycol ethers in the adhesive will emit to the
atmosphere; therefore, emissions for these HAPs shall be calculated as 18% multiplied by the
above equation using mass-balance method.

[R307-401-8]

II.B.5.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-AN161020003-24
Page 8

II.B.5.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.

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.5.b The owner/operator shall store the VOC/HAP containing materials in closed and airtight
containers when the materials are not in use. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN161020001-22 dated December 23, 2022
Is Derived From NOI dated April 1, 2024

DAQE-AN161020003-24
Page 9

ACRONYMS

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

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

DAQE-IN161020003-24

June 13, 2024

Austin Payne
Steves and Sons, Incorporated
203 Humble Avenue
San Antonio, TX 78225
[e-mail]

Dear Mr. Payne:

Re: Intent to Approve: Modification to Approval Order DAQE-AN161020001-22 to Increase
Adhesive Usage and Emissions
Project Number: N161020003

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 (AO) 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, Dungan Adams, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dungan Adams, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA:jg

cc: Bear River 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-IN161020003-24
Modification to Approval Order DAQE-AN161020001-22 to
Increase Adhesive Usage and Emissions

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

Issued to
Steves and Sons, Incorporated - Door Manufacturing Plant

Issued On
June 13, 2024

{{$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.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN161020003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Steves and Sons, Incorporated Steves and Sons, Incorporated - Door
Manufacturing Plant

Mailing Address Physical Address
203 Humble Avenue 1080 North Main Street
San Antonio, TX 78225 Brigham City, UT 84302

Source Contact UTM Coordinates
Name: Austin Payne 415,500 m Easting
Phone: [phone] Ext 1394 4,598,250 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2431 (Millwork)

SOURCE INFORMATION
General Description
Steves and Sons, Incorporated (Steves) operates a wood door manufacturing facility in Brigham City in
Box Elder County. The door manufacturing processes include woodworking, adhesive applications, and
painting operations. Particulate emissions generated from woodworking operations are controlled with
baghouses and cyclones. Particulate emissions from paint booths are controlled with filters. Natural gas
consumption is limited to 70.4 million scf per year.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: B

Applicable Federal Standards
None
Project Description
Steves has requested to increase adhesive usage at the facility by 661,440 lbs per year. VOC and HAP
emissions are updated to reflect the increases in adhesive usage.

DAQE-IN161020003-24
Page 4

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4230.00
Carbon Monoxide 0 2.96
Nitrogen Oxides 0 3.52
Particulate Matter - PM10 0 9.26
Particulate Matter - PM2.5 0 9.26
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 6.95 34.52

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 40 220
Glycol Ethers (CAS #EDF109) 2260 10340
Hexane (CAS #110543) 0 127
Methanol (CAS #67561) 660 3020
Vinyl Acetate (CAS #108054) 120 540
Change (TPY) Total (TPY)
Total HAPs 1.54 7.12

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 Box Elder News & Journal on June 19, 2024. 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.

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]

DAQE-IN161020003-24
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

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 The Brigham City Facility
Wood Door Manufacturing Facility

II.A.2 Wood Working Operations
Two (2) sets of cyclones and baghouses, each set includes a cyclone and a baghouse in series

II.A.3 Adhesive Applications
One (1) automated spreader (minimum 65% transfer efficiency)

II.A.4 Primer Applications
Two (2) paint booths with HVLP sprayers (minimum 65% transfer efficiency)

II.A.5 Various Natural gas Combustion Equipment
Including space heaters, door heaters, and hot water heaters, each rated at less than 5 MMBtu/hr
Exempt equipment; for information only

DAQE-IN161020003-24
Page 6

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

A. All-natural gas combustion equipment - 10% opacity.

B. All baghouse stacks - 10% opacity.

C. All paint booth stacks - 10% opacity.

D. All other points - 10% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not consume more than 70.4 million scf of natural gas per rolling 12-
month period. [R307-401-8]

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

A. Determine natural gas consumption by monthly billing statements from the
utility company.

B. Use the monthly billing statements to calculate a new rolling 12-month total by
the 20th day of each month using data from the previous 12 months.

C. Keep the natural gas consumption records for all periods the plant is in
operation.

[R307-401-8]

II.B.2 Requirements for Wood Working Operations
II.B.2.a The owner/operator shall install and operate two (2) dust collection and removal systems, each of
which consists of a cyclone and a baghouse in series. All exhaust air from the woodworking
operations, including door sizing, routing, sawing, and grinding, shall be routed through the
cyclone-baghouse systems before being vented to the atmosphere. [R307-401-8]

II.B.2.b The owner/operator shall install and operate a magnehelic pressure gauge to measure the static
pressure drop across each baghouse. [R307-401-8]

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

DAQE-IN161020003-24
Page 7

II.B.2.c The owner/operator shall maintain the static pressure drop across each baghouse during operation
between one (1) and four (4) inches of water column. [R307-401-8]

II.B.2.c.1 The owner/operator shall record the pressure drop at least once per operating day. [R307-401-8]

II.B.2.c.2 The pressure drop records shall be kept for all periods the plant is in operation. [R307-401-8]

II.B.3 Adhesive Application Requirements
II.B.3.a The owner/operator shall comply with the applicable requirements and limitations in R307-342,
Adhesive and Sealants. [R307-342]

II.B.4 Primer Application Requirements
II.B.4.a The owner/operator shall comply with the applicable requirements and limitations in R307-349,
Flat Wood Paneling Coatings. [R307-349]

II.B.4.b The owner/operator shall install and operate a set of paint arrestor particulate filters for each
paint booth to control particulate emissions. All air exiting the booths shall pass through this
control system before being vented to the atmosphere (outside building/operation). The filters
shall be maintained and replaced according to the manufacturer's instructions. [R307-401-8]

II.B.5 VOC and HAP Requirements
II.B.5.a The owner/operator shall not emit more than the following from evaporative sources (adhesive
and primer applications) on site:

34.32 tons per rolling 12-month period of VOCs.

0.11 tons per rolling 12-month period of formaldehyde.

5.17 tons per rolling 12-month period of glycol ethers.

1.51 tons per rolling 12-month period of methanol.

0.27 tons per rolling 12-month period of vinyl acetate.

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

[R307-401-8]

II.B.5.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]

*18% of formaldehyde, vinyl acetate, and glycol ethers in the adhesive will emit to the
atmosphere; therefore, emissions for these HAPs shall be calculated as 18% multiplied by the
above equation using the mass-balance method.

[R307-401-8]

II.B.5.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-IN161020003-24
Page 8

II.B.5.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.

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.5.b The owner/operator shall store the VOC/HAP containing materials in closed and airtight
containers when the materials are not in use. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN161020001-22 dated December 23, 2022
Is Derived From NOI dated April 1, 2024

DAQE-IN161020003-24
Page 9

ACRONYMS

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

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

Box Elder News Journal
Publication Name:
Box Elder News Journal
Publication URL:
www.benewsjournal.com
Publication City and State:
Brigham City, UT
Publication County:
Box Elder
Notice Popular Keyword Category:
Notice Keywords:
steves
Notice Authentication Number:
202406190952269121622
1761527914
Notice URL:
Back
Notice Publish Date:
Wednesday, June 19, 2024
Notice Content
NOTICE OF INTENT
STEVES AND SONS
INCORPORATED
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: Steves and Sons, Incorporated
Location: Steves and Sons, Incorporated - Door Manufacturing Plant – 1080 North Main Street, Brigham City, UT
Project Description:
Steves and Sons, Incorporated (Steves) operates a wood door manufacturing facility in Brigham City. The door manufacturing processes
include woodworking, adhesive applications, and painting operations. Particulate emissions generated from woodworking operations are
controlled with baghouses and cyclones. Particulate emissions from paint booths are controlled with filters. Natural gas consumption is limited
to 70.4 million scf per year. Steves has requested to increase adhesive usage at the facility by 661,440 lbs per year.
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 July 19, 2024, 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: June 19, 2024
Back

DAQE-NN161020003-24

June 13, 2024

Box Elder News & Journal
Legal Advertising Dept
PO BOX 370
Brigham City, UT 843020370

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Box Elder News &
Journal (Account Number: LOC0403) on June 19, 2024.

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: Box Elder County
cc: Bear River 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-NN161020003-24
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: Steves and Sons, Incorporated
Location: Steves and Sons, Incorporated - Door Manufacturing Plant – 1080 North Main
Street, Brigham City, UT
Project Description: Steves and Sons, Incorporated (Steves) operates a wood door manufacturing
facility in Brigham City. The door manufacturing processes include
woodworking, adhesive applications, and painting operations. Particulate
emissions generated from woodworking operations are controlled with baghouses
and cyclones. Particulate emissions from paint booths are controlled with filters.
Natural gas consumption is limited to 70.4 million scf per year. Steves has
requested to increase adhesive usage at the facility by 661,440 lbs per year.

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 July 19, 2024, 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: June 19, 2024

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

Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
State of Utah
SPENCER J. COX
DIVISION OF AIR QUALITY
Bryc€ C. Bird
Director
DEIDRI] IIt]NDERSON
L,ieutenanl Covemor
RN r 6 1020003
June 5, 2024
Austin Payne
Steves and Sons, Inc.
203 Humble Avenue
San Antonio, TX 78225
[e-mail]
Re: Engineer Review:
Minor Modification to DAQE-AN I 61020001-22 to Increase Adhesive Usage and Emissions
Project Number: N 161020003
Steves and Sons, Inc. should contact Dungan Adams at (3 85) 290-2474 ifthere are questions or concerns
with the review ofthe draft permit conditions. Upon resolution ofyour concerns, please email Dungan
Adams 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.
lf Steves and Sons, Inc. does not respond to this lcttcr within 10 business days, the project will move
forward without source concurre ce. IfS es and Sons, Inc. has concems that cannot be resolved and
the project becomes stagnant, th AQ tor may issue an Order prohibiting construction
Apprcval Signalurc
gnature & Date)
I95 Nonh 1950 Wcst. Salt Lake City, UT
Mailins Address: P O. Box 144820. Salr Lake City, UT 84114-4820
Tel€phon€ (801) s364000. Fd [phone]. T.D D. [phone]
s\|N deq utdh-tov
ftinred otr 100'/o r€cycled prp€r
Dear Austin Payne,
'I'he DAQ requests a company represcntative review and sign the attached Engineer Review (E,R). This
ER identifies all applicable elements ofthe New Source Review pcnnitting program. Steves and Sons,
Inc. should complete this review within l0 business days of receipt.
Project Number
Owner Name
Mailing Address
Source Name
Source Location
UTM Projection
UTM Datum
UTM Zone
SIC Code
Source Contact
Phone Number
Email
Billing Contact
Phone Number
Email
Project Engineer
Phone Number
Email
Notice of Intent (NOI) Submitted
Date of Accepted Application
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
N161020003
Steves and Sons, Inc.
203 Humble Avenue
San Antonio, TX,78225
Steves and Sons, Inc.- Door Manulacturing PIant
1080 North Main Street
Brigham City, UT 84302
415,500 m Easting, 4,598,250 m Northing
NAD83
UTM Zone 12
243 I (Millwork)
Austin Payne
(210) 924-51I 1 Ext 1394
[e-mail]
Austin Payne
(210)924-5lll ext 1394
[e-mail]
Dungan Adams, Engineer
(38s)290-2474
[e-mail]
April I ,2024
April 11 .2024
Engineer Review N161020003: Stevesand Sons, Inc.- Door Manufacturing Plant
Aptil 11,2024
Page I
SOURCE DESCRIPTION
NSR CI ification:
Minor Modification at Minor Sourcc
Source Classification
Located in Salt Lake City UT PM: s NAA
Box Elder County
Airs Source Size: B
Applicable Federal Standards
None
Proiect Proposal
Minor Modification to Increase Adhesive Usage
Pro ect Dc n
The source has requested to increase adhesive usage at the facility by 661,4401bs per year. VOC
and HAP emissions are updated to reflect the increases in adhesive usage.
EMISSION IMPACT ANALYSIS
Emission increases for all criteria pollutants and HAPs are below their respective thresholds in R307-410-4 and
R307-4l 0-5; therefore, modeling is not required for this modification. [Last updated April22,2024)
Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
Aptil17,2024
Page 2
General Description
Steves and Sons, lnc. (Steves) operates a wood door manufacturing facility in Brigham City in
Box Elder County. The door manufacturing processes include woodworking, adhesive
applications, and painting operations. Particulate emissions generated from woodworking
operations are controlled with baghouses and cyclones Particulate emissions from paint booths
are controlled with filters. Natural gas consumption is limited to 70.4 million scf per year.
The emissions listed below are an estimate ofthe total potential emissions from the source. Some
rounding of emissions is possible.
Nole: Change ih emissions indicales lhe dwrehce betueen previous AO ahl proposed ,rodirtcdlion.
Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
Aprll17,2024
Page 3
Criteria Pollutant Chanee (TPY)Total (TPY)
CO: Equivalent 0 4230.00
Carbon Monoxide 0 2.96
Nitrogen Oxidcs 0 3.52
Particulate Mafter - PMro 0 9.26
Particulate Matter - PMr s 0 9.26
Sullur Dioxide 0 0.02
Volatile Organic Compounds b.v)34.52
Ilazardous Air Pollutant Change (lbs/vr)Total (lbs/yr)
l'ormaldehyde (CAS #50000)40 220
Glycol Ethers (CAS #EDF 109)2260 10340
I lexane (CAS #l10543)0 127
Methanol (CAS #67561)660 3020
vinyl Acetate (CAS # I 08054)120 540
Change (TPY)Total (TPY)
'l otal HAPS 1.54 1 .12
SUMMARY OF EMISSIONS
I
I
Review of BACT for New/lVlodified Emission Units
BACT review resardin Adhesive Aoolications
VOC and flAP emissions are produced when adhesives are applied during door assembly.
Available capture systems for VOCs and IIAPS include carbon absorbers and thermal oxidizers.
Specific pick-up vents and enclosures required to effectively use these capture systems are difficult
to implement due to the nature ofdoor manufacturing. VOC emissions are released as the doors
are glued, pressed, and cured. In order to effectively use pick-up vents, capture devices would be
required at several locations which would be cost prohibitive. The curing process is conducted on a
conveyor system making the use of enclosures infeasible. Therefore, capture systems for VOC and
HAP emissions are considered to be technicallv infeasible.
BAC'I' for VOC and HAP emissions is best operating practices. Best operating practices include
the use of low VOC adhesives and the use ofan automated spreader that achieves a minimum
transfer efficiency of 65%. BAC'I is also complying with UAC Rule R307-342. Adhesives and
Sealants.
[-ast updated June 5,20241
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing thc project with the following recommended
conditions and that failure to comply with any ofthe conditions may constitute a violation ofthe
AO. (New or Modified conditions are indicated as "New" in the Outline Label):
Modifications to the equipment or processes approved by this AO that could alfect the
emissions covered by this AO must be revierved and approved. [R3 07-40 I - I ]
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 ofthe 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]
Engineer Review N 161020003: Steves and Sons, Inc.- Door Manufacturing Plant
Aptil 17,2024
Page 4
VOC and HAP Emissions
I 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- l 0l ]
t.2 'Ihe limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3
l.+
1.
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 ofwhether 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 ofoperating and maintenance procedures, and inspection ofthe source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4)
L6 The owner/operator shall comply with UAC Rl07-107. General Requirements: Breakdowns
IR307- 107]
t.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
1501
II.A
SECTION II: PERMITTED EQUIPMENT
'Ihc intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any ofthe conditions may constitute a violation ofthe
AO. (New or Modified conditions are indicated as "New" in the Outlinc Label):
Engineer Review N161020003: Steves and Sons, lnc.- Door Manulacturing Plant
Aptil l'1,2024
Page 5
II,A.I The Brigham City Facility
Wood Door Manufacturing Facility
|.4.2 Wood Working Operations
Two (2) sets ofcyclones and baghouses, each set include a cyclone and a baghouse in series
II,A.J Adhesive Applications
One (1) automated spreader (minimum 650lo transfer efficiency)
It.A.4 Primer Applications
Two (2) paint booths with HVLP sprayers (minimum 65o% transfer efficiency)
II.A.5 Various Natural gas Combustion Equipment
lncluding space heaters, door heaters, and hot water heaters, each rated less than 5 MMBtu/hr
Exempt equipment; for information only
THE APPROVED EOUIPMENT
II.B
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 ofthe conditions may constitute a violation ofthe
AO. (New or Modified conditions are indicated as "New" in the Outline Label):
REOUIREMENTS AND LIMITATIONS
Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April I7,2024
page 6
u.B.1 Plant-Wide Requirements
II.B.1.a
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:
A. All natural gas combustion equipment - l0% opacity
B. All baghouse stacks - l0% opacity
C. All paint booth stacks - 10% opacity
D. All other points - 10% opacity. [R307-401-8]
II.B. l.a. I Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401 -8]
It.B.r.b The owner/operator shall not consume more than 70.4 million scfolnatural gas per rolling l2-
month period. IR307-401 -8]
II.B.r.b.l The owner/operator shall
A Determine natural gas consumption by monthly billing statements from the utili[
company.
B Use the monthly billing statements to calculate a new rolling l2-month total by the
20th day ofeach month using data from the previous l2 months.
C. Keep the natural gas consumption records for all periods the plant is in operation
IR307-401-8,]
II.B.2 Requirements for Wood Working Operations
Il.B.2.a The owner/operator shall install and operate two (2) dust collection and removal systems, each
of which consists ofa cyclone and a baghouse in series. All exhaust air from the
woodworking operations, including door sizing, routing, sawing, and grinding, shall be routed
through the cyclone-baghouse systems before being vented to the atmosphere. IR307-401-8]
II.B.2.b The owner/operator shall install and operate a magnehelic pressure gauge to measure the static
pressure drop across each baghouse. [R307-401-8]
II.B.2.b.l The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. IR307-40 I -8]
It.8.2.b.2 The pressure gauge shall measure the pressure drop in l-inch water column increments or lcss
[R307-401-8]
I
II.B.2.c The owner/operator shall maintain the static pressure drop across each baghouse during
operation between I and 4 inches ofwater column. [R307-401-8]
ll.B.2.c.l The owner/operator shall record the pressure drop at least once per operating day. [R307-401-
8l
The pressure drop records shall be kept for all periods the plant is in operation. [R307-401-81
n. B.3 Adhesive ADDlication Require me nts
II.B.3.a 'l'he owner/operator shall comply with the applicable requirements and limitations in R307-
342, Adhesive and Sealants. [R307-342]
II.B,.I Primer Application Rcquirements
II.B.4.a The owner/operator shall comply with thc applicable requirements and limilations in R307-
349, Flat Wood Paneling Coatings. IR307-349]
ll.B.4.b The owner/operator shall install and operate a set of paint arrestor particulale filters for each
paint booth to control particulate emissions. All air exiting the booths shall pass through this
conlrol system before being vented to the atmosphere (outside building/operation). The filters
shall be maintained and replaced according to the manufacturer's instructions. [R]07-401-81
II.B.5 VOC & HAP Rcquircments
ILB.5.a
NEW
The owner/operator shall not emit more than the following from evaporative sources (adhesive
and primer applications) on site:
34.32 tons per rolling l2-month period ofVOCs
0.11 tons per rolling l2-month period offormaldehyde
5.17 tons per rolling l2-month period ofglycol ethers
l.5l tons per rolling l2-month period ofmethanol
0.27 tons per rolling l2-month period ofvinyl acetate
7.06 tons per rolling l2-month period ofall HAPs combined. [R307-401-8]
II.B.5.a.I The owner/operator shall calculate a new l2-month total by the 20th day ofeach month using
data from the previous l2 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:
HAP* : [% HAP by WeighVl00] x [Density] x [Volume Consumed]
Engineer Review N161020003: Steves and Sons, lnc.- Door Manufacturing Plant
April 11,2024
Page 1
11.8.2.c.2
VOCs = [% VOCs by Weight/100] x [Density] x fVolume Consumed]
* I 8% of formaldehyde, vinyl acetate, and glycol ethers in the adhesive will emit to the
atmosphere; therefore, emissions for these HAPs shall be calculated as I8% multiplied by the
above equation using mass-balance method. IR307-401-8]
I I. B.5. a.2 The orvner/operator shall use a mass-balance method to quantify any amount of VOCs and
IIAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed
from the quantil.ies calculated above to provide the monthly total emissions ofVOCs and
HAPs. [R307-401-8]
Il. B.5.a.3 The owner/operator shall keep records each month ofthe 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 ofeach material used
D. The volume of each VOC- and HAP-emitting material used
E. The amount of VOCs and the amount of each HAP emitted from each material
F. The amount ofVOCs and the amount ofeach HAP reclaimed and/or controlled from
each material
G. The total amount ofVOCs, the total amount ofeach HAP, and the total amount ofall
HAPs combined emitted from all materials (in tons)
1R307-401-81
Ir.B.s.b The owner/operator shall store the VOC/HAP containing materials in closed and airtight
containers when the materials are not in use. [R307-401-8]
Engineer Rgview N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17,2024
Page 8
PERMIT HISTORY
Supersedes
Is Derived From
AO DAQE-AN 1 6 1 02000 1 -22 dated December 23, 2022
NOI dated April l, 2024
REVIEWER COMMENTS
Comment resardins Adhesive Emission Calculations:
VOC and IIAP emissions were estimated using a mass balance approach. HAP emission factors
were determined using the Virginia Department of Environmental Quality's (VDEQ) Permit
Boilerplate Procedures for Wood Furniture and Fixtures Manufacturing Facilities. These emission
factors are used for calculations at all Steves' facilitics throughout the country as well as in the
previous AO DAQE-1 6 I 02000 I -22.
Using the VDEQ document, calculations assume l8% offormaldehyde, vinyl acetate, and glycol
ethers will emit to the atmosphere during adhesive application. The remaining 82% ofthese HAPs
will remain in the adhesive. There is no guidance for methanol in the VDEQ document, so it is
conservatively assumed that l00o/o of methanol in the adhesive will be emitted to the atmosphere.
[Last updated April 22, 2024)
2. Comment resardins Federal Subpart Arrplicability:
MACT
The facility is not subject to 40 CFR 63 Subpart JJ (National Emission Standards for Wood Furniture
Manufacturing Operations). The provisions ofthis subpart apply only to major sources. The facility
is not a major source; therefore, MACT Subpart JJ does not apply to the source. lLast updated April
22,20241
Comment resardinq Title V Anolicabilitv:
Title V of the 1990 Clean Air Act (Title V) applies to the following:
I . Any major source
2. Any source subject to a standard, limitation, or other requiremcnt under Section I I I ofthe Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 ofthe Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.
This lacility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR
60 (NSPS),40 CFR 6l (NESHAP), or 40 CFR 63 (MACT) regulations. Therefore, Title V does not
apply to this facility. [Last updated April 22,2024)
Enginecr Review N | 6l 020003: Stevesalrd Sons, Inc.- Door Manufacturing Plant
Aptil l'1,2024
Page 9
-)
When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:
l.
ACROT\TYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 ofthe Code ofFederal RegulationsAO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classif 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
COz Carbon Dioxide
COze Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-l
COM Continuous opacity monitor
DAQ/UDAQ Division of Air QualityDAQE This is a document tracking code for intemal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Cas(es) - 40 CFR 52.21 (bX49Xi)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
LIAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hourLB^fR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Mitlion British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of lntent
NO- Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PMro Particulate matter less than l0 microns in size
PMr s Particulate matter less than 2.5 microns in sizePSD Prevention of Significant Deterioration
PTE Potential to EmitR307 Rules Series 307
R307-401 Rules Series 307 - Section 401SOu Sulfur dioxide
Title lV Title IV of the Clean Air Act
Title V Titl€ V of the Clean Air ActTPY Tons per year
UAC Utah Administrative CodeVOC Volatile organic compounds
Engineer Review N161020003: Steves and Sons. Inc.- Door Manufacruring Plant
April 17,2024
Page l0
DAQE-

RN161020003
June 5, 2024

Austin Payne
Steves and Sons, Inc.
203 Humble Avenue
San Antonio, TX 78225
[e-mail]

Dear Austin Payne,

Re: Engineer Review:
Modification to Approval Order DAQE-AN161020001-22 to Increase Adhesive Usage and
Emissions
Project Number: N161020003

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. Steves and Sons,
Inc. should complete this review within 10 business days of receipt.

Steves and Sons, Inc. should contact Dungan Adams at [phone] if there are questions or concerns
with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan
Adams at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the
DAQ will prepare an 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 Steves and Sons, Inc. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Steves and Sons, Inc. 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 N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N161020003
Owner Name Steves and Sons, Inc.
Mailing Address 203 Humble Avenue
San Antonio, TX, 78225

Source Name Steves and Sons, Inc.- Door Manufacturing Plant
Source Location 1080 North Main Street
Brigham City, UT 84302

UTM Projection 415,500 m Easting, 4,598,250 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 2431 (Millwork)

Source Contact Austin Payne
Phone Number [phone] Ext 1394
Email [e-mail]

Billing Contact Austin Payne
Phone Number [phone] ext 1394
Email [e-mail]

Project Engineer Dungan Adams, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted April 1, 2024
Date of Accepted Application April 17, 2024

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 2
SOURCE DESCRIPTION

General Description
Steves and Sons, Inc. (Steves) operates a wood door manufacturing facility in Brigham City in
Box Elder County. The door manufacturing processes include woodworking, adhesive
applications, and painting operations. Particulate emissions generated from woodworking
operations are controlled with baghouses and cyclones Particulate emissions from paint booths
are controlled with filters. Natural gas consumption is limited to 70.4 million scf per year.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: B

Applicable Federal Standards
None

Project Proposal
Minor Modification to Approval Order DAQE-AN161020001-22 to Increase Adhesive Usage
and Emissions

Project Description
The source has requested to increase adhesive usage at the facility by 661,440 lbs per year. VOC
and HAP emissions are updated to reflect the increases in adhesive usage.

EMISSION IMPACT ANALYSIS
Emission increases for all criteria pollutants and HAPs are below their respective thresholds in R307-410-4 and
R307-410-5; therefore, modeling is not required for this modification. [Last updated April 22, 2024]

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 3
SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4230.00
Carbon Monoxide 0 2.96
Nitrogen Oxides 0 3.52
Particulate Matter - PM10 0 9.26
Particulate Matter - PM2.5 0 9.26
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 6.95 34.52

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 40 220
Glycol Ethers (CAS #EDF109) 2260 10340
Hexane (CAS #110543) 0 127
Methanol (CAS #67561) 660 3020
Vinyl Acetate (CAS #108054) 120 540
Change (TPY) Total (TPY)
Total HAPs 1.54 7.12

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

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Adhesive Applications
VOC and HAP Emissions
VOC and HAP emissions are produced when adhesives are applied during door assembly.
Available capture systems for VOCs and HAPS include carbon absorbers and thermal oxidizers.
Specific pick-up vents and enclosures required to effectively use these capture systems are difficult
to implement due to the nature of door manufacturing. VOC emissions are released as the doors
are glued, pressed, and cured. In order to effectively use pick-up vents, capture devices would be
required at several locations which would be cost prohibitive. The curing process is conducted on a
conveyor system making the use of enclosures infeasible. Therefore, capture systems for VOC and
HAP emissions are considered to be technically infeasible.

BACT for VOC and HAP emissions is best operating practices. Best operating practices include
the use of low VOC adhesives and the use of an automated spreader that achieves a minimum
transfer efficiency of 65%. BACT is also complying with UAC Rule R307-342. Adhesives and
Sealants.
[Last updated June 5, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

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

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

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

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

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 5
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]

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

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

SECTION II: PERMITTED EQUIPMENT
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 The Brigham City Facility
Wood Door Manufacturing Facility

II.A.2 Wood Working Operations
Two (2) sets of cyclones and baghouses, each set include a cyclone and a baghouse in series

II.A.3 Adhesive Applications
One (1) automated spreader (minimum 65% transfer efficiency)

II.A.4 Primer Applications
Two (2) paint booths with HVLP sprayers (minimum 65% transfer efficiency)

II.A.5 Various Natural gas Combustion Equipment
Including space heaters, door heaters, and hot water heaters, each rated less than 5 MMBtu/hr
Exempt equipment; for information only

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 6
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 Plant-Wide Requirements
II.B.1.a
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. All natural gas combustion equipment - 10% opacity

B. All baghouse stacks - 10% opacity

C. All paint booth stacks - 10% opacity

D. All other points - 10% opacity. [R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not consume more than 70.4 million scf of natural gas per rolling 12-
month period. [R307-401-8]

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

A. Determine natural gas consumption by monthly billing statements from the utility
company.

B. Use the monthly billing statements to calculate a new rolling 12-month total by the
20th day of each month using data from the previous 12 months.

C. Keep the natural gas consumption records for all periods the plant is in operation.
[R307-401-8]

II.B.2 Requirements for Wood Working Operations
II.B.2.a The owner/operator shall install and operate two (2) dust collection and removal systems, each
of which consists of a cyclone and a baghouse in series. All exhaust air from the
woodworking operations, including door sizing, routing, sawing, and grinding, shall be routed
through the cyclone-baghouse systems before being vented to the atmosphere. [R307-401-8]

II.B.2.b The owner/operator shall install and operate a magnehelic pressure gauge to measure the static
pressure drop across each baghouse. [R307-401-8]

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

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 7
II.B.2.c The owner/operator shall maintain the static pressure drop across each baghouse during
operation between 1 and 4 inches of water column. [R307-401-8]

II.B.2.c.1 The owner/operator shall record the pressure drop at least once per operating day. [R307-401-
8]

II.B.2.c.2 The pressure drop records shall be kept for all periods the plant is in operation. [R307-401-8]

II.B.3 Adhesive Application Requirements
II.B.3.a The owner/operator shall comply with the applicable requirements and limitations in R307-
342, Adhesive and Sealants. [R307-342]

II.B.4 Primer Application Requirements
II.B.4.a The owner/operator shall comply with the applicable requirements and limitations in R307-
349, Flat Wood Paneling Coatings. [R307-349]

II.B.4.b The owner/operator shall install and operate a set of paint arrestor particulate filters for each
paint booth to control particulate emissions. All air exiting the booths shall pass through this
control system before being vented to the atmosphere (outside building/operation). The filters
shall be maintained and replaced according to the manufacturer's instructions. [R307-401-8]

II.B.5 VOC & HAP Requirements
II.B.5.a
NEW
The owner/operator shall not emit more than the following from evaporative sources (adhesive
and primer applications) on site:

34.32 tons per rolling 12-month period of VOCs

0.11 tons per rolling 12-month period of formaldehyde

5.17 tons per rolling 12-month period of glycol ethers

1.51 tons per rolling 12-month period of methanol

0.27 tons per rolling 12-month period of vinyl acetate

7.06 tons per rolling 12-month period of all HAPs combined. [R307-401-8]

II.B.5.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]

*18% of formaldehyde, vinyl acetate, and glycol ethers in the adhesive will emit to the
atmosphere; therefore, emissions for these HAPs shall be calculated as 18% multiplied by the
above equation using mass-balance method. [R307-401-8]

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 8
II.B.5.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.5.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

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.5.b The owner/operator shall store the VOC/HAP containing materials in closed and airtight
containers when the materials are not in use. [R307-401-8]

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 9
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes AO DAQE-AN161020001-22 dated December 23, 2022
Is Derived From NOI dated April 1, 2024

REVIEWER COMMENTS

1. Comment regarding Adhesive Emission Calculations:
VOC and HAP emissions were estimated using a mass balance approach. HAP emission factors
were determined using the Virginia Department of Environmental Quality's (VDEQ) Permit
Boilerplate Procedures for Wood Furniture and Fixtures Manufacturing Facilities. These emission
factors are used for calculations at all Steves' facilities throughout the country as well as in the
previous AO DAQE-161020001-22.

Using the VDEQ document, calculations assume 18% of formaldehyde, vinyl acetate, and glycol
ethers will emit to the atmosphere during adhesive application. The remaining 82% of these HAPs
will remain in the adhesive. There is no guidance for methanol in the VDEQ document, so it is
conservatively assumed that 100% of methanol in the adhesive will be emitted to the atmosphere.
[Last updated April 22, 2024]

2. Comment regarding Federal Subpart Applicability:
MACT
The facility is not subject to 40 CFR 63 Subpart JJ (National Emission Standards for Wood Furniture
Manufacturing Operations). The provisions of this subpart apply only to major sources. The facility
is not a major source; therefore, MACT Subpart JJ does not apply to the source. [Last updated April
22, 2024]

3. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.

This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR
60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. Therefore, Title V does not
apply to this facility. [Last updated April 22, 2024]

Engineer Review N161020003: Steves and Sons, Inc.- Door Manufacturing Plant
April 17, 2024
Page 10
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

Dungan Adams <[e-mail]>
Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
9 messages
Alan Humpherys <[e-mail]>Tue, Apr 2, 2024 at 12:24 PM
To: Dungan Adams <[e-mail]>
Dungan,
Can you please process this project?
Site ID: 16102
Peer: EQ
Thanks,
Alan
---------- Forwarded message ---------
From: Chase Peterson <[e-mail]>
Date: Mon, Apr 1, 2024 at 3:07 PM
Subject: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
To: Alan Humpherys <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Austin Payne <[e-mail]>, Henry Vossler
<[e-mail]>, Herman Vogel <[e-mail]>
Alan,

Attached is a Notice of Intent (NOI) air permit application for submittal to the Utah Division of Air Quality (UDAQ) on behalf
of Steves and Sons’ Brigham City Facility. The attached serves as the NOI air permit application per Utah Administrative
Code R307-401-5 and is being submitted to request a modification to the Brigham City Facility’s existing approval order
DAQE-AN161020001-22.

Steves and Sons has taken responsibility for the UDAQ’s NOI air permit application fee through the online portal.

Please feel free to reach out with questions that you may have regarding this submittal.

Thanks very much,

Chase Peterson
Consultant
Trinity Consultants, Inc.
[phone]
4525 Wasatch Blvd, Suite 200
Salt Lake City, UT 84124
6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…1/7

--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Steves and Sons' Brigham City Facility NOI - Adhesives 2024-0401 v1.00.pdf
2297K
Alan Humpherys <[e-mail]>Tue, Apr 2, 2024 at 12:24 PM
To: Chase Peterson <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Austin Payne <[e-mail]>, Henry Vossler
<[e-mail]>, Herman Vogel <[e-mail]>, Dungan Adams
<[e-mail]>
Chase,
Thanks for submitting this over. I've assigned the project to Dungan. He should be reaching out with any questions. If you
have any questions in the meantime, please let me know.
Thanks,
Alan
[Quoted text hidden]
Chase Peterson <[e-mail]>Fri, May 17, 2024 at 1:47 PM
To: Dungan Adams <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Austin Payne <[e-mail]>, Henry Vossler
<[e-mail]>, Herman Vogel <[e-mail]>
Dungan,

Just following up with you on the status of the NOI air permit application for Steves and Sons’ Brigham City
Plant. Do you have any questions for us? Please let us know whether there is anything that we can do to
help with your review.

Thanks very much,

Chase Peterson
Consultant
Trinity Consultants, Inc.
[phone]
6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…2/7
4525 Wasatch Blvd, Suite 200
Salt Lake City, UT 84124

From: Alan Humpherys <[e-mail]>
Sent: Tuesday, April 2, 2024 12:25 PM
To: Chase Peterson <[e-mail]>
Cc: Brian Mensinger <[e-mail]>; Ausn Payne <[e-mail]>; Henry
Vossler <[e-mail]>; Herman Vogel <[e-mail]>; Dungan Adams
<[e-mail]>
Subject: Re: Steves and Sons' Brigham City Facility - Noce of Intent Air Permit Applicaon

Chase,

Thanks for submitting this over. I've assigned the project to Dungan. He should be reaching out with any questions. If you
have any questions in the meantime, please let me know.

Thanks,
Alan

On Mon, Apr 1, 2024 at 3:07 PM Chase Peterson <[e-mail]> wrote:
Alan,

Attached is a Notice of Intent (NOI) air permit application for submittal to the Utah Division of Air Quality (UDAQ) on
behalf of Steves and Sons’ Brigham City Facility. The attached serves as the NOI air permit application per Utah
Administrative Code R307-401-5 and is being submitted to request a modification to the Brigham City Facility’s existing
approval order DAQE-AN161020001-22.

Steves and Sons has taken responsibility for the UDAQ’s NOI air permit application fee through the online portal.

Please feel free to reach out with questions that you may have regarding this submittal.

Thanks very much,

Chase Peterson
Consultant
Trinity Consultants, Inc.
[phone]
4525 Wasatch Blvd, Suite 200
Salt Lake City, UT 84124
6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…3/7

--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
[Quoted text hidden]
Dungan Adams <[e-mail]>Mon, May 20, 2024 at 9:11 AM
To: Chase Peterson <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Austin Payne <[e-mail]>, Henry Vossler
<[e-mail]>, Herman Vogel <[e-mail]>
Hi Chase,
My manager is currently reviewing the permit modification for Steves and Sons’ Brigham City Facility. I do not have any
questions and should have the updated permit for you to review in the next week or so.
Let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
--
6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…4/7

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
Austin Payne <[e-mail]>Fri, May 31, 2024 at 6:35 AM
To: Dungan Adams <[e-mail]>, Chase Peterson <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Henry Vossler <[e-mail]>, Herman
Vogel <[e-mail]>
Any update?
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, May 31, 2024 at 10:13 AM
To: Austin Payne <[e-mail]>
Cc: Chase Peterson <[e-mail]>, Brian Mensinger <[e-mail]>, Henry
Vossler <[e-mail]>, Herman Vogel <[e-mail]>
Austin,
My manager is still reviewing the project. I've sent him another reminder and should have the draft permit for you to
review next week. I apologize for the delay.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Jun 5, 2024 at 10:10 AM
To: Chase Peterson <[e-mail]>
Cc: Austin Payne <[e-mail]>, Brian Mensinger <[e-mail]>, Henry Vossler
<[e-mail]>, Herman Vogel <[e-mail]>
Hi Chase,
Attached is the Engineering Review (ER) for Steves and Sons' Brigham City minor modification. Please review the
document and let me know if you have any questions or comments. If everything looks good, please have Austin sign the
cover page and return the document to me.
Thanks,
Dungan
[Quoted text hidden]
RN161020003.rtf
1516K
Brian Mensinger <[e-mail]>Wed, Jun 5, 2024 at 1:38 PM
6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…5/7
To: Dungan Adams <[e-mail]>
Cc: Henry Vossler <[e-mail]>, Matthew Watkins <[e-mail]>
Dungan,
Can you coordinate future correspondence with Henry Vossler, copied on this email. Also keep Matt Watkins copied
too as they will work together.

Thanks,
Brian Mensinger

…………………………………………………………………………
Brian Mensinger
Managing Consultant

4525 Wasatch Blvd, Suite 200, Salt Lake City, Utah 84124
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[Quoted text hidden]
Austin Payne <[e-mail]>Mon, Jun 10, 2024 at 7:52 AM
To: Dungan Adams <[e-mail]>, Chase Peterson <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Henry Vossler <[e-mail]>, Herman
Vogel <[e-mail]>
Good morning, Everyone
Please see signed attachment for the updated request. Please let me know if you have any questions or
comments.
Austin Payne
Code & Regulatory Compliance Manager
Office Tel: [phone] Ext. 1394
6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…6/7
www.Stevesdoors.com
“Accept your past without regrets. Handle your present with confidence. Face your future without fear.”
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Utah.pdf
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6/11/24, 9:53 AM State of Utah Mail - Fwd: Steves and Sons' Brigham City Facility - Notice of Intent Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1795248371795007889&simpl=msg-f:17952483717950078…7/7
UTAH DIVISION OF AIR QUALITY
NOTICE OF INTENT
Steves and Sons, Inc. – Brigham City, Utah
Modification of Approval Order
Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, Utah 84104
[phone]
Submitted on Behalf of:
STEVES AND SONS
203 Humble Avenue
San Antonio, Texas 78225
March 2024
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1-1
2. GENERAL INFORMATION 2-1
2.1 Source Identification Summary.................................................................................. 2-1
2.2 Area Designation ......................................................................................................... 2-1
2.3 Source Size Determination ......................................................................................... 2-1
2.4 Notice of Intent Forms................................................................................................ 2-1
2.5 Notice of Intent Fees .................................................................................................. 2-2
3. DESCRIPTION OF PROJECT AND PROCESS 3-1
3.1 Description of Project ................................................................................................. 3-1
3.2 Description of Process ................................................................................................ 3-1
3.3 Site Plan ...................................................................................................................... 3-3
4. EMISSIONS RELATED INFORMATION 4-1
4.1 Adhesive Application – VOC and HAP Emissions ......................................................... 4-1
5. BACT ANALYSIS 5-1
5.1 Adhesive Application VOC Emissions .......................................................................... 5-2
6. EMISSION IMPACT ANALYSIS 6-1
7. NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING 7-1
8. APPLICABLE REGULATIONS 8-1
8.1 UDAQ Air Quality Rules ............................................................................................... 8-1
8.2 Federal Rules: National Emission Standards for Hazardous Air Pollutants................. 8-5
8.3 Federal Rules: New Source Performance Standards ................................................... 8-6
APPENDIX A. FORMS A
APPENDIX B. EMISSION CALCULATIONS B
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1. EXECUTIVE SUMMARY
Steves and Sons, Inc. (Steves), is a company that manufactures doors at facilities throughout the United
States. Steves’ wood door manufacturing facility located at 1080 North Main St. Brigham City, Utah, 31714
(the Brigham City facility) operates in accordance with approval order (AO) DAQE-AN161020001-22. Steves
is proposing to update their permit by increasing the Brigham City facility’s adhesive usage. As a result,
Steves is submitting this Notice of intent (NOI) air permit application to the Utah Division of Air Quality
(UDAQ) for the modification of their air permit. The current permit adequately accounts for all other raw
materials and overall production. Thus, Steves is not proposing to increase overall door production or any
other process outside of adhesive application with this NOI air permit application.
The proposed project will incur an increase in the site’s potential to emit (PTE) of volatile organic
compounds (VOCs) and hazardous air pollutants (HAPs), resulting from the increased adhesive usage. The
proposed project increase in PTE for the Brigham City facility is 6.95 tons per year (tpy) of VOCs and 1.55
tpy of HAPs.
The Brigham City facility is located in Box Elder County, which is classified as attainment for all pollutants
with the exception of particulate matter (PM) with an aerodynamic diameter of 2.5 microns or less (PM2.5)
and its precursors. In 2016, portions of Box Elder County were designated as serious nonattainment. As a
result, the major source threshold (MST) for PM2.5 and its precursors are 70 tons per year (tpy) for nitrogen
oxides (NOX), sulfur dioxide (SO2), VOCs, and ammonia (NH3).1
The MST for Prevention of Significant Deterioration of Air Quality (PSD) applicability is 250 tpy, unless the
source is included on a list of 28 specifically defined industrial source categories, for which the PSD major
source threshold is 100 tpy.2 The Brigham City facility is classified as a ,
which is not one of the 28 listed source categories. As such, the PSD major source threshold is 250 tpy for
any New Source Review (NSR) regulated pollutant. The PTE of the PSD pollutants do not exceed 250 tpy;
therefore, the Brigham City facility will not be considered a major source under PSD. It will continue to be a
minor source under NSR.
This NOI air permit modification application has been developed pursuant to Utah Administrative Code
(UAC) R307-401-5 and UDAQ’s application guidance, and includes, but is not limited to:
NOI Air Permit Application Forms and Fees;
Process Description;
PTE Calculations;
Best Available Control Technology (BACT) Analysis;
Applicable State and Federal Requirements; and
Emission Impact Analysis Applicability.
1 40 CFR 51.165(a)(1)(iv)(A), definition of a Major stationary source.
2 40 CFR 52.21(b)(1)(i)(a).

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2. GENERAL INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ’s Form 1 .
2.1 Source Identification Summary
Company Name: Steves and Sons, Inc.
Address: 1080 North Main Street, Brigham City, Utah 31714
County: Box Elder County
UTM Coordinates: 415,500 m Easting, 4,598,250 m Northing, Zone 12
Primary SIC Code: 2431 – Millwork
Area Designation: Serious nonattainment area PM2.5
Source Size Determination: Minor Source
Current AO: DAQE-AN161020001-22

All correspondence regarding this submission should be addressed to:

Mr. Austin Payne
Code and Regulatory Compliance Manager
203 Humble Avenue
San Antonio, TX 78225
Phone: [phone] EXT 1394
Email: [e-mail]

2.2 Area Designation
The Brigham City facility is located within an area of Box Elder County that is classified as attainment for all
pollutants with exception to the following: (1) PM2.5, for which it is classified as a serious nonattainment
area of the National Ambient Air Quality Standards (NAAQS).
2.3 Source Size Determination
As presented in Appendix B, Table B-1, site-wide emissions at the Brigham City facility are less than the
MSTs for PM with an aerodynamic diameter of 10 microns or less (PM10), PM2.5, NOX, carbon monoxide
(CO), SO2, VOCs, greenhouse gases (GHGs), and HAPs. This facility is designated as a minor source under
NSR.
2.4 Notice of Intent Forms
The following UDAQ forms have been included with this NOI air permit application:

Form 1 – Notice of Intent (NOI) Application Checklist
Form 2 – Company Information/Notice of Intent (NOI)
Form 4 – Project Information
Form 5 – Emissions Information Criteria/GHGs/HAPs

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2.5 Notice of Intent Fees
Steves will use the UDAQ’s Payment Portal to prepay the following UDAQ NOI air permit application fees
associated with this submittal:
“Application Filing Fee” for the “New Minor Source or Minor Modification at Minor or Major Source”
category = $500
“Application Review Fee” for the “New Minor Source or Minor Modification at Minor or Major Source”
category in maintenance or non-attainment areas = $2,300
Total UDAQ fees = $2,800

Steves understands that the total permit review fee is based on the total actual time spent by UDAQ staff
processing this NOI air permit application. Upon issuance of the AO, if the total review time is more than 20
standard hours, UDAQ will invoice Steves at $115 per hour for the additional time above 20 standard hours.

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3. DESCRIPTION OF PROJECT AND PROCESS
3.1 Description of Project
The Brigham City facility manufactures solid-core and hollow-core wooden doors made to order. Air
emissions from the facility are due to woodworking, adhesive application, and painting operations. Steves is
seeking to increase its adhesive usage. The current permit adequately accounts for the facility’s door
production, including the associated generation of dust and the use of primer and paints. However, it does
not adequately account for adhesive usage. This has only been determined in the time that the facility has
been in operation, through actual operations. Adhesive usage is consequently proposed to be increased
under this NOI air permit application so that the facility may meet its design production values.
The emission sources that will be covered in this NOI air permit application include the following:
Fugitive VOC emissions resulting from the door assembly process; and
Fugitive HAP emissions resulting from the door assembly process.
3.2 Description of Process
3.2.1 Receiving
Raw materials for door manufacturing are delivered to the Brigham City facility by truck and are unloaded
and stored inside of the facility. Raw materials received include the following: cores, stiles, rails, skins,
cardboard, foam, primer, and adhesive. Primer and adhesive are provided in totes and are sealed until
needed. All received raw materials do not have the ability to emit any air pollutants during unloading.
3.2.2 Processing & Builds
Received raw materials are processed prior to being utilized in the door building process. Cores are routed
such that molded skins will fit the doors. Stiles and rails are cut down to size using saws with dust control
pick-up points routed to the cyclone and baghouse. Foam sheets and skins are also cut down to size for
each specific door type. All the scrap from the core, stiles, rails, foam sheets, and skins goes to disposal.

The doors are built by taking the cores, stiles, rails, foam, and skins and using an adhesive to assemble the
door parts together. The adhesives used emit VOCs and HAPs. After the parts are glued and the doors are
built, they are pressed for 30 minutes to allow the glue to dry before moving them. After pressing, the doors
are sent to the dry line for some time prior to sizing.
3.2.3 Sizing & Finishing
Once the doors have dried, they move to sizing where excess material can be cut down to actual customer
specification. Sizers at the facility cut excess material and sands in a two-pass operation. Doors pass
through the sizer stile-side first, then rail side. Pallets for the doors are manually made to size by pallet
builders, and the off-bearers manually lay down a board, then a pallet, and then a sheet of cardboard to
protect the sized door. Then the off-bearers remove the sized door off the sizer and stack it on the pallet.
All dust is collected using equipment-specific, dust-control pickup points before being sent to the cyclone
and dust collector.

The finishing process includes painting the doors in one (1) of two (2) paint booths. Doors are painted with
primer on three (3) sides, with the label side of the door rail left unpainted. Doors are allowed to dry and
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electrical heaters aid in the drying process. Once dry, the stiles are buffed smooth and the doors are
checked for any needed repairs. Various machining is performed per customer specification (e.g., hinges,
knob holes, etc.).
3.2.4 Shipping
Wrapped doors are picked up at one (1) of two (2) wrap stations on site. Doors are stacked in rows inside
of the facility while awaiting pickup. When trucks arrive to pick up, the doors are loaded under cover and
placed into the back of trucks. There are no expected emissions from these operations.
Refer to Figure 3-1 for a simplified process flow diagram. The proposed increase in adhesive usage will
occur in the “Glue Application” step.
Figure 3-1. Process Flow Diagram of Brigham City Facility
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3.3 Site Plan
The property boundaries of the Brigham City facility are shown in Figures 3-2 and 3-3, in blue.
Figure 3-2. Brigham City facility General Location
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Figure 3-3. Brigham City Facility Property Boundary
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4. EMISSIONS RELATED INFORMATION
This section details the methodology used to calculate controlled and uncontrolled emissions for criteria
pollutants and HAPs associated with the relevant process and its associated fugitives as regulated by R307-
401-5(2)(b). Detailed emission calculation tables are included in Appendix B. Additionally, a comparison to
major source thresholds is conducted.
4.1 Adhesive Application – VOC and HAP Emissions
Emissions from adhesive usage include VOC and HAP emissions. All adhesives are applied inside the
Brigham City facility but are likely to volatilize and be emitted from the facility through its ventilation system
on the roof. VOC and HAP emissions were estimated using a mass balance approach assuming adhesives
were to operate at maximum capacity and using HAP emission rates provided by Virginia DEQ: Permit
Boilerplate Procedures for Wood Furniture and Fixtures Manufacturing Facilities.3 These emission factors
were also used to maintain consistency across Steves’ facilities throughout the country. This is the same
process used to estimate VOC and HAP emissions in the current AO.
Annual VOC emissions are given by:
()
= × ( %)× × 1
2,000
And annual HAPs emissions are given by:
()
= × ( %)× (%)
× × 1
2,000
3 Virginia Department of Environmental Quality, Permit Boilerplate Procedures for Wood Furniture and Fixtures Manufacturing
Facilities, Section VI (A)(2)(a), Toxic Emissions. 11/05/1998.
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5. BACT ANALYSIS
In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant into the air, must consider BACT for a proposed
new source or modification.4 The below BACT analysis only addresses units which will be modified, installed,
or otherwise addressed in this NOI air permit application.
In a memorandum dated December 1, 1987, the United States Environmental Protection Agency (EPA)
stated its preference for a “top-down” BACT analysis.5 After determining if any New Source Performance
Standard (NSPS) is applicable, the first step in this approach is to determine, for the emission unit in
question, the most stringent control available for a similar or identical source or source category. If it can be
shown that this level of control is technically, environmentally, or economically infeasible for the unit in
question, then the next most stringent level of control is determined and similarly evaluated. This process
continues until the BACT level under consideration cannot be eliminated by any substantial or unique
technical, environmental, or economic objections. Presented below are the five basic steps of a top-down
BACT review as identified by the EPA.
Presented below are the five steps of the top-down BACT review for adhesive application.
Step 1 – Identify All Control Technologies
Available control technologies are identified for each emission unit in question. The following methods are
used to identify potential technologies: 1) researching the RACT/BACT/LAER/Clearinghouse (RBLC)
database, 2) surveying regulatory agencies, 3) drawing from previous engineering experience, 4) surveying
air pollution control equipment vendors, and/or 5) surveying available literature.
Step 2 – Eliminate Technically Infeasible Options
The second step in the BACT analysis is to eliminate any technically infeasible control technologies. Each
control technology for each pollutant is considered, and those that are clearly technically infeasible are
eliminated. EPA states the following regarding technical feasibility:6
A demonstration of technical infeasibility should be clearly documented and should show, based on physical,
chemical, and engineering principles, that technical difficulties would preclude the successful use of the
control option on the emissions unit under review.
Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Once technically infeasible options are removed from consideration, the remaining options are ranked based
on their control effectiveness. If there is only one remaining option or if all the remaining technologies could
achieve equivalent control efficiencies, ranking based on control efficiency is not required.
4 UAC R307-401-4
5 EPA, Office of Air and Radiation. Memorandum from J.C. Potter to the Regional Administrators. Washington, D.C. December
1, 1987.
6 EPA, New Source Review Workshop Manual (Draft): Prevention of Significant Deterioration and Nonattainment Area
Permitting, October 1990.
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Step 4 – Evaluate Most Effective Controls and Document Results
Beginning with the most effective control option in the ranking, detailed economic, energy, and
environmental impact evaluations are performed. If a control option is determined to be economically
feasible without adverse energy or environmental impacts, it is not necessary to evaluate the remaining
options with lower control effectiveness.
The economic evaluation centers on the cost effectiveness of the control option. Costs of installing and
operating control technologies are estimated and annualized following the methodologies outlined in the
EPA’s (CCM) and other industry resources.7 Note that the analysis is not
whether controls are affordable, but whether the expenditure is effective.
Step 5 – Select BACT
In the final step, one pollutant-specific control option is proposed as BACT for each emission unit under
review based on evaluations from the previous step.
The EPA has consistently interpreted the statutory and regulatory BACT definitions as containing two core
requirements that the agency believes must be met by any BACT determination, regardless of whether the
“top-down” approach is used. First, the BACT analysis must include consideration of the most stringent
available control technologies, i.e., those which provide the “maximum degree of emissions reduction.”
Second, any decision to require a lesser degree of emissions reduction must be justified by an objective
analysis of “energy, environmental, and economic impacts.”8
The UDAQ NOI Guide also details the requirement to achieve BACT as required in the State of Utah
permitting process. The proposed BACT must be based on the most effective engineering techniques and
control equipment to minimize emission of air contaminants into the outside environment from its process.
5.1 Adhesive Application VOC Emissions
5.1.1 Adhesive Application VOC Emissions Step 1 – Identify All Available Control
Technologies
The least-stringent emission rate allowable for BACT is any applicable limit under either NSPS – Part 60, or
NESHAP – Part 61. As described in Section 8, there are no applicable NSPS or NESHAP for the adhesive
application processes. Additionally, due to the unique nature of this operation, no relevant control
technology comparisons are given in either the RBLC or by similar air quality agencies.9 VOC control
technologies were identified based on research and extensive historic knowledge of common control
technologies used in similar manufacturing industries and/or VOC emitting processes.
To control VOC emissions, they must be effectively captured. Steves has considered the technical feasibility
of a capture system and best operating practices.
7 Office of Air Quality Planning and Standards (OAQPS), , Sixth Edition, EPA 452-02-001,
Daniel C. Mussatti & William M. Vatavuk, January 2002.
8 Ibid.
9 RBLC Process Type 30.700 contains entries for woodworking, but information has not been entered in the past 10 years.
RBLC search pulled 2/16/2022
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5.2.2 Adhesive Application VOC Emissions Step 2 – Eliminate Technically Infeasible
Options
Capture System
To implement a stand-alone control device, emissions must first be captured and routed to a central
location. The standard capture methods for product manufacturing can be broadly described as specific
pick-up vents and enclosures. Specific pick-up vents generally consist of a vacuum strategically placed over
the VOC-emitting process. For example, a fan located over a process tank, or a pick-up point located next to
a date coder. These pick-up vents generally have a high-capture efficacy because the emission rate at that
location is constant.
An enclosure entails boxing in the emissions with physical boundaries. Enclosures come in many forms but
are generally effective when the VOC emissions are generated within a relatively small space. Manufacturing
examples include ovens or other process-specific equipment.
VOC emissions from adhesive application are particularly difficult to capture, as the emissions evolve over a
4.5-hour period as doors are glued, pressed, and allowed to cure. Furthermore, the curing process is
conducted on a conveyor system within a warehouse. The large area over which the emissions evolve
prevents the use of a pick-up vent or enclosure smaller than the warehouse used for curing. If the air from
the entire warehouse were to be captured, the resulting air stream would have a very low VOC
concentration, rendering traditional stand-alone control technologies ineffective.
Due to the technical difficulties associated with the capture of VOCs, the control of these emissions through
the use of a centralized control device, such as a thermal oxidizer or carbon adsorber, has been determined
to be technically infeasible and eliminated as BACT.
Low VOC Adhesives
Many air quality agencies have established VOC concentration or material vapor pressure upper bounds
which limit the potential for VOC emissions from a facility. Often, these limits are established via process-
specific rules and limits given within the rule and are further specified to the exact type of application.
Compliance with these limits has been cited as established BACT in both the Bay Area Air Quality
Management District (BAAQMD) and the TCEQ. The State of Utah has established regulations similar to
those established by these agencies; specifically, R307-342 applies to this project.
As established in Section 8, , compliance with Utah regulations is technically feasible and
adhesive materials proposed meet the VOC concentration limits specified.
High-Efficiency Application Method
High-efficiency application methods ensure that VOC-containing substances are applied in ways that
minimize volatilization and usage. TCEQ lists high efficiency transfer application equipment as follows:
Utah rule R307-342 lists the following as reduced VOC application techniques:
10 BACT Guidelines for Coating Sources

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Steves uses an automated spreader which achieves a minimum of 65% transfer efficiency.
5.2.3 Adhesive Application VOC Emissions Steps 3 through 5 – Select BACT
As all the feasible controls for the control of VOC emission from adhesive application are currently in use,
there is not a need to conduct further detailed economic, energy, and environmental impact evaluations. As
a result, Steves proposes that the use of low-VOC adhesives and high-efficiency application methods meets
the intent of BACT.

11 UAC R307-342-6

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6. EMISSION IMPACT ANALYSIS
Table 6-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained
in R307-403-4 through 7, and R307-410-4.
Table 6-1. Facility-Wide Emissions and Comparison to Major Source and Modeling Thresholds.
Variable
Annual Emission Rates (tpy)
PM10 PM2.5 NOX CO SO2 VOC Total
HAP CO2e
Adhesive -- -- -- -- --6.95 1.55 --
Total 0.00 0.00 0.00 0.00 0.00 6.95 1.55 0.00

Modeling Limit1 15/5 -- 40 100 40 -- See HAP
Summary --
Modeling Required? No No No No No No No No

Permitted PTE2 9.26 9.26 3.52 2.96 0.02 27.57 5.58 4,230
Proposed PTE 9.26 9.26 3.52 2.96 0.02 34.52 7.13 4,230

Major Source
Thresholds3,4 250 70 70 250 70 70 10/25 75,000
Exceeding Major
Source Thresholds? No No No No No No No No
1 Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled
Emission Rates for New Sources, or Emissions Increase. Modeling thresholds for PM10 are 15 tpy for point sources
and 5 tpy for fugitive sources.
2 Permitted emissions are from DAQE-AN161020001-22.
3 Major source emission thresholds are defined by 40 CFR 51.165(a)(1)(iv)(A), definition of a
, for PM2.5 and its precursors. Major source emission thresholds are defined by 40 CFR 52.21(b)(1)(i)(b) for
PM10 and CO, i.e., criteria pollutants for which Box Elder County is in attainment
4 Total HAP threshold is given in 40 CFR 63.2 under definition of a . 10 tpy for a single HAP, 25 tpy for
combined HAPs.

Neither modeling nor MST limits have been surpassed in this project.

Table 6-2. Project HAP Emissions
Pollutant
Project Hourly
Emissions ETV1 Modeling
Requiredlb/hr lb/hr
Methanol 0.424 67.941 No
Formaldehyde 0.031 0.0823 No
Vinyl Acetate 0.076 8.591 No
Glycol Ethers 1.450 - No
1The Emission Threshold Value (ETV) assumes a 50-100 m distance to the fence line and vertically
unrestricted releases.

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7. NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING
7.1 Offset Applicability
7.1.1 PM2.5 Offsets
PM2.5 offsets are applicable for major modifications of sources located within or impacting a PM2.5
nonattainment area of the NAAQS. A major modification in a serious nonattainment area is defined in R307-
403-5(2)(c) as “a rate of emissions that would equal or exceed 10 tons per year (tpy) of direct PM2.5, 40 tpy
of sulfur dioxide, 40 tpy of nitrogen oxides, or 40 tpy of volatile organic compounds (VOC)”. The project
does not exceed the limits of PM2.5, SO2, NOX, or VOCs. It is therefore not subject to the offset requirements
of R307-403.
7.1.2 PM10 Offsets
PM10 offsets requirements are described in UAC R307-421-2. They apply to new or modified sources that are
located in or impact Salt Lake County or Utah County and increase SO2 or NOX by 25 tpy or more 12. The
Brigham City facility is located in Box Elder County and is therefore not subject to the PM10 offset
requirements of R307-403.
7.1.3 Ozone Offsets
Ozone offsets requirements recorded in UAC R307-420-3(2) and VOC offsets are applicable to significant
sources located within or impacting an ozone nonattainment area of the NAAQS.

The Brigham City facility is located in Box Elder County and is therefore not subject to ozone offset
requirements.

12 UAC R307-421-3. Offset Requirements.

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8. APPLICABLE REGULATIONS
8.1 UDAQ Air Quality Rules
Steves has evaluated the applicability of each rule under the UAC Title R307. Rules generally applicable to
Steves but not affected by this project have not been addressed.
Table 8-1. Evaluation of UDAQ Air Quality Rules
Reference Regulation Name Applicability
Yes No
R307-101 General Requirements X
R307-102 1 General Requirements: Broadly Applicable
Requirements X
R307-103 1 Administrative Procedures X
R307-104

Conflict of Interest X
R307-105 1 General Requirements: Emergency controls X
R307-107

General Requirements: Breakdowns X
R307-110
1 General Requirements: State Implementation
Plan X
R307-115 1 General Conformity X

R307-120
General Requirements: Tax Exemption for Air
Pollution Control Equipment X
R307-121
General Requirements: Clean Air and Efficient
Vehicle Tax Credit X
R307-122
General Requirements: Heavy Duty Vehicle Tax
Credit X
R307-123
General Requirements: Clean Fuels and Vehicle
Technology Grant and Loan Program X
R307-124
General Requirements: Conversion to Alternative
Fuel Grant Program X
R307-125
Clean Air Retrofit, Replacement, and Off-Road
Technology Program X
R307-130 1 General Penalty Policy X
R307-135
Enforcement Policy for Asbestos Hazard
Emergency Response Act X
R307-150 Emission Inventories X
R307-165

Emission Testing X
R307-170 Continuous Emission Monitoring Program X
R307-201
1 Emission Standards: General Emission Standards X
R307-202 Emission Standards: General Burning X

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Reference Regulation Name Applicability
Yes No
R307-203 Emission Standards: Sulfur Content of Fuels X
R307-204 Emission Standards: Smoke Management X
R307-205
1 Emission Standards: Fugitive Emissions and
Fugitive Dust X
R307-206 Emission Standards: Abrasive Blasting X
R307-207
Residential Fireplaces and Solid Fuel Burning
Devices X
R307-208 Outdoor Wood Boilers X
R307-210 Standards of Performance for New Stationary
Sources X
R307-214 National Emission Standards for Hazardous Air
Pollutants X
R307-220
Emission Standards: Plan for Designated Facilities X
R307-221
Emission Standards: Emission Controls for
Existing Municipal Solid Waste Landfills X
R307-222
Emission Standards: Existing incinerator for
Hospital, Medical, Infectious Waste X
R307-223
Emission Standards: Existing Small Municipal
Waste Combustion Units X
R307-224
Mercury Emission Standards: Coal Fired Electric
Generating Units X
R307-230

NOX Emission Limits for Natural Gas-Fired Water
Heaters X
R307-250
Western Backstop Sulfur Dioxide Trading Program X
R307-301
Utah and Weber Counties: Oxygenated Gasoline
Program as a Contingency Measure X
R307-302 Solid Fuel Burning Devices X
R307-303 Commercial Cooking X
R307-304

Solvent Cleaning X
R307-305

Nonattainment and Maintenance Areas for PM10:
Emission Standards X
R307-306
PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting X
R307-307

Road Salting and Sanding X
R307-309
1 Nonattainment and Maintenance Areas for PM10
and PM2.5: Fugitive Emissions and Fugitive Dust X

Steves and Sons / NOI Air Permit Application
Trinity Consultants 8-3
Reference Regulation Name Applicability
Yes No
R307-310
Box Elder County: Trading of Emission Budgets
for Transportation Conformity X
R307-311 Utah County: Trading of Emission Budgets for
Transportation Conformity X
R307-312
Aggregate Processing Operations for PM2.5
Nonattainment Areas X
R307-320

Ozone Maintenance Areas and Ogden City:
Employer Based Trip Reduction X
R307-325

Ozone Nonattainment and Maintenance Areas:
General Requirements X
R307-326
Ozone Nonattainment and Maintenance Areas:
Control of Hydrocarbon Emissions in Petroleum
Refineries
X
R307-327
Ozone Nonattainment and Maintenance Areas:
Petroleum Liquid Storage X
R307-328

Gasoline Transfer and Storage X
R307-335

Degreasing X
R307-341

Ozone Nonattainment and Maintenance Areas:
Cutback Asphalt X
R307-342

Adhesives and Sealants X
R307-343 Wood Furniture Manufacturing Operations X
R307-344 Paper, Film, and Foil Coatings X
R307-345 Fabric and Vinyl Coatings X
R307-346 Metal Furniture Surface Coatings X
R307-347 Large Applicable Surface Coatings X
R307-348 Magnet Wire Coatings X
R307-349 Flat Wood Panel Coating X
R307-350 Misc. Metal Parts and Product Coating X
R307-351

Graphic Arts X
R307-352 Metal Container, Closure, and Coil Coatings X
R307-353 Plastic Parts Coatings X
R307-354 Automotive Refinishing Coatings X
R307-355 Aerospace Manufacture and Rework Facilities X
R307-356 Appliance Pilot Light X
R307-357 Consumer Products X
R307-361

Architectural Coatings X
R307-401

Permit: New and Modified Sources X

Steves and Sons / NOI Air Permit Application
Trinity Consultants 8-4
Reference Regulation Name Applicability
Yes No
R307-403
Permits: New and Modified Sources in
Nonattainment and Maintenance Areas X
R307-405 Permits: Major Sources in Attainment or
Unclassified Areas (PSD) X
R307-406 Visibility X
R307-410 Permits: Emission Impact Analysis X
R307-414 1 Permits: Fees for Approval Orders X

R307-415 Permits: Operating Permit Requirements X
R307-417 Permits: Acid Rain Sources X
R307-420

Permits: Ozone Offset Requirements in Salt Lake
and Utah County X
R307-421

Permits: PM10 Offset Requirements in Salt Lake
County and Utah County X
R307-424
Permits: Mercury Requirements for Electric
Generating Units X
R307-501 to
511
Oil and Gas Industry X
R307-801

Utah Asbestos Rule X
R307-840

Lead-Based Paint Program Purpose, Applicability,
and Definitions X
R307-841
Residential Property and Child-Occupied Facility
Renovation X
R307-842

Lead-Based Paint Activities X
1. This rule is not specific to operational-compliance requirements and is therefore not discussed in this NOI air permit application.
8.1.1 UAC R307-101 General Requirements:
Chapter 19-2 and the rules adopted by the Air Quality Board constitute the basis for control of air pollution
sources in the state. These rules apply and will be enforced throughout the state and are recommended for
adoption in local jurisdictions where environmental specialists are available to cooperate in implementing rule
requirements.

NAAQS, NSPS, National PSD standards, and the NESHAP apply throughout the nation and are legally
enforceable in Utah.

Steves will comply and conform to the definitions, terms, abbreviations, and references used in the R307-
101 and 40 CFR.
8.1.2 UAC R307-107 General Requirements: Breakdowns
Steves will report breakdowns at its Brigham City facility within 24 hours via telephone, electronic mail, fax,
or other similar method and provide detailed written description within 14 days of the onset of the incident

Steves and Sons / NOI Air Permit Application
Trinity Consultants 8-5
to UDAQ. Breakdown reports will include all reporting details outlined in R307-107-2, including, but not
limited to, the cause and nature of the event, estimated quantity of emissions, and time of emissions.
8.1.3 UAC R307-150 Emission Inventories:
For every third year, the Brigham City facility will report its emissions inventory in accordance with R307-
150-6. The emissions inventory shall include all criteria pollutants, including filterable and condensable PM,
HAPs not exempted in R307-150-8, and chargeable pollutants in accordance with R307-150-6.
8.1.5 UAC R307-342 Adhesives and Sealants
This rule requires that no person apply any adhesive, sealant, adhesive primer, or sealant primer with a VOC
content in excess of the limits in Table 1 in the rule, unless that person uses an add-on control device. The
adhesive used by Steves is below each of these limits. Therefore, no add-on control devices are required.
Proper application technique requirements and administrative requirements will be met, including the
maintenance of records to demonstrate compliance with this rule.

8.1.6 UAC R307-343 Wood Furniture Manufacturing Operations
This rule applies to sources with the following SIC codes: 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541,
2599, or 5712. The Brigham City facility is classified under 2431, , and is therefore not applicable to
this rule.
8.1.8 UAC R307-401-8: Permit New and Modified Sources - Approval Order
(1) The director will issue an approval order (AO) if all conditions and regulations have been met.
(a) The degree of pollution control for emissions, to include fugitive emissions and fugitive dust, is at
least best available control technology. When determining best available control technology for a new or
modified source in an attainment area that will emit VOC or NOX, best available control technology shall be
at least as stringent as any Control Technique Guidance document that has been published by EPA that is
applicable to the source.
(2) The Brigham City facility will require that all pollution control equipment be adequately and properly
maintained.
(3) Receipt of an AO does not relieve any owner or operator of the responsibility to comply with the
provisions of R307 or the State Implementation Plan.

BACT provisions specified in UAC R307-401 have been demonstrated in Section 5.

The Brigham City facility will comply with all applicable requirements detailed above.
8.2 Federal Rules: National Emission Standards for Hazardous Air
Pollutants
40 CFR Part 63 requires certain source categories to control HAPs emissions to the level achievable by the
Maximum Achievable Control Technology (MACT), or, in some cases, the Generally Applicable Control
Technology (GACT), as specified in the applicable subparts. Emissions standards and compliance
requirements are divided by source category based on PTE. The Brigham City facility is a true minor source
with respect to HAP emissions because it has a PTE of less than 10 tpy of a single HAP (e.g., glycol ether)
and 25 tpy of total HAPs.
Steves and Sons / NOI Air Permit Application
Trinity Consultants 8-6
8.2.1 NESHAP Subpart A – General Provisions
All affected sources subject to source-specific NESHAP are subject to the general provisions of NESHAP
Subpart A except where specifically exempted by the source-specific NESHAP. Subpart A requires initial
notification, performance testing, recordkeeping, and monitoring, provides reference methods, and
mandates general control device requirements for all other subparts, as applicable.
8.2.2 NESHAP Subpart JJ – Wood Furniture Manufacturing Operations
This regulation applies to each facility that is engaged in the manufacture of wood furniture or wood
furniture components and that is located at a major source of HAP. As the Brigham City facility
manufactures doors and does not manufacture wood furniture, as defined in 40 CFR 63.801, this rule is not
applicable.
8.2.3 Non-Applicability of All Other NESHAP
The applicability of all other NESHAP subparts can be readily ascertained based on the industrial source
category covered. All other NESHAP are categorically not applicable to the facility.
8.3 Federal Rules: New Source Performance Standards
40 CFR Part 60 requires new, modified, or reconstructed sources with certain source categories to control
emissions to the level achievable by the best-demonstrated technology as specified in the applicable
subparts.
8.3.1 NSPS Subpart A – General Provisions
All affected sources subject to one (1) or more source-specific NSPS are subject to the general provisions of
NSPS Subpart A except where specifically exempted by the source-specific NSPS. Subpart A requires initial
notification, performance testing, recordkeeping, and monitoring, provides reference methods, and
mandates general control device requirements for all other subparts, as applicable.
8.3.2 Non-Applicability of All Other NSPS
The NSPS subparts at the time of this application are categorically not applicable to the facility.
Steves and Sons / NOI Air Permit Application
Trinity Consultants A
APPENDIX A. FORMS
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
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
References/assumptions, SDS, for each calculation and pollutant
All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
Visibility impact analysis, Class I area impact 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.
a pSfs March 2024
AIR OUA LIT Y lnitial Approval Order Approval Order Modification{
General Owner and Source lnformation
l.Company name and mailing address
Steves and Sons, lnc.
203 Humble Avenue
San Antonio, fX 78225
Phone No
Fax No.:
(21O) 924-5111()
Phone no.: ([phone]
Email: [e-mail]
" Company contacl only, consultant ot independenl contractor conlact
intormation can be plovided in a covor lefter
3. Source name and physical address (if different from
above):' Steves and Sons, lnc
1080 North Main Street
Brigham City, UT 31714
Phone no.: (
Fax no.: (
)
)
4. Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum
UTM: "12
X: 415,500m E
y: 4,598,250 m N
5. The Source is located ;n Box Elder 6. Standard Industrial classificatLoi loadc (src)
7. lf request for modification, AO# to be modified p4qs sAN'161020001-22 DATED: 12 123 122
8. Brief (50 words or less) description of process.
Steves and Sons is a door manufacturing company seeking to increase their usage of adhesive in
order to attain the Brigham City facility's potential.
Electronic NOI
9. A complete and accurate electronic NOI submitted to OAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal
Authorization/Si gnature
I hereby certify that on and data submifted in and with this application is completely true, accurate and
complete, ba e inquiry made by me and to the best of my knowledge and belief
Si nature
TeleDhone Number:-et")*L-Kt'l
Email
St<r
Name (Type or pri
T tle
O\to*>Lou*arvt
Date:
blrq l*q
'lof1
Form 2
Company lnformation/Notice of lntent (NOl)
Utah Division of Air Quality
New Source Review Section
Application for:
2. Company*' contacl for environmental matters:
Austin Payne
County
Electronic Copy Submittd I aotnT
I
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data -For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3. Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5. Condition(s) Changing:
6. Description of Permit/Process Change**
7. New or modified materials and quantities used in process. **
Material Quantity Annually
8. New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Page 1 of 1
Company___________________________
_____________________________
Form
Emissions Information
Criteria/GHGs/
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
Steves and Sons / NOI Air Permit Application
Trinity Consultants B
APPENDIX B. EMISSION CALCULATIONS
Appendix B. Emissions Calculations
Table 2. HAP Summary
Project Total in
Hourly Emissions
Project Total in
Annual Emissions ETV1
(lb/hr) (tpy) (lb/hr)
Methanol 0.424 0.33
67.941 No
Formaldehyde 0.031 0.02
0.083 No
Vinyl Acetate 0.076 0.06
8.591 No
Glycol Ethers 1.450 1.13
-No
1. The Emission Threshold Value (ETV) assumes a 50-100 m distance to the fenceline and vertically
unrestricted releases.
Pollutant Modeling
Required?
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Appendix B. Emissions Calculations
Doors Produced per Day 10,000
Weeks Per Year 52
Days Per week 5
Facility Hours per Day 16
Facility Hours per Week 80
Facility Hours per Year 4160
Doors per Year 2,500,000
Doors per Hour 601
Adhesive use (hours/day)16
Adhesive use increase (hours/day)6
Woodworking (hours/day)16
Spray Booths (hours/day)10
Adhesive Usage (tote/day)5.0
Adhesive Usage Increase (tote/day)1.1
Est. Adhesive Usage Increase (lb/yr)661,440
Adhesive Usage Increase (gal/yr)72,186
Adhesive Usage Increase (gal/hr)46
Door Type % of Production Adhesive Use/Door1 (lb)Primer Use/Door1 (gal)
Hollow Core 73%0.625 0.012
Solid Core 27%1.813 0.012
Average 0.946 0.012
Table 4. Target Production Output
1Study performed by Steves. Determined by dividing actual material usage by door output. 10 oz adhesive per hollow-core door, 29 oz
adhesive per solid-core door. Values account for all waste material.
Table 3. Target Production Schedule, Output, and
Material Usage
Hours and Production
Adhesive Use1
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Appendix B. Emissions Calculations
Table 11. Glue Information
Product: G-2360 SJW (IFS Industries)
Product Type: Construction and Panel Adhesive
Component Min Weight % in Product Max Weight % in Product
Solids1 37% 46%
Water2 58% 60%
Total VOC2,3 1.43% 2.1%
Component Weight % in Product
Diethylene Glycol Monobutyl Ether
Acetate (DB Acetate)1.9%
Methanol 0.1%
Vinyl Acetate 0.1%
Component CAS Number Weight % in Product
Diethylene Glycol Monobutyl Ether
Acetate 124-17-4 1.9%
Methanol 67-56-1 0.1%
Formaldehyde1,2 50-00-0 0.04%
Vinyl Acetate 108-05-4 0.1%
Glue Specific Gravity1 1.10
Density of Water (lb/gal)8.33
Glue Density (lb/gal)9.16
1G-2360 SJW Safety Data Sheet (Feb 16, 2016)
Significant Potential VOC Contributors1
HAP/TAP Components1
Speciation of Adhesive
3G-2360 SJW contains 2.1 % by weight VOC when calculated according to EPA Method 24.
1RFI from IFS Industries (November 24, 2020), , states that solids
content is between 37-39%. Product SDS lists solids content as 46%.
2RFI from IFS Industries (November 24, 2020),
1RFI from IFS Industries (November 24, 2020),
2Based on the polymerization process associated with the polyvinyl acetate resin and impurities from raw materials,
formaldehyde may be present at low (< 400 ppm) levels.
1RFI from IFS Industries (November 24, 2020), Provides
refinements to SDS values for HAP components.
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Brigham City 4 of
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March 2024