DAQ-2024-009868

DAQE-AN161280001-24

{{$d1 }}

Lorin Lewis
Steel Coatings Inc.
410 South Monterey Street
Salt Lake City, UT 84104
[e-mail]

Dear Lorin Lewis:

Re: Approval Order: New Metal Coating Plant
Project Number: N161280001

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
November 2, 2022. Steel Coatings Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Enqiang He, 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:EH:jg

cc: Salt Lake County Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

August 5, 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-AN161280001-24
New Metal Coating Plant

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Steel Coatings Inc. - Salt Lake Metal Parts Coating Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

August 5, 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 ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN161280001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Steel Coatings Inc. Steel Coatings Inc. - Salt Lake Metal Parts
Coating Facility

Mailing Address Physical Address
410 South Monterey Street 410 South Monterey Street
Salt Lake City, UT 84104 Salt Lake City, UT 84104

Source Contact UTM Coordinates
Name: Lorin Lewis 419,144 m Easting
Phone: [phone],512,554 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3479 (Coating, Engraving, & Allied Services, NEC)

SOURCE INFORMATION
General Description
Steel Coatings Inc. operates a metal coating plant in Salt Lake City, Salt Lake County. Metal parts are
received, prepared using degreasing and abrasive blasting operations, and then powder-coated or painted.
Powder coated metal parts will also cure in the ovens. Annual consumption of natural gas and abrasive
materials for outdoor blasting operations is limited to 7.62 MMscf and 375,000 pounds, respectively.

NSR Classification
New Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
None

DAQE-AN161280001-24
Page 4

Project Description
Steel Coatings, Inc. has proposed to use the following processes and equipment:

1. One (1) vapor degreaser.
2. Abrasive blasting operations include one (1) outdoor blasting area and one (1) indoor blasting building.
3. Painting operations, including two (2) paint booths and one (1) partially enclosed paint area.
4. Powder coating operations, including two (2) powder coat booths controlled with a cyclone and one (1)
internally vented booth, and
5. Natural gas combustion equipment, including ovens and space heating equipment.

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 399.00
Carbon Monoxide 0.32
Nitrogen Oxides 0.38
Particulate Matter - PM10 4.39
Particulate Matter - PM2.5 1.65
Sulfur Dioxide 0.00
Volatile Organic Compounds 18.92

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
1,2-Butylene Oxide (CAS #86737) 118
Cumene (CAS #98828) 40
Ethyl Benzene (CAS #100414) 760
Generic HAPs (CAS #GHAPS) 180
Methanol (CAS #67561) 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 940
n-Propyl Bromide (CAS #110827) 6980
Naphthalene (CAS #91203) 20
Toluene (CAS #108883) 520
Xylenes (Isomers And Mixture) (CAS #1330207) 3400
Change (TPY) Total (TPY)
Total HAPs 6.55

SECTION I: GENERAL PROVISIONS

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

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

DAQE-AN161280001-24
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]

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

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Steel Coatings
Metal Parts Cleaning and Painting Facility

II.A.2 One (1) Open-Top Vapor Degreaser

II.A.3 Abrasive Blasting Operations
One (1) outdoor blasting area
One (1) enclosed blasting building controlled with a dust collector
Including three (3) blaster guns using grit and silica sand

II.A.4 Three (3) Painting Operations
Including two (2) paint booths and one (1) partially enclosed (on two sides and the top) paint area
The paint booths are controlled with filters

II.A.5 Three (3) Powder Coating Booths
Powder Coat Booths #1 and #2 are controlled with a cyclone
Powder Coat Booth #3 vents indoors (for information only)

DAQE-AN161280001-24
Page 6

II.A.6 Natural Gas Combustion Equipment
Four (4) Powder Coating Ovens, one (1) Paint Hook Burn-Off Oven, and Comfort Heating
Equipment (for information only)
The combined rating for all natural gas combustion equipment is approximately 3 MMBtu/hr

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any source on site to exceed 20% opacity. [R307-401-8]

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of visible 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 allow visible emissions to exceed the following opacity limits:

A. Any cyclone stack - 10%.

B. Any paint booth stack - 10%.

C. Any emissions from the dust collector stack of the indoor blasting building - 10%.

D. Any fugitive emissions from the outdoor blasting operations - 20%.

E. Any natural gas combustion devices - 10%.

F. Vapor degreaser operations - No visible emissions.

[R307-306-4, R307-401-8]

II.B.1.b.1 Visible emissions from intermittent sources shall use procedures similar to Method 9, but the
requirement for observations to be made at 15 second intervals over a six-minute period shall not
apply. [R307-306-5]

II.B.1.b.2 Visible emissions from unconfined blasting operations shall be measured at the densest point of
the emission after a major portion of the spent abrasive has fallen out at a point not less than five
feet nor more than twenty-five feet from the impact surface from any single abrasive blasting
nozzle. [R307-306-5]

II.B.1.b.3 An unconfined blasting operation that uses multiple nozzles shall be considered a single source
unless it can be demonstrated by the owner or operator that each nozzle, measured separately,
meets the visible emission standards in this AO. [R307-306-5]

II.B.1.c The owner/operator shall only use natural gas in the ovens and space heating equipment.
[R307-401-8]

II.B.1.d The owner/operator shall not consume more than 7.62 MMscf of natural gas per rolling
12-month period. [R307-401-8]

DAQE-AN161280001-24
Page 7

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

A. Determine natural gas consumption by monthly billing statements from a 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 Degreasing Requirements
II.B.2.a The owner/operator shall comply with applicable requirements in R307-335 for degreasing
operations. [R307-335]

II.B.2.b The owner/operator shall not operate the vapor degreaser containing n-propyl bromide prior to
9:00 a.m. or after 3:00 p.m. each day. [R307-410-5]

II.B.2.b.1 The owner/operator shall keep the following records when operating the vapor degreaser:

A. The date the vapor degreaser is operated.

B. The start time for the vapor degreaser operations.

C. The end time for the vapor degreaser operations.

D. The above records shall be kept when the plant is in operation.

[R307-410-5]

II.B.2.c The owner/operator shall not allow the release height of the vapor degreaser stack to be less than
48 feet above ground level. [R307-410-5]

II.B.3 Abrasive Blasting Requirements
II.B.3.a The owner/operator shall not consume:

A. More than 300,000 lbs of grit (mineral abrasive) used in the outdoor blasting
operations per rolling 12-month period.

B. More than 75,000 lbs of silica sand used in the outdoor blasting operations per rolling
12-month period.

[R307-401-8]

DAQE-AN161280001-24
Page 8

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall

A. Determine the grit and silica sand used in the outdoor blasting operations by
maintaining an operations log.

B. Record the abrasive usage in lbs each day.

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

D. Keep all the records for all periods when the plant is in operation.

[R307-401-8]

II.B.3.b The owner/operator shall comply with applicable requirements in R307-306 for abrasive blasting
operations. [R307-306]

II.B.4 Paint Booth Requirements
II.B.4.a The owner/operator shall install and operate filters in the paint booths to control particulate
emissions from the painting operations. The owner/operator shall vent all exhaust air streams
from the paint booths to the filters before being vented to the atmosphere. The owner/operator
shall replace the filters in accordance with the manufacturer's recommendations. [R307-401-8]

II.B.4.b The owner/operator shall install and operate a cyclone to control particulate emissions from
Powder Coat Booths #1 and #2. The owner/operator shall vent all exhaust air streams from the
powder coating operations to the cyclone before being vented to the atmosphere. [R307-401-8]

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

18.90 tons per rolling 12-month period of VOCs.
1.70 tons per rolling 12-month period of xylene.
0.38 tons per rolling 12-month period of ethyl benzene .
0.26 tons per rolling 12-month period of toluene.
0.47 tons per rolling 12-month period of methyl isobutyl ketone.
0.07 tons per rolling 12-month period of methanol.
3.49 tons per rolling 12-month period of n-propyl bromide.
0.06 tons per rolling 12-month period of 1,2-butylene oxide.
0.09 tons per rolling 12-month period of generic HAPs.
6.55 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]

[R307-401-8]

DAQE-AN161280001-24
Page 9

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 comply with applicable requirements in R307-350 for miscellaneous
metal parts and product coating operations. [R307-350]

PERMIT HISTORY

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

Is Derived From NOI dated November 2, 2022
Incorporates Additional information dated January 17, 2023
Incorporates Additional information dated March 9, 2023
Incorporates Additional information dated March 15, 2023
Incorporates Additional information dated August 8, 2023
Incorporates Additional information dated August 16, 2023
Incorporates Additional information dated March 26, 2024
Incorporates DAQE-MN161280001-24 dated April 30, 2024

DAQE-AN161280001-24
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 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-IN161280001-24

June 20, 2024

Lorin Lewis
Steel Coatings Incorporated
410 South Monterey Street
Salt Lake City, UT 84104
[e-mail]

Dear Lorin Lewis:

Re: Intent to Approve: New Metal Coating Plant
Project Number: N161280001

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

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:EH:jg

cc: Salt Lake County Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN161280001-24
New Metal Coating Plant

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Steel Coatings Incorporated - Salt Lake Metal Parts Coating Facility

Issued On
June 20, 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 .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-IN161280001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Steel Coatings Incorporated Steel Coatings Incorporated - Salt Lake Metal
Parts Coating Facility

Mailing Address Physical Address
410 South Monterey Street 410 South Monterey Street
Salt Lake City, UT 84104 Salt Lake City, UT 84104

Source Contact UTM Coordinates
Name: Lorin Lewis 419,144 m Easting
Phone: [phone],512,554 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3479 (Coating, Engraving, & Allied Services, NEC)

SOURCE INFORMATION
General Description
Steel Coatings Incorporated operates a metal coating plant in Salt Lake City, Salt Lake County. Metal
parts are received, prepared using degreasing and abrasive blasting operations, and then powder coated or
painted. Powder-coated metal parts will also cure in the ovens. Annual consumption of natural gas and
abrasive materials for outdoor blasting operations is limited to 7.62 MMscf and 375,000 pounds,
respectively.
NSR Classification
New Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
None
Project Description
Steel Coatings Incorporated has proposed to use the following processes and equipment:

1. One (1) vapor degreaser.
2. Abrasive blasting operations include one (1) outdoor blasting area and one (1) indoor blasting building.
3. Painting operations, including two (2) paint booths and one (1) partially enclosed paint area.
DAQE-IN161280001-24
Page 4

4. Powder coating operations, including two (2) powder coat booths controlled with a cyclone and one (1)
internally vented booth, and
5. Natural gas combustion equipment, including ovens and space heating equipment.

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 399.00
Carbon Monoxide 0.32
Nitrogen Oxides 0.38
Particulate Matter - PM10 4.39
Particulate Matter - PM2.5 1.65
Sulfur Dioxide 0.00
Volatile Organic Compounds 18.92

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
1,2-Butylene Oxide (CAS #86737) 118
Cumene (CAS #98828) 40
Ethyl Benzene (CAS #100414) 760
Generic HAPs (CAS #GHAPS) 180
Methanol (CAS #67561) 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 940
n-Propyl Bromide (CAS #110827) 6980
Naphthalene (CAS #91203) 20
Toluene (CAS #108883) 520
Xylenes (Isomers And Mixture) (CAS #1330207) 3400
Change (TPY) Total (TPY)
Total HAPs 6.55

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 Salt Lake Tribune and Deseret News on June 23, 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.

DAQE-IN161280001-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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

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

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

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

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

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

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

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

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Steel Coatings
Metal Parts Cleaning and Painting Facility

DAQE-IN161280001-24
Page 6

II.A.2 One (1) Open-Top Vapor Degreaser

II.A.3 Abrasive Blasting Operations
One (1) outdoor blasting area
One (1) enclosed blasting building controlled with a dust collector
Including three (3) blaster guns using grit and silica sand

II.A.4 Three (3) Painting Operations
Including two (2) paint booths and one (1) partially enclosed (on two sides and the top) paint area
The paint booths are controlled with filters

II.A.5 Three (3) Powder Coating Booths
Powder Coat Booths #1 and #2 are controlled with a cyclone
Powder Coat Booth #3 vents indoors (for information only)

II.A.6 Natural Gas Combustion Equipment
Four (4) Powder Coating Ovens, one (1) Paint Hook Burn-Off Oven, and Comfort Heating
Equipment (for information only)
The combined rating for all-natural gas combustion equipment is approximately 3 MMBtu/hr

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 Site-Wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any source on site to exceed 20% opacity. [R307-401-8]

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of visible 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 allow visible emissions to exceed the following opacity limits:

A. Any cyclone stack - 10%.

B. Any paint booth stack - 10%.

C. Any emissions from the dust collector stack of the indoor blasting building
- 10%.

D. Any fugitive emissions from the outdoor blasting operations - 20%.

E. Any natural gas combustion devices - 10%.

F. Vapor degreaser operations - no visible emissions.

[R307-306-4, R307-401-8]

DAQE-IN161280001-24
Page 7

II.B.1.b.1 Visible emissions from intermittent sources shall use procedures similar to Method 9, but the
requirement for observations to be made at 15-second intervals over a six-minute period shall not
apply. [R307-306-5]

II.B.1.b.2 Visible emissions from unconfined blasting operations shall be measured at the densest point of
the emission after a major portion of the spent abrasive has fallen out at a point not less than five
(5) feet nor more than twenty-five feet from the impact surface from any single abrasive blasting
nozzle. [R307-306-5]

II.B.1.b.3 An unconfined blasting operation that uses multiple nozzles shall be considered a single source
unless it can be demonstrated by the owner or operator that each nozzle, measured separately,
meets the visible emission standards in this AO. [R307-306-5]

II.B.1.c The owner/operator shall only use natural gas in the ovens and space heating equipment. [R307-
401-8]

II.B.1.d The owner/operator shall not consume more than 7.62 MMscf of natural gas per rolling 12-
month period. [R307-401-8]

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

A. Determine natural gas consumption by monthly billing statements from a 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 Degreasing Requirements
II.B.2.a The owner/operator shall comply with applicable requirements in R307-335 for degreasing
operations. [R307-335]

II.B.2.b The owner/operator shall not operate the vapor degreaser containing n-propyl bromide prior to
9:00 a.m. or after 3:00 p.m. each day. [R307-410-5]

II.B.2.b.1 The owner/operator shall keep the following records when operating the vapor degreaser:

A. The date the vapor degreaser is operated.

B. The start time for the vapor degreaser operations.

C. The end time for the vapor degreaser operations.

D. The above records shall be kept when the plant is in operation.

[R307-410-5]

II.B.2.c The owner/operator shall not allow the release height of the vapor degreaser stack to be less than
48 feet above ground level. [R307-410-5]

DAQE-IN161280001-24
Page 8

II.B.3 Abrasive Blasting Requirements
II.B.3.a The owner/operator shall not consume:

A. More than 300,000 lbs of grit (mineral abrasive) used in the outdoor blasting
operations per rolling 12-month period.

B. More than 75,000 lbs of silica sand used in the outdoor blasting operations per
rolling 12-month period.

[R307-401-8]

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall

A. Determine the grit and silica sand used in the outdoor blasting operations by
maintaining an operations log.

B. Record the abrasive usages in lbs each day.

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

D. Keep all the records for all periods when the plant is in operation.

[R307-401-8]

II.B.3.b The owner/operator shall comply with applicable requirements in R307-306 for abrasive blasting
operations. [R307-306]

II.B.4 Paint Booth Requirements
II.B.4.a The owner/operator shall install and operate filters in the paint booths to control particulate
emissions from the painting operations. The owner/operator shall vent all exhaust air streams
from the paint booths to the filters before being vented to the atmosphere. The owner/operator
shall replace the filters in accordance with the manufacturer's recommendations. [R307-401-8]

II.B.4.b The owner/operator shall install and operate a cyclone to control particulate emissions from
Powder Coat Booths #1 and #2. The owner/operator shall vent all exhaust air streams from the
powder coating operations to the cyclone before being vented to the atmosphere. [R307-401-8]

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

18.90 tons per rolling 12-month period of VOCs
1.70 tons per rolling 12-month period of xylene
0.38 tons per rolling 12-month period of ethyl benzene
0.26 tons per rolling 12-month period of toluene
0.47 tons per rolling 12-month period of methyl isobutyl ketone
0.07 tons per rolling 12-month period of methanol
3.49 tons per rolling 12-month period of n-propyl bromide
0.06 tons per rolling 12-month period of 1,2-butylene oxide
0.09 tons per rolling 12-month period of generic HAPs
6.55 tons per rolling 12-month period of all HAPs combined.

[R307-401-8]

DAQE-IN161280001-24
Page 9

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]

[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]

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 comply with applicable requirements in R307-350 for miscellaneous
metal parts and product coating operations. [R307-350]

PERMIT HISTORY

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

Is Derived From NOI dated November 2, 2022
Incorporates Additional information dated January 17, 2023
Incorporates Additional information dated March 9, 2023
Incorporates Additional information dated March 15, 2023
Incorporates Additional information dated August 8, 2023
Incorporates Additional information dated August 16, 2023
Incorporates Additional information dated March 26, 2024
Incorporates DAQE-MN161280001-24 dated April 30, 2024

DAQE-IN161280001-24
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 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

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
steel
Notice Authentication Number:
202406241039141890121
1761527914
Notice URL:
Back
Notice Publish Date:
Sunday, June 23, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Steel Coatings Incorporated Location: Steel Coatings Incorporated - Salt Lake
Metal Parts Coating Facility – 410 South Monterey Street, Salt Lake City, UT Project Description: Steel Coatings Incorporated operates a
metal coating plant in Salt Lake City, Salt Lake County. Metal parts are received, prepared using degreasing and abrasive blasting operations,
and the powder coated or painted. Powder-coated metal parts will also cure in the ovens. Equipment includes a vapor degreaser, blasting
operations, paint and powder coat booths, ovens, space heating equipment, and a cyclone. Annual consumption of natural gas and abrasive
materials for outdoor blasting operations is limited to 7.62 MMscf and 375,000 pounds, respectively. 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 23, 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 23, 2024
SLT0028176
Back
Order Number:
Classification:
Package:
Order Cost:
Referral Code:
Job Details
SLT0028176
Public Meeting/Hearing
Notices
Legals
$134.60
DAQE-NN161280001
Account Details
TERRI WEISS
PO BOX 144820
SALT LAKE CITY, UT 84114
801-536-4000
[e-mail]
UTAH DIVISION OF AIR QUALITY
The Salt Lake Tribune E-
Edition
All Zones
The Salt Lake Tribune
Legals
All Zones
Schedule for ad number SLT00281760
Sat Jun 22, 2024
Sun Jun 23, 2024
Jeree Greenwood <[e-mail]>
Thank you for placing your order with us.
2 messages
[e-mail] <[e-mail]>Thu, Jun 20, 2024 at 11:20 AM
To: [e-mail]
THANK YOU for your ad submission!
This is your confirmation that your order has been submitted. Below are the details of your transaction. Please save this confirmation for your
records.
6/20/24, 11:46 AM State of Utah Mail - Thank you for placing your order with us.
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Package:
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Referral Code:
Job Details
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Public Meeting/Hearing
Notices
Legals
$134.60
DAQE-NN105710048-24
Account Details
TERRI WEISS
PO BOX 144820
SALT LAKE CITY, UT 84114
801-536-4000
[e-mail]
UTAH DIVISION OF AIR QUALITY
Schedule for ad number SLT00281770
[Quoted text hidden]
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DAQE-NN161280001-24

June 20, 2024

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on June 23, 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: Salt Lake County
cc: Wasatch Front Regional Council

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-NN161280001-24
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: Steel Coatings Incorporated
Location: Steel Coatings Incorporated - Salt Lake Metal Parts Coating Facility – 410 South
Monterey Street, Salt Lake City, UT
Project Description: Steel Coatings Incorporated operates a metal coating plant in Salt Lake City, Salt
Lake County. Metal parts are received, prepared using degreasing and abrasive
blasting operations, and the powder coated or painted. Powder-coated metal parts
will also cure in the ovens. Equipment includes a vapor degreaser, blasting
operations, paint and powder coat booths, ovens, space heating equipment, and a
cyclone. Annual consumption of natural gas and abrasive materials for outdoor
blasting operations is limited to 7.62 MMscf and 375,000 pounds, respectively.

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 23, 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 23, 2024

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

DAQE-

RN161280001
June 6, 2024

Lorin Lewis
Steel Coatings Inc.
410 South Monterey Street
Salt Lake City, UT 84104
[e-mail]

Dear Lorin Lewis,

Re: Engineer Review:
New Metal Coating Plant
Project Number: N161280001

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. Steel Coatings Inc.
should complete this review within 10 business days of receipt.

Steel Coatings Inc. should contact Mr. Enqiang He at [phone] if there are questions or concerns
with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr.
Enqiang He 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 Steel Coatings Inc. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Steel Coatings 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 N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N161280001
Owner Name Steel Coatings Inc.
Mailing Address 410 South Monterey Street
Salt Lake City, UT 84104

Source Name Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
Source Location 410 South Monterey Street
Salt Lake City, UT 84104

UTM Projection 419,144 m Easting, 4,512,554 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3479 (Coating, Engraving, & Allied Services, NEC)

Source Contact Lorin Lewis
Phone Number [phone]
Email [e-mail]

Billing Contact Lorin Lewis
Phone Number [phone]
Email [e-mail]

Project Engineer Mr. Enqiang He, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 2, 2022
Date of Accepted Application May 13, 2024

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 2
SOURCE DESCRIPTION

General Description
Steel Coatings Inc. operates a metal coating plant in Salt Lake City, Salt Lake County. Metal
parts are received, prepared using degreasing and abrasive blasting operations, and then powder
coated or painted. Powder coated metal parts will also cure in the ovens. Annual consumption of
natural gas and abrasive materials for outdoor blasting operations are limited to 7.62 MMscf and
375,000 pounds, respectively.

NSR Classification:
New Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County
SO2 NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NA

Project Proposal
New Metal Coating Plant

Project Description
Steel Coatings, Inc has proposed to use the following processes and equipment:

1. One (1) vapor degreaser
2. Abrasive blasting operations including one (1) outdoor blasting area and one (1) indoor
blasting building
3. Painting operations including two (2) paint booths and one (1) partially enclosed paint
area
4. Powder coating operations including two (2) powder coat booths controlled with a
cyclone and one (1) internally-vented booth, and
5. Natural gas combustion equipment including ovens and space heating equipment

EMISSION IMPACT ANALYSIS
Emission increases from any criteria pollutant are less than the thresholds established in R307-410-4; therefore,
criteria pollutant modeling is not required. The source operates a vapor degreaser that uses n-propyl bromide
as solvent. The HAP emissions trigger the toxic screening threshold value, therefore, the source has conducted
a modeling analysis. The predicted concentration for n-propyl bromide over 24-hr period is less than the toxic
screening level at 84.1% under the following conditions:

A. The owner/operator shall not operate the vapor degreaser prior to 9:00 am or after 3:00 pm each day,
and
B. The owner/operator shall not allow the release height of the vapor degreaser stack to be less than 48
feet above ground level.

The above conditions have been incorporated into this ER. [Last updated May 13, 2024]

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 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 399.00
Carbon Monoxide 0.32
Nitrogen Oxides 0.38
Particulate Matter - PM10 4.39
Particulate Matter - PM2.5 1.65
Sulfur Dioxide 0.00
Volatile Organic Compounds 18.92

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
1,2-Butylene Oxide (CAS #86737) 118
Cumene (CAS #98828) 40
Ethyl Benzene (CAS #100414) 760
Generic HAPs (CAS #GHAPS) 180
Methanol (CAS #67561) 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 940
n-Propyl Bromide (CAS #110827) 6980
Naphthalene (CAS #91203) 20
Toluene (CAS #108883) 520
Xylenes (Isomers And Mixture) (CAS #1330207) 3400
Change (TPY) Total (TPY)
Total HAPs 6.55

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

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding degreasing operations
There are a few methods to control VOC emissions from degreasing operations. The methods
include aqueous ultrasonic parts cleaning, thermal oxidation, and carbon adsorption Aqueous
ultrasonic parts cleaning has size limitations. The source usually clean very large parts. Therefore,
it is infeasible to use this technology to clean very large parts. Thermal oxidizers can usually
provide 95% efficiency for VOC controls. However, the annualized cost effectiveness is $24,949
per ton of VOC removed. Similar to the thermal oxidizers, carbon adsorption can also provide 95%
removal efficiency for VOCs. Annualized cost effectiveness for carbon adsorption is estimated at
$27,867 per ton of VOCs removed. Both technologies are economically infeasible for VOC
controls at this facility.

The degreasing operations shall comply with applicable requirements in R307-335. The applicable
requirements are considered as BACT. [Last updated August 17, 2023]

2. BACT review regarding abrasive blasting operations
Available control technologies for PM include enclosures (buildings) and using less PM generating
grit abrasives. However, because of the size limitations of the blasted parts and the proposed
building, large parts will have to be blasted outdoors where grit is used 80% (300,000 lbs/yr) and
sand 20% (75,000 lbs/yr). Small parts that can be brought in the proposed building will use grit at
375,000 lbs/yr. The building will be controlled with a dust collector with a control efficiency of
99.5%. The annual cost effectiveness is estimated at $8,735 per ton of particulate matter removed,
which is considered economically feasible. In addition, the source shall comply with applicable
requirements in R307-306. The Minor NSR Section considers these measures and applicable
requirements in the Rule as BACT for the abrasive blasting operations. [Last updated August 16,
2023]

3. BACT review regarding painting operations
Paint Booth #1
Available technologies to control VOC emissions from paint booths include using water-based
paint, thermal oxidation, carbon adsorption, and use powder coating whenever possible. The parts
painted at this facility are usually for outdoor applications. Extreme weather conditions and
chemical exposures require high quality of coating materials. It may be difficult to find water-
based paints that can perform well in the adverse environment. In addition, the source receives
parts from many customers, many of them have specific requirements. Therefore, using water-
based paints to coat the parts is infeasible in most cases. The source has also looked at thermal
oxidation and carbon adsorption to control VOCs from the paint booths. The annualized cost
effectiveness is $39,111 and $27,931 per ton of VOCs removed for thermal oxidation and carbon
adsorption, respectively. The source proposed to use powder coating as much as possible. The
source is subject to R307-350 for Miscellaneous Metal Parts and Products Coatings. The Minor
NSR Section considers the use of powder coating and the applicable requirements in the rule as
BACT for VOC controls.

The Source shall install and operate filters to control PM emissions from the paint booth. Visible
emissions from the paint booth are limited to 10% opacity. The Minor NSR Section considers the
filters and opacity limit as BACT for PM controls.

Paint Booth #2
Available control technologies discussed above for Paint Booth #1 are also available for Paint
Booth #2. Water-based paints are usually not feasible for the reasons discussed above. The

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 5
annualized cost effectiveness is $36,773 and $27,636 per ton of VOCs removed for thermal
oxidation and carbon adsorption, respectively. The source proposed to use powder coating as much
as possible. The source is subject to R307-350 for Miscellaneous Metal Parts and Products
Coatings. The Minor NSR Section considers the use of powder coating and the applicable
requirements in the rule as BACT for VOC controls.

The Source shall install and operate filters to control PM emissions from the paint booth. Visible
emissions from the paint booth are limited to 10% opacity. The Minor NSR Section considers the
filters and opacity limit as BACT for PM controls.

Paint Area #3
The paint Area #3 is a partially enclosed space used for painting large parts. There are 20% of all
parts that will be painted in the Paint Area #3. The solids in the paint will lose 30% due to
overspray and approximately 50% of the remaining solids due to fallout. It is estimated that 1.14
tpy of PM would be emitted to the atmosphere from the partially enclosed paint area. Therefore, it
is economically infeasible ($18,337 per ton of PM removed per year for a full enclosure and
installation and operation of a ventilation and a filter systems) to control such small PM
emissions. For VOC controls, because of only 20% painting jobs performed in the paint area, the
cost effectiveness would be doubled from the costs associated with Paint Booth #1 or #2.
Therefore, it would be too expensive to use thermal oxidation or carbon absorption technologies to
control VOC emissions.

The source is subject to R307-350 for Miscellaneous Metal Parts and Products Coatings. Visible
emissions from the paint area are limited to 10% opacity. The Minor NSR Section considers the
use of powder coating where possible, the opacity limit, and the applicable requirements in the rule
as BACT for VOC and PM controls [Last updated August 18, 2023]

4. BACT review regarding powder coating operations
The source operates three (3) powder coat booths. Two booths are controlled with cyclones.
Uncontrolled PM emissions from both booths are estimated less than 0.12 tpy. For such small
emissions and particle sizes, cyclones provide a reasonable control for PM. Visible emissions
from the cyclones are limited to 10% opacity. The third powder coat booth is equipped with a filter
and vents indoors. The Minor NSR Section considers the cyclone and opacity limit as BACT.
[Last updated April 4, 2023]

5. BACT review regarding powder coat ovens
The source operates natural gas-fired powder coat and paint hook burn-off ovens, and office and
building heating equipment. Emissions from the natural gas combustion are very small, with the
highest amount of emissions being 0.38 tpy of NOx. Therefore, it is economically infeasible to
control the emissions. Visible emissions from the natural gas combustion equipment are limited to
10% opacity. The Minor NSR Section considers the opacity limit as BACT. [Last updated August
18, 2023]

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):

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 6

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

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

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

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

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

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

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

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

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

II.A THE APPROVED EQUIPMENT

II.A.1
NEW
Steel Coatings
Metal Parts Cleaning and Painting Facility

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 7
II.A.2
NEW
One (1) Open Top Vapor Degreaser

II.A.3
NEW
Abrasive Blasting Operations
One (1) outdoor blasting area
One (1) enclosed blasting building controlled with a dust collector
Including three (3) blaster guns using grit and silica sand

II.A.4
NEW
Three (3) Painting Operations
Including two (2) paint booths and one (1) partially enclosed (on two sides and the top) paint
area
The paint booths are controlled with filters

II.A.5
NEW
Three (3) Powder Coating Booths
Powder Coat Booths #1 and #2 are controlled with a cyclone
Powder Coat Booth #3 vents indoors (for information only)

II.A.6
NEW
Natural Gas Combustion Equipment
Four (4) Powder Coating Ovens, one (1) Paint Hook Burn-Off Oven, and Comfort Heating
Equipment (for information only)
The combined rating for all-natural gas combustion equipment is approximately 3 MMBtu/hr

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

II.B REQUIREMENTS AND LIMITATIONS

II.B.1
NEW
Site-Wide Requirements
II.B.1.a
NEW
Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions
from any source on site to exceed 20% opacity. [R307-401-8]

II.B.1.a.1
NEW
Unless otherwise specified in this AO, opacity observations of visible emissions from
stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-
401-8]

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 8
II.B.1.b
NEW
The owner/operator shall not allow visible emissions to exceed the following opacity limits:

A. Any cyclone stack - 10%

B. Any paint booth stack - 10%

C. Any emissions from the dust collector stack of the indoor blasting building - 10%

D. Any fugitive emissions from the outdoor blasting operations - 20%

E. Any natural gas combustion devices - 10%

F. Vapor degreaser operations - No visible emissions.

[R307-306-4, R307-401-8]

II.B.1.b.1
NEW
Visible emissions from intermittent sources shall use procedures similar to Method 9, but the
requirement for observations to be made at 15 second intervals over a six (6) minute period
shall not apply. [R307-306-5]

II.B.1.b.2
NEW
Visible emissions from unconfined blasting operations shall be measured at the densest point
of the emission after a major portion of the spent abrasive has fallen out at a point not less
than five feet nor more than twenty-five feet from the impact surface from any single abrasive
blasting nozzle. [R307-306-5]

II.B.1.b.3
NEW
An unconfined blasting operation that uses multiple nozzles shall be considered a single
source unless it can be demonstrated by the owner or operator that each nozzle, measured
separately, meets the visible emission standards in this AO. [R307-306-5]

II.B.1.c
NEW
The owner/operator shall only use natural gas in the ovens and space heating equipment.
[R307-401-8]

II.B.1.d
NEW
The owner/operator shall not consume more than 7.62 MMscf of natural gas per rolling 12-
month period. [R307-401-8]

II.B.1.d.1
NEW
The owner/operator shall:

A. Determine natural gas consumption by monthly billing statements from a 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
NEW
Degreasing Requirements

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 9
II.B.2.a
NEW
The owner/operator shall comply with applicable requirements in R307-335 for degreasing
operations. [R307-335]

II.B.2.b
NEW
The owner/operator shall not operate the vapor degreaser containing n-propyl bromide prior to
9:00 am or after 3:00 pm each day. [R307-410-5]

II.B.2.b.1
NEW
The owner/operator shall keep the following records when operating the vapor degreaser:

A. The date the vapor degreaser is operated

B. The start time for the vapor degreaser operations

C. The end time for the vapor degreaser operations

D. The above records shall be kept when the plant is in operation.

[R307-410-5]

II.B.2.c
NEW
The owner/operator shall not allow the release height of the vapor degreaser stack to be less
than 48 feet above ground level. [R307-410-5]

II.B.3
NEW
Abrasive Blasting Requirements
II.B.3.a
NEW
The owner/operator shall not consume:

A. More than 300,000 lbs of grit (mineral abrasive) used in the outdoor blasting
operations per rolling 12-month period

B. More than 75,000 lbs of silica sand used in the outdoor blasting operations per rolling
12-month period.

[R307-401-8]

II.B.3.a.1
NEW
To determine compliance with a rolling 12-month total, the owner/operator shall

A. Determine the grit and silica sand used in the outdoor blasting operations by
maintaining an operations log

B. Record the abrasive usages in lbs each day

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

D. Keep all the records for all periods when the plant is in operation.

[R307-401-8]

II.B.3.b
NEW
The owner/operator shall comply with applicable requirements in R307-306 for abrasive
blasting operations. [R307-306]

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 10
II.B.4
NEW
Paint Booth Requirements
II.B.4.a
NEW
The owner/operator shall install and operate filters in the paint booths to control particulate
emissions from the painting operations. The owner/operator shall vent all exhaust air streams
from the paint booths to the filters before being vented to the atmosphere. The owner/operator
shall replace the filters in accordance with the manufacturer's recommendations. [R307-401-8]

II.B.4.b
NEW
The owner/operator shall install and operate a cyclone to control particulate emissions from
Powder Coat Booths #1 and #2. The owner/operator shall vent all exhaust air streams from
the powder coating operations to the cyclone before being vented to the atmosphere. [R307-
401-8]

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

18.90 tons per rolling 12-month period of VOCs
1.70 tons per rolling 12-month period of xylene
0.38 tons per rolling 12-month period of ethyl benzene
0.26 tons per rolling 12-month period of toluene
0.47 tons per rolling 12-month period of methyl isobutyl ketone
0.07 tons per rolling 12-month period of methanol
3.49 tons per rolling 12-month period of n-propyl bromide
0.06 tons per rolling 12-month period of 1,2-butylene oxide
0.09 tons per rolling 12-month period of generic HAPs
6.55 tons per rolling 12-month period of all HAPs combined.

[R307-401-8]

II.B.5.a.1
NEW
The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

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

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

[R307-401-8]

II.B.5.a.2
NEW
The owner/operator shall use a mass-balance method to quantify any amount of VOCs and
HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed
from the quantities calculated above to provide the monthly total emissions of VOCs and
HAPs. [R307-401-8]

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 11
II.B.5.a.3
NEW
The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used

C. The density of each material used

D. The volume of each VOC- and HAP-emitting material used

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
NEW
The owner/operator shall comply with applicable requirements in R307-350 for miscellaneous
metal parts and products coating operations. [R307-350]

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 12
PERMIT HISTORY

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

Is Derived From NOI dated November 2, 2022
Incorporates Additional information dated January 17, 2023
Incorporates Additional information dated March 9, 2023
Incorporates Additional information dated March 15, 2023
Incorporates Additional information dated August 8, 2023
Incorporates Additional information dated August 16, 2023
Incorporates Additional information dated March 26, 2024
Incorporates DAQE-MN161280001-24 dated April 30, 2024

REVIEWER COMMENTS

1. Comment regarding emission calculations:
Vapor degreasing - VOC emissions from vapor degreasing operations are based on annual purchase
of degreasing solvent less the amount of used solvent recycled. HAPs are calculated based on the
weight percentages of HAPs multiplied by the annual VOC emissions.

Particulate emissions from abrasive blasting are calculated using the annual blasting media (sand and
grit) purchased multiplied by the emission factors from AP-42 Table 13.2.6-1 and Table 4-2. The
source assumes 20% abrasive blasting operations use silica (75,000 lbs) sand and 80%m of blasting
operations use grit (300,000 lbs) in the outdoor blasting operations. The source proposes to consume
375,000 lbs of grit in the indoor building which is controlled by a dust collector with a 99.5 %
control efficiency.

Particulate emissions from powder coat operations are based on annual usages of the powder coat
paint. The source assumes 3% of the powder will reach the two cyclones and the cyclone control
efficiency of 80%. The third powder coat booth has a filter and vents to the inside of the building. It
is assumed that no particulate emissions from this booth.

VOC and HAP emission from the paint booths are based on the mass balance method using the
volumes of various paints, density, and VOC/HAP % by weight. Particulate emissions are based on
the total solid weight, 70% overspray, and filter control efficiency of 99.4%. VOC and HAP
emissions from the partially enclosed paint area are calculated using mass balance method and
assuming a 50% particulate fallout from the exhaust.

Emission from natural gas combustion devices are based on annual natural gas usage of 7.62 MMscf
multiplied with emission factors from AP-42 Section 1.4-2.

[Last updated August 17, 2023]

2. Comment regarding Natural gas equipment ratings, the cyclone pressure drop, and the
proposed new building for abrasive blasting operations:
The natural gas equipment including four (4) powder coating ovens and one (1) burn-off oven. Total
natural gas consumption is only 7.62 MMscf per year. The equipment is old and the capacities are
unknown. Based on the total natural gas consumption, the combined rating for all equipment is
approximately 3 MMBtu/hr. Each individual rating would be probably less than 1 MMBtu/hr.

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 13
Requirements for the natural gas combustion equipment include an opacity limit and a natural gas
consumption limit. No other control technologies are required.

About 97% of the solids from the powder coating operations will fall out and only 3% of the
materials will be vented to the cyclone. Total emissions from the cyclone is only 0.12 tpy. As long
as the cyclone withdraws air from the intermittent operations, pressure drop through the cyclone is of
less concern. Therefore, a pressure drop condition is unnecessary.

Although most of the equipment is existing, the source has proposed to build an enclosed space for
part of the abrasive blasting operations. Because the building is considered as a control device,
Condition I.8 is included in the General Provisions. [Last updated August 18, 2023]

3. Comment regarding Federal standard and Title V applicability:
The source is not subject to any federal standards including NSPS, NESHAP, and/or MACT.

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, is not a Title IV source, and is not subject to any federal
standards. Therefore, this source is not subject to Title V requirements. [Last updated August 18,
2023]

Engineer Review N161280001: Steel Coatings Inc.- Salt Lake Metal Parts Coating Facility
June 6, 2024
Page 14
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by 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

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

DAQE-MN161280001-24

M E M O R A N D U M

TO: Enqiang He, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler

DATE: April 30, 2024

SUBJECT: Modeling Analysis Review for the Notice of Intent for Steel Coatings Inc – Salt Lake
Metal Parts Coating Facility, Salt Lake County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Steel Coatings Inc. (Applicant) is seeking an approval order for their Salt Lake Metal Par ts Coating
Facility located in Salt Lake County, Utah. The applicant seeks an Approval Order for a vapor
degreaser, abrasive blasting operations, paint booths, powder coating booths, and natural gas fired
ovens and space heating equipment. The powder coating booth emissions will be controlled by a
cyclone.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-5 Documentation of Ambient Air Impacts for Hazardous Air Pollutants

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

+.
JK
DAQE- MN121680001-24
Page 2
III. MODELING METHODOLOGY

A. Applicability

Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a
new approval order. The emission rates for n-propyl bromide (nPB) triggered the requirement
to model under R307-410. Modeling was performed by the Applicant.

B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4233 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12

b. Approximate Location:

UTM (NAD83): 419144 meters East
4512554 meters North

2. Urban or Rural Area Designation

After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is
“rural” for air modeling purposes.

3. Ambient Air

It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash

The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Salt Lake Airport, UT NWS: 2016-2020
Upper Air – Salt Lake Airport, UT NWS: 2016-2020

6. Background

No background concentrations were included in this HAP modeling analysis.

DAQE- MN121680001-24
Page 3
7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.

8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Source
UTM Coordinates Modeled Emission Rates
Easting Northin
g nPB
(m) (m) (lb/hr) (tons/yr) hrs/year
VPRDGSR 419146 4512580 3.19 3.49 2190

Total 3.19 3.49

10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Tem
p Flow Dia Sigma
-Y
Sigma
-Z
X-
Dim
Y-
Dim Area
(ft) (m) (ft) (K) (m/s) (ft) (m) (m) (m) (m) (m^2)
VPRDGSR POINT 4228.9 14.6 48.0 0
10.7
1 0.51 0.00 1

IV. RESULTS AND CONCLUSIONS

A. Toxic Screening Levels

The model predicted all HAP concentrations to be less than their respective UDAQ - Toxic
Screening Levels (TSL) for each scenario. Based on these results, no further analysis is
required.

DAQE- MN121680001-24
Page 4
Pollutant Period
Predictio
n TSL Percen
t
(μg/m3) (μg/m3)
nPB 24-
Hour 14.3 17 84.1%

V. PERMIT CONDITIONS

The following suggested permit language should be included under the Terms and Conditions in the
AO:

● The owner/operator shall limit n-Propyl Bromide-emitting vapor degreaser operations to
between the hours of 9:00 am and 3:00 pm.
● The release height of the vapor degreaser’s stack shall measure no less than 48 feet above
ground level.

JK:jg

Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Vapor
Degreaser
Abrasive
Blasting
(outdoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 5.900 12.995 0.020 18.915 63.729
SOx (SO2)0.002 0.002 0.007
NOx 0.362 0.362 1.219
PM10 (tot)6.075 0.117 0.068 0.028 6.288 21.185 14.897
PM2.5 (tot)0.608 0.117 0.068 0.028 0.820 2.764
CO 0.304 0.304 1.024
HAPS lbs/year Modeling?
Xylene 1.698 1.698 5.719 3395.13585 1.305821 y
Ethylbenzene 0.380 0.380 1.282 760.978725 0.292684 y
Toluene 0.263 0.263 0.888 526.831425 0.202627 n
Methyl Isobutyl Ketone 0.468 0.468 1.578 936.5892 0.360227 n
Methanol 0.073 0.073 0.247 146.3420625 0.056285 n
Naphthalene 0.009 0.009 0.030 17.5610475 0.006754 n
Cumene 0.015 0.015 0.049 29.2684125 0.011257
All Other HAPS 0.088 0.088 0.296 175.610475 0.067542 n
n-propyl bromide 5.664 5.664 19.083 11328 4.356923 y
1,2 butylene oxide 0.059 0.059 0.199 118 0.045385
Total HAPs 8.717 29.370 17,434.317 8.717159
Greenhouse Gases
N2O 0.008 0.00796 0.027
N2O (CO2 Eqiv)(x 298)2.373 2.37294
Methane 0.010 0.00992 0.033
Methane (CO2 Eqiv)(x25)0.248 0.24794
CO2 379.139 379.139 1,277.407
CO2 (CO2 Eqiv)(x 1)379.14 379.139
February 6, 2023
Annual Emissions (tons)
Existing
Appendix A
Vapor Degreasing
Steel Coatings
Plastic Pipe Assembly

(lbs)

by weight (lbs)

by weight (lbs)
GENTECH Degreaser Solvent Purchased 14,000
Amount shipped as waste 2,200
Amount emitted 11,800 96 11,328 1 118
TOTAL (pounds):11,328 118
TOTAL (tons):5.664 0.059
Note: All VOC is assumed emitted.
= Data Input
= Output to "Plant-Wide" work

106-94-5 (HAP)

106-88-7 (HAP)

by weight (lbs)

by weight (lbs)
3 354 100 11,800
354 11,800
0.177 5.900
ksheet

VOCs Total VOC Emissions
Appendix B
Emissions from Outdoor Abrasive Blasting
Steel Coatings
= Data Input
= Output to "Plant-Wide" worksheet
PM101 PM2.52 PM101 PM2.52
Blast Media Throughput (Annual)(1,000 lbs)150,000 150,000 600,000 600,000
Emission Factors (lbs PM/lb abrasive)1,2 0.041 0.0041 0.01 0.001
PM Emissions (lbs)6,150 615 6,000 600
PM Emissions (tons)3.08 0.31 3.00 0.30
1 From "Emission Factor Documentation for AP-42, Section 13.2.6, Table 4.2"
2 PM10 to PM2.5 ratio is from "AP-42 13.2.6 Abrasive Blasting, Table 13.2.6-1"
Emissions
Sand Grit
Calculation for BACT Determination
Steel Coatings
Abrasive Blasting
Silica
Sand
Mineral
Abrasive
Silica
Sand
Total abrasive used per year 750,000
Percent per abrasive material 100%80%20%
Abrasive used (pounds)750,000 600,000 150,000
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041
PM10 Emitted (pounds)30,750 6,000 6,150
PM10 Emitted (tons)15.38 3.00 3.08
Total PM10 Emitted (tons)15.38 6.08
Difference (tons)9.30
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, or equivalent.
Calculation for BACT
Abrasive Material
Appendix C
Emissions from Powder Coat (dry) Paint Process
Steel Coatings = Data Input
= Output to "Plant-Wi
Annual Use
to Cyclone

Cyclone

Separator
Percent

(lbs)(%)(lbs)(%)
Total Powder Coat Paint (various colors)65,000
Powder Coat Booth #1 30 19,500 3 585 80
Powder Coat Booth #2 30 19,500 3 585 80
Powder Coat Booth #3 (100% recirculated)40 26,000 0 NA NA
Total (lbs):
Tons:
1 All calculations are based on process observation and best engineering estimates
Most powder overspray falls to the floor and is swept up for reuse or discarded.
2 All emissions are assumed to be PM2.5.
PM Emission Calculations
ide" worksheet

Emissions2
(lbs)
117
117 0.0585
0
234
0.117
s1
Appendix D
Emissions from Wet (solvent) Paint Process
Steel Coatings = Data Input
(Emissions per 2,080 hrs/year)= Output to "Plant-Wide" worksheet
VOC Solids HAPs
Usage
Density
(Average)Usage
VOC
(Average)
VOC
Emissions Solids Solids
Product Name (gallons)(lbs/gal)(pounds)% by weight (lbs)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds
150+ Paints and Thinners 5,650.0 10.36 58,537 44.40 25,990 55.60 32,546 5.80 3,395 1.30 761 0.90 527 1.60 937 0.25 146 0.03 18 0.05 29 0.30 176
(See "SC Paint Use List" for details)0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
Total (pounds):58,537 25,990 32,546 3,395 761 527 937 146 18 29 176
Total (tons):29.268 12.995 16.273 1.698 0.380 0.263 0.468 0.073 0.009 0.015 0.088
Percent
Paint Booth #1 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Booth #2 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Area #3 20 5,198 679 152 105 187 29 4 6 35
2.599 0.340 0.076 0.053 0.094 0.015 0.002 0.003 0.018
Total
Indoors
Booth 1
Indoors
Booth 2
Outdoors
Area #3 Total
Solids Sprayed (percent)100 40 40 20
Solids Sprayed (tons)16.273 6.509 6.509 3.255
Overspray (%)70 70 70
Overspray (tons)4.557 4.557 2.278
Captured by Filter (Filter Effic %)99.4 99.4 99.4
Captured by Filter (tons)4.529 4.529 2.265
PM Emissions (tons)0.027 0.027 0.014 0.068
Methanol
67-56-1
Napthalene
91-20-3
Cumene
98-82-8 All Other HAPS
Xylene (o, m,& p)
1330-20-7
PM Emission Calculations
Ethylbenzene
100-41-4
Toluene
108-88-3
Methyl Isobutyl
Ketone
108-10-1
Appendix EEmissions from Combustion of Natural GasBased on fuel use records and 2,600 hrs/yr = Data InputSteel Coatings = Output to "Plant-Wide" worksheet
Gas Consumed Plant-wide (MMscf)7.62
Emission Unit # and Name:Heating
Powder Coat
Ovens
Paint Hook
Burn-Off
Oven Total
Percent of plant-wide gas use:10.0%85.0%5.0%100.0%
Gas Consumed (MMscf)0.76 6.48 0.38 7.24
Emission Factor lbs/hr tons/8769
(lbs/MMscf)(tons/yr)(tons/yr)(tons/yr)(tons/yr)
Lead 0.0005 0.000 0.000 0.000 0.000 0.000 0.000
VOC 5.5 0.002 0.018 0.001 0.020 0.043 0.060
SOx 0.6 0.000 0.002 0.000 0.002 0.005 0.007
NOx (Standard NOx Burners)100 0.038 0.324 0.019 0.362 0.778 1.091
PM10 (total)7.6 0.003 0.025 0.001 0.028 0.059 0.083
PM2.5 (total)7.6 0.003 0.025 0.001 0.028 0.059 0.083
PM2.5 (condensable)5.7 0.002 0.018 0.001 0.021 0.044 0.062
PM2.5 (filterable)1.9 0.001 0.006 0.000 0.007 0.015 0.021
CO 84 0.032 0.272 0.016 0.304 0.654 0.916
N2O (greenhouse)2.2 0.001 0.007 0.000 0.008 0.017 0.024
Methane (greenhouse)2.74 0.001 0.009 0.001 0.010 0.021 0.030
CO2 (greenhouse)104,749 39.909 339.230 19.955 379.139 815.456 1,142.865
1 From AP-42 1.4-2 External Combustion Sources, Natural Gas Combustion
Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Annual Emissions (tons)
Existing
Vapor
Degreaser
Abrasive
Blasting
(Outdoor)
Abrasive
Blasting
(Indoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 4.320 12.995 0.020 17.335 58.406
SOx (SO2)0.002 0.002 0.007
NOx 0.362 0.362 1.219
PM10 (tot)3.038 0.009 1.194 0.028 4.268 14.381
PM2.5 (tot)0.304 0.001 0.117 0.028 0.449 1.513
CO 0.304 0.304 1.024
HAPS
Xylene 1.698 1.698 5.719
Ethylbenzene 0.380 0.380 1.282
Toluene 0.263 0.263 0.888
Methyl Isobutyl Ketone 0.468 0.468 1.578
Methanol 0.073 0.073 0.247
Naphthalene 0.009 0.009 0.030
Cumene 0.015 0.015 0.049
All Other HAPS 0.088 0.088 0.296
n-propyl bromide 4.147 4.147 13.973
1,2 butylene oxide 0.043 0.043 0.146
Total HAPs 7.185 24.206
Greenhouse Gases
N2O 0.008 0.00796 0.027
N2O (CO2 Eqiv)(x 298)2.373 2.37294
Methane 0.010 0.00992 0.033
Methane (CO2 Eqiv)(x25)0.248 0.24794
CO2 379.139 379.139 1,277.407
CO2 (CO2 Eqiv)(x 1)379.14 379.139
November 6, 2023
Appendix A
Vapor Degreasing
Steel Coatings
n-Propyl Bromide
106-94-5 (HAP)

Plastic Pipe Assembly
Annual Use
(lbs)
Percent
by weight
Emissions
(lbs)
GENTECH Degreaser Solvent Purchased 10,800
Amount shipped as waste 2,160
Amount emitted 8,640 96 8,294
TOTAL (pounds):8,294
TOTAL (tons):4.147
Note: All VOC is assumed emitted.
= Data Inp
= Output t
Appendix B
Emissions from Abrasive Blasting
Steel Coatings
Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material
Abrasive Blasting
Grit (Mineral
Abrasive)
Silica
Sand Total
Grit (Mineral
Abrasive)
Total abrasive used per year 300,000 75,000 375,000 375,000
Percent per abrasive material 80%20%100%100%
PM10 Emission Factor** (lbs/1,000 lb)0.010 0.041 0.010
PM10 Emitted (pounds)3,000 3,075 3,750
PM10 Emitted (tons)1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)1.87
PM10 Emitted after controls (tons)1.50 1.54 3.04 0.01
PM2.5 Emission Factor** (lbs/1,000 lb)0.001 0.0041 0.0041 0.001
PM2.5 Emitted (pounds)300 308 1,538 375
PM2.5 Emitted (tons)0.15 0.15 0.19
Controlled by Dust Collector (99.5%)(tons)- - 0.19
PM2.5 Emitted after controls (tons)0.15 0.15 0.30 0.001
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Calculation for BACT Determination
Steel Coatings
Calculations for BACT Scenarios:Baseline Control Alternative 2 Control Alternative 1
Outdoor Only Outdoor Only Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material Abrasive Material
Abrasive Blasting
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Total abrasive used per year 750,000 600,000 150,000 300,000 75,000 375,000
Percent per abrasive material 100%80%20%80%20%100%
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041 0.010 0.041 0.010
PM10 Emitted (pounds)30,750 6,000 6,150 3,000 3,075 3,750
PM10 Emitted (tons)15.38 3.00 3.08 1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)- - 1.87
PM10 Emitted after controls (tons)3.00 3.08 1.50 1.54 0.01
Total PM10 Emitted (tons)15.38 6.08 3.05
Difference (tons less than baseline)9.30 12.33
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Appendix C
Emissions from Powder Coat (dry) Paint Process
Steel Coatings
Annual Use
Percent
Annual Use
(lbs)
Total Powder Coat Paint (various colors)65,000
Powder Coat Booth #1 30 19,500
Powder Coat Booth #2 30 19,500
Powder Coat Booth #3 (100% recirculated)40 26,000
1 All calculations are based on process observation and best engineering es
Most powder overspray falls to the floor and is swept up for reuse or disc
2 All emissions are assumed to be PM2.5.
Appendix D
Emissions from Wet (solvent) Paint Process
Steel Coatings = Data Input
(Emissions per 2,600 hrs/year)= Output to "Plant-Wide" worksheet
VOC Solids HAPs
Usage
Density
(Average)Usage
VOC
(Average)
VOC
Emissions Solids Solids
Xylene (o, m,& p)
1330-20-7
Ethylbenzene
100-41-4
Toluene
108-88-3
Methyl Isobutyl
Ketone
108-10-1
Methanol
67-56-1
Napthalene
91-20-3
Cumene
98-82-8 All Other HAPS
Product Name (gallons)(lbs/gal)(pounds)% by weight (lbs)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds
150+ Paints and Thinners 5,650.0 10.36 58,537 44.40 25,990 55.60 32,546 5.80 3,395 1.30 761 0.90 527 1.60 937 0.25 146 0.03 18 0.05 29 0.30 176
(See "SC Paint Use List" for details)0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
Total (pounds):58,537 25,990 32,546 3,395 761 527 937 146 18 29 176
Total (tons):29.268 12.995 16.273 1.698 0.380 0.263 0.468 0.073 0.009 0.015 0.088
Percent
Paint Booth #1 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Booth #2 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Area #3 20 5,198 679 152 105 187 29 4 6 35
2.599 0.340 0.076 0.053 0.094 0.015 0.002 0.003 0.018
PM Emission Calculations
Total
Indoors
Booth 1
Stack 03
Indoors
Booth 2
No Stack
Outdoors
Area #3
No Stack Total
Solids Sprayed (percent):100 40 40 20
Solids Sprayed (tons):16.273 6.509 6.509 3.255
Overspray (%):70 70 70
Overspray (tons):4.557 4.557 2.278
Fallout (%):50 Note: Although no fallout factor for a partial enclosure were located, PM fallout is well recognized and 50% in
Fallout (tons):1.139 an enclosure like the one at Steel Coatings is a conservative estimate.
Captured by Filter (Filter Effic %):99.4 99.4 0
Captured by Filter (tons):4.529 4.529 0
PM Emissions (tons):0.027 0.027 1.139 1.194
Appendix E
Emissions from Combustion of Natural Gas
Based on fuel use records and 2,600 hrs/yr
Steel Coatings
Gas Consumed Plant-wide (MMscf)7.62
Emission Unit # and Name:Heating
Percent of plant-wide gas use:10.0%
Gas Consumed (MMscf)0.76
Emission Factor
(From AP-42)1
(lbs/MMscf)(tons/yr)
Lead 0.0005 0.000
VOC 5.5 0.002
SOx 0.6 0.000
NOx (Standard NOx Burners)100 0.038
PM10 (total)7.6 0.003
PM2.5 (total)7.6 0.003
PM2.5 (condensable)5.7 0.002
PM2.5 (filterable)1.9 0.001
CO 84 0.032
N2O (greenhouse)2.2 0.001
Methane (greenhouse)2.74 0.001
CO2 (greenhouse)104,749 39.909
1 From AP-42 1.4-2 External Combustion Sources, Natural Gas Combust
Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Annual Emissions (tons)
Existing
Vapor
Degreaser
Abrasive
Blasting
(Outdoor)
Abrasive
Blasting
(Indoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 5.900 12.995 0.020 18.915 63.729
SOx (SO2)0.002 0.002 0.007
NOx 0.362 0.362 1.219
PM10 (tot)3.038 0.009 1.194 0.028 4.268 14.381
PM2.5 (tot)0.304 0.001 0.117 0.028 0.449 1.513
CO 0.304 0.304 1.024
HAPS
Xylene 1.698 1.698 5.719
Ethylbenzene 0.380 0.380 1.282
Toluene 0.263 0.263 0.888
Methyl Isobutyl Ketone 0.468 0.468 1.578
Methanol 0.073 0.073 0.247
Naphthalene 0.009 0.009 0.030
Cumene 0.015 0.015 0.049
All Other HAPS 0.088 0.088 0.296
n-propyl bromide 5.664 5.664 19.083
1,2 butylene oxide 0.059 0.059 0.199
Total HAPs 8.717 29.370
Greenhouse Gases
N2O 0.008 0.00796 0.027
N2O (CO2 Eqiv)(x 298)2.373 2.37294
Methane 0.010 0.00992 0.033
Methane (CO2 Eqiv)(x25)0.248 0.24794
CO2 379.139 379.139 1,277.407
CO2 (CO2 Eqiv)(x 1)379.14 379.139
August 15, 2023
Appendix A
Vapor Degreasing
Steel Coatings
n-Propyl Bromide
106-94-5 (HAP)

Plastic Pipe Assembly
Annual Use
(lbs)
Percent
by weight
Emissions
(lbs)
GENTECH Degreaser Solvent Purchased 14,000
Amount shipped as waste 2,200
Amount emitted 11,800 96 11,328
TOTAL (pounds):11,328
TOTAL (tons):5.664
Note: All VOC is assumed emitted.
= Data Inp
= Output t
Appendix B
Emissions from Abrasive Blasting
Steel Coatings
Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material
Abrasive Blasting
Grit (Mineral
Abrasive)
Silica
Sand Total
Grit (Mineral
Abrasive)
Total abrasive used per year 300,000 75,000 375,000 375,000
Percent per abrasive material 80%20%100%100%
PM10 Emission Factor** (lbs/1,000 lb)0.010 0.041 0.010
PM10 Emitted (pounds)3,000 3,075 3,750
PM10 Emitted (tons)1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)1.87
PM10 Emitted after controls (tons)1.50 1.54 3.04 0.01
PM2.5 Emission Factor** (lbs/1,000 lb)0.001 0.0041 0.0041 0.001
PM2.5 Emitted (pounds)300 308 1,538 375
PM2.5 Emitted (tons)0.15 0.15 0.19
Controlled by Dust Collector (99.5%)(tons)- - 0.19
PM2.5 Emitted after controls (tons)0.15 0.15 0.30 0.001
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Calculation for BACT Determination
Steel Coatings
Calculations for BACT Scenarios:Baseline Control Alternative 2 Control Alternative 1
Outdoor Only Outdoor Only Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material Abrasive Material
Abrasive Blasting
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Total abrasive used per year 750,000 600,000 150,000 300,000 75,000 375,000
Percent per abrasive material 100%80%20%80%20%100%
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041 0.010 0.041 0.010
PM10 Emitted (pounds)30,750 6,000 6,150 3,000 3,075 3,750
PM10 Emitted (tons)15.38 3.00 3.08 1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)- - 1.87
PM10 Emitted after controls (tons)3.00 3.08 1.50 1.54 0.01
Total PM10 Emitted (tons)15.38 6.08 3.05
Difference (tons less than baseline)9.30 12.33
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Appendix C
Emissions from Powder Coat (dry) Paint Process
Steel Coatings
Annual Use
Percent
Annual Use
(lbs)
Total Powder Coat Paint (various colors)65,000
Powder Coat Booth #1 30 19,500
Powder Coat Booth #2 30 19,500
Powder Coat Booth #3 (100% recirculated)40 26,000
1 All calculations are based on process observation and best engineering es
Most powder overspray falls to the floor and is swept up for reuse or disc
2 All emissions are assumed to be PM2.5.
Appendix D
Emissions from Wet (solvent) Paint Process
Steel Coatings = Data Input
(Emissions per 2,600 hrs/year)= Output to "Plant-Wide" worksheet
VOC Solids HAPs
Usage
Density
(Average)Usage
VOC
(Average)
VOC
Emissions Solids Solids
Xylene (o, m,& p)
1330-20-7
Ethylbenzene
100-41-4
Toluene
108-88-3
Methyl Isobutyl
Ketone
108-10-1
Methanol
67-56-1
Napthalene
91-20-3
Cumene
98-82-8 All Other HAPS
Product Name (gallons)(lbs/gal)(pounds)% by weight (lbs)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds
150+ Paints and Thinners 5,650.0 10.36 58,537 44.40 25,990 55.60 32,546 5.80 3,395 1.30 761 0.90 527 1.60 937 0.25 146 0.03 18 0.05 29 0.30 176
(See "SC Paint Use List" for details)0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
Total (pounds):58,537 25,990 32,546 3,395 761 527 937 146 18 29 176
Total (tons):29.268 12.995 16.273 1.698 0.380 0.263 0.468 0.073 0.009 0.015 0.088
Percent
Paint Booth #1 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Booth #2 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Area #3 20 5,198 679 152 105 187 29 4 6 35
2.599 0.340 0.076 0.053 0.094 0.015 0.002 0.003 0.018
PM Emission Calculations
Total
Indoors
Booth 1
Stack 03
Indoors
Booth 2
No Stack
Outdoors
Area #3
No Stack Total
Solids Sprayed (percent):100 40 40 20
Solids Sprayed (tons):16.273 6.509 6.509 3.255
Overspray (%):70 70 70
Overspray (tons):4.557 4.557 2.278
Fallout (%):50 Note: Although no fallout factor for a partial enclosure were located, PM fallout is well recognized and 50% in
Fallout (tons):1.139 an enclosure like the one at Steel Coatings is a conservative estimate.
Captured by Filter (Filter Effic %):99.4 99.4 0
Captured by Filter (tons):4.529 4.529 0
PM Emissions (tons):0.027 0.027 1.139 1.194
Appendix E
Emissions from Combustion of Natural Gas
Based on fuel use records and 2,600 hrs/yr
Steel Coatings
Gas Consumed Plant-wide (MMscf)7.62
Emission Unit # and Name:Heating
Percent of plant-wide gas use:10.0%
Gas Consumed (MMscf)0.76
Emission Factor
(From AP-42)1
(lbs/MMscf)(tons/yr)
Lead 0.0005 0.000
VOC 5.5 0.002
SOx 0.6 0.000
NOx (Standard NOx Burners)100 0.038
PM10 (total)7.6 0.003
PM2.5 (total)7.6 0.003
PM2.5 (condensable)5.7 0.002
PM2.5 (filterable)1.9 0.001
CO 84 0.032
N2O (greenhouse)2.2 0.001
Methane (greenhouse)2.74 0.001
CO2 (greenhouse)104,749 39.909
1 From AP-42 1.4-2 External Combustion Sources, Natural Gas Combust
Verified emissions
Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Annual Emissions (tons)
Existing
Vapor
Degreaser
Abrasive
Blasting
(Outdoor)
Abrasive
Blasting
(Indoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 5.900 12.995 0.021 18.916 63.733
SOx (SO2)0.002 0.002 0.008
NOx 0.381 0.381 1.284
PM10 (tot)3.038 0.009 0.117 1.194 0.029 4.387 14.780
PM2.5 (tot)0.304 0.001 0.117 1.194 0.029 1.645 5.541
CO 0.320 0.320 1.078
HAPS
Xylene 1.698 1.698 5.719
Ethylbenzene 0.380 0.380 1.282
Toluene 0.263 0.263 0.888
Methyl Isobutyl Ketone 0.468 0.468 1.578
Methanol 0.073 0.073 0.247
Naphthalene 0.009 0.009 0.030
Cumene 0.015 0.015 0.049
All Other HAPS 0.088 0.088 0.296
n-propyl bromide 5.664 5.664 19.083
1,2 butylene oxide 0.059 0.059 0.199
Total HAPs 8.717 29.370
Greenhouse Gases
N2O 0.008 0.00838 0.028
N2O (CO2 Eqiv)(x 298)2.498 2.49784
Methane 0.010 0.01044 0.035
Methane (CO2 Eqiv)(x25)0.261 0.26099
CO2 399.094 399.094 1,344.639
CO2 (CO2 Eqiv)(x 1)399.09 399.094
August 15, 2023
Appendix A
Vapor Degreasing
Steel Coatings
n-Propyl Bromide
106-94-5 (HAP)

Plastic Pipe Assembly
Annual Use
(lbs)
Percent
by weight
Emissions
(lbs)
GENTECH Degreaser Solvent Purchased 14,000
Amount shipped as waste 2,200
Amount emitted 11,800 96 11,328
TOTAL (pounds):11,328
TOTAL (tons):5.664
Note: All VOC is assumed emitted.
= Data Inp
= Output t
Appendix B
Emissions from Abrasive Blasting
Steel Coatings
Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material
Abrasive Blasting
Grit (Mineral
Abrasive)
Silica
Sand Total
Grit (Mineral
Abrasive)
Total abrasive used per year 300,000 75,000 375,000 375,000
Percent per abrasive material 80%20%100%100%
PM10 Emission Factor** (lbs/1,000 lb)0.010 0.041 0.010
PM10 Emitted (pounds)3,000 3,075 3,750
PM10 Emitted (tons)1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)1.87
PM10 Emitted after controls (tons)1.50 1.54 3.04 0.01
PM2.5 Emission Factor** (lbs/1,000 lb)0.001 0.0041 0.0041 0.001
PM2.5 Emitted (pounds)300 308 1,538 375
PM2.5 Emitted (tons)0.15 0.15 0.19
Controlled by Dust Collector (99.5%)(tons)- - 0.19
PM2.5 Emitted after controls (tons)0.15 0.15 0.30 0.001
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Calculation for BACT Determination
Steel Coatings
Calculations for BACT Scenarios:Baseline Control Alternative 2 Control Alternative 1
Outdoor Only Outdoor Only Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material Abrasive Material
Abrasive Blasting
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Total abrasive used per year 750,000 600,000 150,000 300,000 75,000 375,000
Percent per abrasive material 100%80%20%80%20%100%
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041 0.010 0.041 0.010
PM10 Emitted (pounds)30,750 6,000 6,150 3,000 3,075 3,750
PM10 Emitted (tons)15.38 3.00 3.08 1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)- - 1.87
PM10 Emitted after controls (tons)3.00 3.08 1.50 1.54 0.01
Total PM10 Emitted (tons)15.38 6.08 3.05
Difference (tons less than baseline)9.30 12.33
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Appendix C
Emissions from Powder Coat (dry) Paint Process
Steel Coatings
Annual Use
Percent
Annual Use
(lbs)
Total Powder Coat Paint (various colors)65,000
Powder Coat Booth #1 30 19,500
Powder Coat Booth #2 30 19,500
Powder Coat Booth #3 (100% recirculated)40 26,000
1 All calculations are based on process observation and best engineering es
Most powder overspray falls to the floor and is swept up for reuse or disc
2 All emissions are assumed to be PM2.5.
Appendix D
Emissions from Wet (solvent) Paint Process
Steel Coatings = Data Input
(Emissions per 2,600 hrs/year)= Output to "Plant-Wide" worksheet
VOC Solids HAPs
Usage
Density
(Average)Usage
VOC
(Average)
VOC
Emissions Solids Solids
Xylene (o, m,& p)
1330-20-7
Ethylbenzene
100-41-4
Toluene
108-88-3
Methyl Isobutyl
Ketone
108-10-1
Methanol
67-56-1
Napthalene
91-20-3
Cumene
98-82-8 All Other HAPS
Product Name (gallons)(lbs/gal)(pounds)% by weight (lbs)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds
150+ Paints and Thinners 5,650.0 10.36 58,537 44.40 25,990 55.60 32,546 5.80 3,395 1.30 761 0.90 527 1.60 937 0.25 146 0.03 18 0.05 29 0.30 176
(See "SC Paint Use List" for details)0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
Total (pounds):58,537 25,990 32,546 3,395 761 527 937 146 18 29 176
Total (tons):29.268 12.995 16.273 1.698 0.380 0.263 0.468 0.073 0.009 0.015 0.088
Percent
Paint Booth #1 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Booth #2 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Area #3 20 5,198 679 152 105 187 29 4 6 35
2.599 0.340 0.076 0.053 0.094 0.015 0.002 0.003 0.018
PM Emission Calculations
Total
Indoors
Booth 1
Stack 03
Indoors
Booth 2
No Stack
Outdoors
Area #3
No Stack Total
Solids Sprayed (percent):100 40 40 20
Solids Sprayed (tons):16.273 6.509 6.509 3.255
Overspray (%):70 70 70
Overspray (tons):4.557 4.557 2.278
Fallout (%):50 Note: Although no fallout factor for a partial enclosure were located, PM fallout is well recognized and 50% in
Fallout (tons):1.139 an enclosure like the one at Steel Coatings is a conservative estimate.
Captured by Filter (Filter Effic %):99.4 99.4 0
Captured by Filter (tons):4.529 4.529 0
PM Emissions (tons):0.027 0.027 1.139 1.194
Appendix E
Emissions from Combustion of Natural Gas
Based on fuel use records and 2,600 hrs/yr
Steel Coatings
Gas Consumed Plant-wide (MMscf)7.62
Emission Unit # and Name:Heating
Percent of plant-wide gas use:10.0%
Gas Consumed (MMscf)0.76
Emission Factor
(From AP-42)1
(lbs/MMscf)(tons/yr)
Lead 0.0005 0.000
VOC 5.5 0.002
SOx 0.6 0.000
NOx (Standard NOx Burners)100 0.038
PM10 (total)7.6 0.003
PM2.5 (total)7.6 0.003
PM2.5 (condensable)5.7 0.002
PM2.5 (filterable)1.9 0.001
CO 84 0.032
N2O (greenhouse)2.2 0.001
Methane (greenhouse)2.74 0.001
CO2 (greenhouse)104,749 39.909
1 From AP-42 1.4-2 External Combustion Sources, Natural Gas Combust
Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Annual Emissions (tons)
Existing
Vapor
Degreaser
Abrasive
Blasting
(Outdoor)
Abrasive
Blasting
(Indoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 5.900 12.995 0.020 18.915 63.729
SOx (SO2)0.002 0.002 0.007
NOx 0.362 0.362 1.219
PM10 (tot)3.038 0.009 2.333 0.028 5.407 18.218
PM2.5 (tot)0.304 0.001 0.117 0.028 0.449 1.513
CO 0.304 0.304 1.024
HAPS
Xylene 1.698 1.698 5.719
Ethylbenzene 0.380 0.380 1.282
Toluene 0.263 0.263 0.888
Methyl Isobutyl Ketone 0.468 0.468 1.578
Methanol 0.073 0.073 0.247
Naphthalene 0.009 0.009 0.030
Cumene 0.015 0.015 0.049
All Other HAPS 0.088 0.088 0.296
n-propyl bromide 5.664 5.664 19.083
1,2 butylene oxide 0.059 0.059 0.199
Total HAPs 8.717 29.370
Greenhouse Gases
N2O 0.008 0.00796 0.027
N2O (CO2 Eqiv)(x 298)2.373 2.37294
Methane 0.010 0.00992 0.033
Methane (CO2 Eqiv)(x25)0.248 0.24794
CO2 379.139 379.139 1,277.407
CO2 (CO2 Eqiv)(x 1)379.14 379.139
August 7, 2023
Appendix A
Vapor Degreasing
Steel Coatings
n-Propyl Bromide
106-94-5 (HAP)

Plastic Pipe Assembly
Annual Use
(lbs)
Percent
by weight
Emissions
(lbs)
GENTECH Degreaser Solvent Purchased 14,000
Amount shipped as waste 2,200
Amount emitted 11,800 96 11,328
TOTAL (pounds):11,328
TOTAL (tons):5.664
Note: All VOC is assumed emitted.
= Data Inp
= Output t
Appendix B
Emissions from Abrasive Blasting
Steel Coatings
Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material
Abrasive Blasting
Grit (Mineral
Abrasive)
Silica
Sand Total
Grit (Mineral
Abrasive)
Total abrasive used per year 300,000 75,000 375,000 375,000
Percent per abrasive material 80%20%100%100%
PM10 Emission Factor** (lbs/1,000 lb)0.010 0.041 0.010
PM10 Emitted (pounds)3,000 3,075 3,750
PM10 Emitted (tons)1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)1.87
PM10 Emitted after controls (tons)1.50 1.54 3.04 0.01
PM2.5 Emission Factor** (lbs/1,000 lb)0.001 0.0041 0.0041 0.001
PM2.5 Emitted (pounds)300 308 1,538 375
PM2.5 Emitted (tons)0.15 0.15 0.19
Controlled by Dust Collector (99.5%)(tons)- - 0.19
PM2.5 Emitted after controls (tons)0.15 0.15 0.30 0.001
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Calculation for BACT Determination
Steel Coatings
Calculations for BACT Scenarios:Baseline Control Alternative 2 Control Alternative 1
Outdoor Only Outdoor Only Outdoor
Indoor
(with Blast Building)
Abrasive Material Abrasive Material Abrasive Material
Abrasive Blasting
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Silica
Sand
Grit (Mineral
Abrasive)
Total abrasive used per year 750,000 600,000 150,000 300,000 75,000 375,000
Percent per abrasive material 100%80%20%80%20%100%
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041 0.010 0.041 0.010
PM10 Emitted (pounds)30,750 6,000 6,150 3,000 3,075 3,750
PM10 Emitted (tons)15.38 3.00 3.08 1.50 1.54 1.88
Controlled by Dust Collector (99.5%)(tons)- - 1.87
PM10 Emitted after controls (tons)3.00 3.08 1.50 1.54 0.01
Total PM10 Emitted (tons)15.38 6.08 3.05
Difference (tons less than baseline)9.30 12.33
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Grit, Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, Garnet or equivalent.
Appendix C
Emissions from Powder Coat (dry) Paint Process
Steel Coatings
Annual Use
Percent
Annual Use
(lbs)
Total Powder Coat Paint (various colors)65,000
Powder Coat Booth #1 30 19,500
Powder Coat Booth #2 30 19,500
Powder Coat Booth #3 (100% recirculated)40 26,000
1 All calculations are based on process observation and best engineering es
Most powder overspray falls to the floor and is swept up for reuse or disc
2 All emissions are assumed to be PM2.5.
Appendix D
Emissions from Wet (solvent) Paint Process
Steel Coatings = Data Input
(Emissions per 2,600 hrs/year)= Output to "Plant-Wide" worksheet
VOC Solids HAPs
Usage
Density
(Average)Usage
VOC
(Average)
VOC
Emissions Solids Solids
Xylene (o, m,& p)
1330-20-7
Ethylbenzene
100-41-4
Toluene
108-88-3
Methyl Isobutyl
Ketone
108-10-1
Methanol
67-56-1
Napthalene
91-20-3
Cumene
98-82-8 All Other HAPS
Product Name (gallons)(lbs/gal)(pounds)% by weight (lbs)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds
150+ Paints and Thinners 5,650.0 10.36 58,537 44.40 25,990 55.60 32,546 5.80 3,395 1.30 761 0.90 527 1.60 937 0.25 146 0.03 18 0.05 29 0.30 176
(See "SC Paint Use List" for details)0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
Total (pounds):58,537 25,990 32,546 3,395 761 527 937 146 18 29 176
Total (tons):29.268 12.995 16.273 1.698 0.380 0.263 0.468 0.073 0.009 0.015 0.088
Percent
Paint Booth #1 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Booth #2 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Area #3 20 5,198 679 152 105 187 29 4 6 35
2.599 0.340 0.076 0.053 0.094 0.015 0.002 0.003 0.018
PM Emission Calculations
Total
Indoors
Booth 1
Stack 03
Indoors
Booth 2
No Stack
Outdoors
Area #3
No Stack Total
Solids Sprayed (percent)100 40 40 20
Solids Sprayed (tons)16.273 6.509 6.509 3.255
Overspray (%)70 70 70
Overspray (tons)4.557 4.557 2.278
Captured by Filter (Filter Effic %)99.4 99.4 0
Captured by Filter (tons)4.529 4.529 0
PM Emissions (tons)0.027 0.027 2.278 2.333
Appendix E
Emissions from Combustion of Natural Gas
Based on fuel use records and 2,600 hrs/yr
Steel Coatings
Gas Consumed Plant-wide (MMscf)7.62
Emission Unit # and Name:Heating
Percent of plant-wide gas use:10.0%
Gas Consumed (MMscf)0.76
Emission Factor
(From AP-42)1
(lbs/MMscf)(tons/yr)
Lead 0.0005 0.000
VOC 5.5 0.002
SOx 0.6 0.000
NOx (Standard NOx Burners)100 0.038
PM10 (total)7.6 0.003
PM2.5 (total)7.6 0.003
PM2.5 (condensable)5.7 0.002
PM2.5 (filterable)1.9 0.001
CO 84 0.032
N2O (greenhouse)2.2 0.001
Methane (greenhouse)2.74 0.001
CO2 (greenhouse)104,749 39.909
1 From AP-42 1.4-2 External Combustion Sources, Natural Gas Combust
Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Vapor
Degreaser
Abrasive
Blasting
(outdoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 5.900 12.995 0.020 18.915 63.729
SOx (SO2)0.002 0.002 0.007
NOx 0.362 0.362 1.219
PM10 (tot)6.075 0.117 0.014 0.028 6.233 21.001
PM2.5 (tot)0.608 0.117 2.278 0.028 3.030 10.209
CO 0.304 0.304 1.024
HAPS
Xylene 1.698 1.698 5.719
Ethylbenzene 0.380 0.380 1.282
Toluene 0.263 0.263 0.888
Methyl Isobutyl Ketone 0.468 0.468 1.578
Methanol 0.073 0.073 0.247
Naphthalene 0.009 0.009 0.030
Cumene 0.015 0.015 0.049
All Other HAPS 0.088 0.088 0.296
n-propyl bromide 5.664 5.664 19.083
1,2 butylene oxide 0.059 0.059 0.199
Total HAPs 8.717 29.370
Greenhouse Gases
N2O 0.008 0.00796 0.027
N2O (CO2 Eqiv)(x 298)2.373 2.37294
Methane 0.010 0.00992 0.033
Methane (CO2 Eqiv)(x25)0.248 0.24794
CO2 379.139 379.139 1,277.407
CO2 (CO2 Eqiv)(x 1)379.14 379.139
February 6, 2023
Annual Emissions (tons)
Existing
Appendix A
Vapor Degreasing
Steel Coatings
Plastic Pipe Assembly

(lbs)

by weight (lbs)

by weight (lbs)
GENTECH Degreaser Solvent Purchased 14,000
Amount shipped as waste 2,200
Amount emitted 11,800 96 11,328 1 118
TOTAL (pounds):11,328 118
TOTAL (tons):5.664 0.059
Note: All VOC is assumed emitted.
= Data Input
= Output to "Plant-Wide" work

106-94-5 (HAP)

106-88-7 (HAP)

by weight (lbs)

by weight (lbs)
3 354 100 11,800
354 11,800
0.177 5.900
ksheet

VOCs Total VOC Emissions
Appendix B
Emissions from Outdoor Abrasive Blasting
Steel Coatings
= Data Input
= Output to "Plant-Wide" worksheet
PM101 PM2.52 PM101 PM2.52
Blast Media Throughput (Annual)(1,000 lbs)150,000 150,000 600,000 600,000
Emission Factors (lbs PM/lb abrasive)1,2 0.041 0.0041 0.01 0.001
PM Emissions (lbs)6,150 615 6,000 600
PM Emissions (tons)3.08 0.31 3.00 0.30
1 From "Emission Factor Documentation for AP-42, Section 13.2.6, Table 4.2"
2 PM10 to PM2.5 ratio is from "AP-42 13.2.6 Abrasive Blasting, Table 13.2.6-1"
Emissions
Sand Grit
Calculation for BACT Determination
Steel Coatings
Abrasive Blasting
Silica
Sand
Mineral
Abrasive
Silica
Sand
Total abrasive used per year 750,000
Percent per abrasive material 100%80%20%
Abrasive used (pounds)750,000 600,000 150,000
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041
PM10 Emitted (pounds)30,750 6,000 6,150
PM10 Emitted (tons)15.38 3.00 3.08
Total PM10 Emitted (tons)15.38 6.08
Difference (tons)9.30
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, or equivalent.
Calculation for BACT
Abrasive Material
Appendix C
Emissions from Powder Coat (dry) Paint Process
Steel Coatings = Data Input
= Output to "Plant-Wi
Annual Use
to Cyclone

Cyclone

Separator
Percent

(lbs)(%)(lbs)(%)
Total Powder Coat Paint (various colors)65,000
Powder Coat Booth #1 30 19,500 3 585 80
Powder Coat Booth #2 30 19,500 3 585 80
Powder Coat Booth #3 (100% recirculated)40 26,000 0 NA NA
Total (lbs):
Tons:
1 All calculations are based on process observation and best engineering estimates
Most powder overspray falls to the floor and is swept up for reuse or discarded.
2 All emissions are assumed to be PM2.5.
PM Emission Calculations
ide" worksheet

Emissions2
(lbs)
117
117
0
234
0.117
s1
Appendix D
Emissions from Wet (solvent) Paint Process
Steel Coatings = Data Input
(Emissions per 2,080 hrs/year)= Output to "Plant-Wide" worksheet
VOC Solids HAPs
Usage
Density
(Average)Usage
VOC
(Average)
VOC
Emissions Solids Solids
Product Name (gallons)(lbs/gal)(pounds)% by weight (lbs)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds
150+ Paints and Thinners 5,650.0 10.36 58,537 44.40 25,990 55.60 32,546 5.80 3,395 1.30 761 0.90 527 1.60 937 0.25 146 0.03 18 0.05 29 0.30 176
(See "SC Paint Use List" for details)0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
Total (pounds):58,537 25,990 32,546 3,395 761 527 937 146 18 29 176
Total (tons):29.268 12.995 16.273 1.698 0.380 0.263 0.468 0.073 0.009 0.015 0.088
Percent
Paint Booth #1 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Booth #2 40 10,396 1,358 304 211 375 59 7 12 70
5.198 0.679 0.152 0.105 0.187 0.029 0.004 0.006 0.035
Paint Area #3 20 5,198 679 152 105 187 29 4 6 35
2.599 0.340 0.076 0.053 0.094 0.015 0.002 0.003 0.018
Total
Indoors
Booth 1
Indoors
Booth 2
Outdoors
Area #3 Total
Solids Sprayed (percent)100 40 40 20
Solids Sprayed (tons)16.273 6.509 6.509 3.255
Overspray (%)70 70 70
Overspray (tons)4.557 4.557 2.278
Captured by Filter (Filter Effic %)99.4 99.4 99.4
Captured by Filter (tons)4.529 4.529 2.265
PM Emissions (tons)0.027 0.027 0.014 0.068
Methanol
67-56-1
Napthalene
91-20-3
Cumene
98-82-8 All Other HAPS
Xylene (o, m,& p)
1330-20-7
PM Emission Calculations
Ethylbenzene
100-41-4
Toluene
108-88-3
Methyl Isobutyl
Ketone
108-10-1
Appendix EEmissions from Combustion of Natural GasBased on fuel use records and 2,600 hrs/yr = Data InputSteel Coatings = Output to "Plant-Wide" worksheet
Gas Consumed Plant-wide (MMscf)7.62
Emission Unit # and Name:Heating
Powder Coat
Ovens
Paint Hook
Burn-Off
Oven Total
Percent of plant-wide gas use:10.0%85.0%5.0%100.0%
Gas Consumed (MMscf)0.76 6.48 0.38 7.24
Emission Factor lbs/hr tons/8769
(lbs/MMscf)(tons/yr)(tons/yr)(tons/yr)(tons/yr)
Lead 0.0005 0.000 0.000 0.000 0.000 0.000 0.000
VOC 5.5 0.002 0.018 0.001 0.020 0.043 0.060
SOx 0.6 0.000 0.002 0.000 0.002 0.005 0.007
NOx (Standard NOx Burners)100 0.038 0.324 0.019 0.362 0.778 1.091
PM10 (total)7.6 0.003 0.025 0.001 0.028 0.059 0.083
PM2.5 (total)7.6 0.003 0.025 0.001 0.028 0.059 0.083
PM2.5 (condensable)5.7 0.002 0.018 0.001 0.021 0.044 0.062
PM2.5 (filterable)1.9 0.001 0.006 0.000 0.007 0.015 0.021
CO 84 0.032 0.272 0.016 0.304 0.654 0.916
N2O (greenhouse)2.2 0.001 0.007 0.000 0.008 0.017 0.024
Methane (greenhouse)2.74 0.001 0.009 0.001 0.010 0.021 0.030
CO2 (greenhouse)104,749 39.909 339.230 19.955 379.139 815.456 1,142.865
1 From AP-42 1.4-2 External Combustion Sources, Natural Gas Combustion
Sunset Rail - Nephi, Utah Monthly Emissions Summary
Steel Coatings, Salt Lake City, UT
Period Covered:
Month, Year
Usage Density
Product Name Product ID MSDS No.(gallons)(lbs/gallon)
Carboguard 890 Part A 002 11.70
Carboguard 890 Part B 002B 13.40
Carbothane 134 HG Part A 003 10.68
Carbothane 134 HG Part B/URETHANE 811 003B 9.35
Kem Kromik/Univer Metal Primer (VOC Comp.), B50WZ1 020 12.88
KEM BOND* HS High Solids Alkyd Universal B50WZ4 021 13.76
KEM BOND® HS High Solids Alkyd Universal B50AZ8 021B 13.65
Macropoxy 646 Part B Hardener B58V600 029B 9.66
Macropoxy 646(Part A), Safety Yellow B58Y600 029C 10.95
Macropoxy 646 Fast Cure Epoxy (Part A), Mill B58W610 029D 12.19
Hi-Solids Polyurethane Activator Part T B60V30 030 8.44
Hi-Solids Polyurethane Gloss Part S B65Y337 034 9.88
Zinc Clad II Plus Inorganic Zinc Rich Coating B69VZ12 038A 10.70
Zinc Clad II Plus part B Hardener - .05 B69VZ13 038B 7.75
Methyl Ethyl Ketone MEK-SW 044 6.68
Amershield Cure 055 9.43
Amerlock 2/400 Base 056 12.27
Amerlock 2 Cure 057 11.35
AMERCOAT 101 THINNER AT101 057A 7.43
Dimethcote 302H Green 302F 059 20.37
Sunset Rail - Nephi, Utah Monthly Emissions Summary
PSX 700 A CLEAR COAT RESIN 0.8 319294 061 9.35
PSX 700 CURE US 0.2 336130 061B 7.93
Carboguard 888 Part A - .50 062 12.53
Carboguard 888 Part B - .50 063 12.69
Acrolon 218 HS Acrylic Polyurethane (Part B), B65V600 075 9.41
Acrolon 218 HS Polyurethane - Gloss (Part A), B65W611 077 11.34
HEMPEL'S URETHANE 5595U 086 18.60
HEMPEL'S CURING AGENT 931US 086A 9.10
HEMPADUR ZINC 17369 087 26.70
HEMPEL'S CURING AGENT 97040 087A 8.30
HEMPADUR MASTIC 45889 088 13.10
HEMPEL'S CURING AGENT 088A 7.85
HEMPADUR FAST DRY 15569 089 13.10
HEMPEL'S CURING AGENT 97560 089A 7.85
INTERGARD BEIGE/PART A ECZ089 090 13.11
INTERGARD 740 PART B ECA914 090B 7.50
INTERGARD 740 RAL1023 TRAF YELL PTA ECB132 090C 10.77
INTERTHANE 870 YELLOW BASE - .88 870 090D 10.60
INTERTHANE 870/870UHS PART B - .12 870B 090E 8.50
ENDURA-SHIELD II 1075 091 12.16
ENDURA-SHIELD II CONVERTER 1074 091A 9.32
H-B EPOXOLINE WHITE Part A 0L69-00WHA 091C 14.63
H-B EPOXOLINE WHITE Part B 0L69-00WHA 091E 12.25
F65/66/160/161 CONVERTER B066 091D 10.68
Zinc Clad III HS Part A - .31 B69A100 092A 11.00
Zinc Clad III HS Part B - .31 B69V100 092B 7.83
Zinc Clad III HS Part F - .38 B69D11 092F 58.60
FAST−CLAD* DTM Urethane − Gloss (Part A)B65T854 031 11.21
Sunset Rail - Nephi, Utah Monthly Emissions Summary
FAST−CLAD* DTM Urethane (Part B)B65V850 032 8.82
Carbozinc 859 Part A - .80 PLMSDS 0486A1 005 10.82
Carbozinc 859 Part B - .20 PLMSDS 0486C1 005B 9.21
Carbothane 133HB Part A - .85 PLMSDS 0840A1 064 12.07
Carbothane 133HB Part B - .15 PLMSDS 0840B1 064B 8.74
Corbozinc 11 - .75 PLMSDS 0250A1 004 8.91
Amercoat 68HS - .80 168HS-GREYZ 093 11.57
Amercoat 68HS Cure - .20 AT68HS-B/4L-C1 093C 9.24
Amercoat 450 H - .80 LR2007108/01 094A 10.35
Amercoat 450 H Cure- .20 450N-BHARD 094C 8.24
Amercoat 370 White Resin AT370-3/16L-C1 052 15.80
Amercoat 370 Cure AT370B 053 7.84
Carboxane 2000 Part A 200A1nL 095 12.57
Carboxane 2000 Part A Metal Oxide 200A1nL 095A 10.24
Carboxane 2000 Part B 20B1NL 095B 8.41
INTERZONE 954 BASE PART A 95411A 096 14.66
INTERZONE 954 COMP.B EAA964 096B 8.49
Tile Clad HS Epoxy Part A B62WZ113 097 10.74
Tile Clad HS Epoxy Part B B60VZ70 097B 11.49
INTERCURE 200HS PART A - .75 EPA208 098 15.82
INTERCURE 200 PART B - .25 EPA215 098B 8.16
INTERGARD 251 PART A - .8 KGA905 099 13.07
INTERGARD 251 PART B - .2 KGA901 099B 7.66
INTERGARD 251 CONVERTER 251B 099C 7.73
INTERGARD 475HS PART A EVA011 100 14.41
NTERGARD 475HS LOW TEMP CONVERTER EVA056 100B 14.20
INTERTHANE 990FD PART A - .858 PKI067 101 9.76
INTERTHANE 990 FD PART B - .142 PHA046 101B 8.82
Sunset Rail - Nephi, Utah Monthly Emissions Summary
Amershield VOC Safety Yellow AMV-81 054 10.38
DIMETCOTE 9 LIQUID (D9)DI9-A 069A 8.49
DIMETCOTE 9/D9VOC/D9H POWDER DI9-P 069B 59.50
CARBOZINC 621 PART A PLMSDS 0823A1 106 8.41
ZINC FILLER TYPE II PLMSDS 0229B1 106B 59.30
CARBOGUARD 889 PART A - .50 PLMSDS 002C 10.91
CARBOGUARD 889 PART B - .50 PLMSDS 152FB1 002D 12.74
Molybdate Zinc Primer/Sherwin W TT-P-645B-107 13.32
Epoxy Primer/Sherwin W B67A5 B67A5 108 14.66
Epoxy Primer Hardner/Sherwin W B65v5 B65V5 108H 12.74
DEVRAN 224 HS 224 HS 109 12.74
Devoe Derthane 379 379 109A 10.53
Devoe BarRust 231 231 109B 11.68
Devran 201 Base - .90 201FO245 109C 12.34
Devran 201 Converter - .10 201G0300 109D 9.54
V0001 110 10.28
Amercoat 385PA Resin 053A 11.66
Amercote 240 Cure - .20 053B 8.08
Amercote 240 Resin - .80 053C 13.74
Tenemec Series 10 09 Red F010-0099 058A 11.99
Tenemec Series 72 Part A -.80 0072-00WHA 058B 11.16
Tenemec Series 72 Part B - .20 F072-0072B 058C 9.81
Tenemec Series 90 97 Part A - .80 F090-0097A 058D 8.91
Tenemec Series 90 97 Part B - .20 F090-0097B 058E 58.80
Diamond Vogel Multi-Thane 330 C/B (Part A) IG-0224 111A 9.88
Diamond Vogel Multi-Thane Multi-Thane IG-0220 111B 9.45
Devoe BarRust 235 235 109I 11.90
Hi-Solids Polyurethane-Gloss (Part S)B65W300 076 11.28
Sunset Rail - Nephi, Utah Monthly Emissions Summary
Mult-E-Prime 500 Gray Epoxy (Pt A) .50 LF-0250 112A 11.45
Mult-E-Prime 500 Epoxy Cure .50 LM-0222 112B 11.44
INTERZINC 315 GRAY Part A 0.8 315GA 113 12.99
NTERZINC 315 PART B 0.2 EPA349 113B 7.91
AMERCOAT 385 RESIN AT385-9 114 11.02
AMERCOAT 385 CURE 114B 11.02
STEEL SPEC (2.08 lb/gal VOC B55T804 024 11.00
CARBOXANE 2000 PART A .85 2000A1NL 064C 12.58
CARBOXANE 2000 PART B .15 2000B1NL 064D 8.41CARBOGUARD 893 PART A 0988A1NL 063A 12.99CARBOGUARD 893 PART B 0988B1NL 063B 12.66
INTERGARD 343 Part A .8 AAA100 100C 12.66
INTERGARD 343 Part B .2 AAA046 100D 7.91
INTERZINC 52 Part A 0.8 EPA428 113D 27.70
INTERZINC 52 Part B 0.2 EPA429 113E 7.91
CARBOCOAT 8239 8239S1NL 003C 11.41
CATHACOAT 302HB GREY DC302HB230 109F 22.49
INTERGARD 345 Part A 100E 12.66
INTERGARD 345 Part B 100F 7.91
Dura-Plate 235 Multi-Purpose Epoxy B67T235 035 11.50
INTERLAC 665 BASE DEEP 665 109G 9.74
Interprime 198 CPA198 109H 10.32
CARBOGUARD 60 PART A 1045A1NL 106C 11.66
CARBOGUARD 60 PART B 1045B1NL 106D 13.49
INTERSEAL 670HS Part A (0.8)EGA001 109J 13.91
INTERSEAL 670HS Part B (0.2)EGA247 109K 8.16
CARBOCOAT 150 UNIVERSAL PRIMER 0808S1NL 106E 11.82
Sunset Rail - Nephi, Utah Monthly Emissions Summary
SANITILE 855 PART A (0.9)S855A1NL 106F 11.16
SANITILE 855 PART B (0.1)S855B1NL 106G 8.99
Steel Master 9500 B56W311 115 10.82
PITT-TECH PLUS S/G White Base 90-1210/01 116 10.18
PRO INDUSTRIAL™ Acrylic - Gloss Safety Red B66R600 117 8.74
PRO INDUSTRIAL™ Acrylic - Gloss Safety Yellow B66Y600 118 9.10
Metalastic DTM Acrylic Modified Enamel, Extra B55WZ61 074 12.32
ENVIROLASTIC® 940 DTM (Part A) 0.8 B65B940 119 11.66
ENVIROLASTIC® 940 DTM (Part B) 0.2 B65V940 119B 8.74
PRO INDUSTRIAL™ PRO-CRYL Primer B66A1320 200 10.13
Ferro-Chem Primer (Mann)MB61 201 11.20
Carbozinc 11 0250A1NL 202 8.91
Tnemec SERIES 94-H20 94-H20 203 24.82
Tnemec NO. 2 THINNER 203A 7.24
FThinner 70 205 6.70
Plasite® 3070 206 11.70
TRICHLOROETHYLENE 207 12.40
Isopropyl Alcohol 208 6.58
Xylene Thinner 209 7.25
Sherwin willaims R7K15 PLF 63 210 6.91
VM&P Naphtha 211 6.16
Carbo Guard 635 Part A 212 14.16
Carbo Guard 635 Part A 212B 12.07
Sherwin-Williams POLANE F63W76 213 14.49
Sherwin-Williams POLANE Catylst 213B 9.32
Tnemec SURFACING EPOXY part A S215-1212A 214 13.40
Tnemec SURFACING EPOXY part B S215-1212A 214B 13.25
SEAGUARD™ Solvent #130 R7K130 215 7.08
Sunset Rail - Nephi, Utah Monthly Emissions Summary
FLUORONAR TNEMEC SERIES 1070, PART A 216 11.60
FLUORONAR TNEMEC SERIES 1070, PART B 216B 9.34
V-160 FOREST GREEN ALKYD ENAME 217 9.20
TNENMEC POTA-POX PLUS Part A (50%)218 13.69
TNENMEC POTA-POX PLUS Part B (50%)218B 11.63
THERMALINE 4700 219 10.83
Carboline Thinner 2 220 7.08
Carboline Thinner 214 221 6.80
Carboline Thinner 25 222 8.90
Next Entry
Next Entry
Next Entry
Next Entry
Total Pounds:0
Total Tons:
Sunset Rail - Nephi, Utah Monthly Emissions Summary
VOCs HAPs
Usage VOC
VOC
Emissions
(lbs/month)% by weight (lbs)% by wt Pounds % by wt Pounds % by wt Pounds % by wt
0 14.85 0 0.0 15.0 0 5.0 0
0 14.85 0 0.0 15.0 0 5.0 0 5.0
0 20.50 0 0.0 15.0 0 5.0 0 10.0
0 20.50 0 0.0
0 25.40 0 0.0 11.0 0 2.0 0 3.0
0 31.30 0 0.0 9.0 0 2.0 0
0 37.00 0 0.0 13.0 0 2.0 0
0 12.26 0 0.0 2.0 0 0.3 0
0 29.00 0 0.0 16.0 0 3.0 0
0 29.00 0 0.0 15.0 0 3.00 0
0 36.00 0 0.0 0.4 0
0 32.00 0 0.0 2.0 0
0 50.00 0 0.0
0 93.00 0 0.0
0 100.00 0 0.0
0 12.90 0 0.0 0.5 0 0.1 0
0 8.50 0 0.0 0.0 3.5 0
0 19.30 0 0.0 0.0
0 100.00 0 0.0
0 12.89 0 0.0 1.0 0
Trichloroethylene
79-01-6
Xylene
1330-20-7
Eythl Benzene
100-41-4
Tolue
108-8
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 2.00 0 0.0 1.0
0 0.00 0 0.0 5.0 0
0 20.91 0 0.0 15.0 0 0.3 0 10.0
0 20.91 0 0.0
0 0.00 0 0.0 0.6 0
0 29.00 0 0.0 3.0 0
0 26.00 0 0.0
0 21.00 0 0.0
0 11.00 0 0.0 4.0 0
0 37.00 0 0.0 20.0 0 2.0 0
0 14.00 0 0.0 7.5 0
0 35.60 0 0.0 4.0 0
0 22.00 0 0.0 14.0 0 4.0 0
0 39.00 0 0.0 20.0 0 5.5 0
0 25.00 0 0.0 5.0 0 5.5 0
0 40.00 0 0.0 37.5 0
0 40.00 0 0.0 5.5 0
0 40.00 0 0.0 17.5 0
0 50.00 0 0.0
0 18.34 0 0.0
0 10.00 0 0.0
0 24.34 0 0.0 0.6 0 0.0
0 25.90 0 0.0 0.6 0 0.4 0
0 27.12 0 0.0 10.7 0 0.6 0
0 58.00 0 0.0 4.0 0 2.0 0
0 68.00 0 0.0 12.0 0
0 0.00 0 0.0 0.1 0
0 23.90 0 0.0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 23.30 0 0.0 0.7 0
0 10.95 0 0.0 5.0 0 0.7 0 3.4
0 10.95 0 0.0 5.0 0 5.0 0 26.3
0 28.75 0 0.0 20.0 0 5.0 0 3.0
0 28.75 0 0.0 20.0 0 0.3 0
0 100.00 0 0.0
0 25.00 0 0.0 5.0 0 1.5 0
0 60.50 0 0.0 8.5 0
0 23.50 0 0.0 5.0 0
0 65.00 0 0.0 20.0 0
0 27.00 0 0.0 4.0 0
0 30.00 0 0.0
0 5.60 0 0.0 0.6
0 5.50 0 0.0 5.0 0 0.5
0 25.00 0 0.0 15.0 0 5.5 0
0 16.50 0 0.0 5.5 0
0 46.00 0 0.0 2.0 0
0 27.00 0 0.0 11.0 0 2.0 0
0 23.00 0 0.0 13.0 0 5.5 0
0 22.00 0 0.0 5.5 0
0 48.50 0 0.0 37.5 0 5.5 0
0 28.50 0 0.0 17.5 0 5.5 0
0 53.00 0 0.0 37.5 0 5.5 0
0 53.00 0 0.0 37.5 0 5.5 0
0 11.00 0 0.0 5.5 0 5.5 0
0 16.50 0 0.0 5.5 0 5.5 0
0 55.00 0 0.0 5.5 0
0 100.00 0 0.0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 6.50 0 0.0
0 41.00 0 0.0 3.0
0 0.00 0 0.0 0.6 0
0 51.00 0 0.0
0 0.00 0 0.0 0.2
0 20.09 0 0.0 0.4
0 20.09 0 0.0 0.1
0 19.90 0 0.0 2.0
0 17.50 0 0.0 12.0 0 2.0
0 17.20 0 0.0 9.0 0 0.6
0 20.00 0 0.0 0.6 0 0.6
0 40.10 0 0.0 0.6 0 0.6
0 22.00 0 0.0 3.0 0 0.6
0 21.40 0 0.0 3.0 0 7.5
0 37.70 0 0.0 25.0 0
0 38.00 0 0.0 23.0 0 6.3 0
0 31.25 0 0.0 6.3 0
0 10.12 0 0.0
0 10.00 0 0.0 6.3 0
0 22.40 0 0.0
0 22.39 0 0.0
0 0.00 0 0.0 7.5 0
0 42.60 0 0.0 45.0 0
0 0.00 0 0.0
0 28.000 0 0.0
0 9.900 0 0.0 0.6 0
0 33.160 0 0.0 3.0 0
0 21.00 0 0.0 3.0 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 23.400 0 0.0 12.5 0
0 25.100 0 0.0 5.5 0
0 30.000 0 0.0 17.5 0 5.5 0
0 50.100 0 0.0 37.5 0
0 30.000 0 0.0 0.6 0 6.3
0 42.000 0 0.0 16.3 0 2.2
0 18.000 0 0.0 0.3 0 0.0
0 14.000 0 0.0 5.0 0 1.0
0 30.000 0 0.0 25.0 0 1.0 0
0 46.000 0 0.0 5.0 0 5.0
0 30.000 0 0.0 10.0
0 44.000 0 0.0 5.5 0
0 62.500 0 0.0 0.6 0
0 6.000 0 0.0 0.6 0
0 49.000 0 0.0 37.5 0
0 17.500 0 0.0 5.5 0
0 27.000 0 0.0 11.0 0
0 27.500 0 0.0 5.5 0
0 44.000 0 0.0 0.3 0
0 12.400 0 0.0 2.0 0
0 26.000 0 0.0
0 35.000 0 0.0 5.0 0 6.0 0
0 65.000 0 0.0 12.0 0 1.5 0 0.6
0 45.000 0 0.0 3.0 0 5.5 0
0 22.000 0 0.0 5.5 0
0 40.100 0 0.0 17.5 0 6.1 0
0 33.000 0 0.0 14.0 0 0.6 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 37.500 0 0.0 1.8 0 6.1 0
0 38.000 0 0.0 14.0 0 0.3 0
0 21.000 0 0.0 1.1 0
0 0.800 0 0.0
0 0.000 0 0.0
0 0 0.0 1.0 0
0 28.000 0 0.0 5.0 0
0 24.000 0 0.0 1.0 0
0 16.300 0 0.0
0 0.300 0 0.0
0 0.120 0 0.0 0.3 0
0 73.000 0 0.0 0.6 0
0 17.000 0 0.0 5.5 0 20.0 0
0 100.000 0 0.0 80.0 0
0 100.000 0 0.0
0 13.000 0 0.0
0 100.000 0 100.0 0
0 100.000 0
0 100.000 0 85.0 0 15.00 0
0 76.000 0 37.5 0 10.00 0
0 100.000 0
0 25.000 0 1.8 0 0.55 0 6.1
0 32.000 0 14.0 0
0 22.000 0 3.0 0 0.3
0 93.000 0 0.0 0.0
0 1.190 0
0 0.160 0
0 98.000 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 27.810 0 20.0 0 20.00 0
0 10.000 0
0 33.000 0 20.0 0 3.50 0
0 19.250 0 15.6 0 5.50 0
0 18.220 0 7.5 0 5.50 0
0 31.000 0 30.0 0 6.13 0 0.6
0 100.000 0 87.5
0 87.500 0
0 100.000 0 37.5 0 12.50 0
0 0
0 0
0 0
0 0
0 0 0 0 0
0.00 0.00 0.00 0.00
Sunset Rail - Nephi, Utah Monthly Emissions Summary
Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt Pounds % by wt
0
0
0
10.0 0 0.000
0.5 0
4.0 0 3.0 0
7.5 0 0.0
7.5 0
ene
88-3
Methyl Isobutyl Ketone
108-10-1
Methanol
67-56-1
Naphthalene
91-20-3
Phenol
108-95-2
Formaldehyde
50-00-0
Diphenyl
Diisocy
101-
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0
0 5.0 0
5.0 0 0.3 0
15.3 0
7.0 0 0.3 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0
0
0
10.0 0
5.0 0
4.0 0
1.5 0
0
0
5.5 0
5.5 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0
3.0 0
3.75
2.0 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
12.5 0
35.0 0
0.6 0
0.0
0
0
0
0.0 0
0
6.0 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
2.8 0
9.6 0
5.50
6.1 0
6.1 0
37.5 0
0 6.1 0
0 4.2 0
0.0
6.8 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0 0.6 0
0
0 0 0 0 0 0
0.00 0.00 0.00 0.00 0.00 0.00
Sunset Rail - Nephi, Utah Monthly Emissions Summary
Pounds % by wt Pounds % by wt Pounds % by wt Emissions
0.30 0
0.25 0
A+E16+AF4+AF3:AF4+AF1:AF4
methane
yanate
68-8
Hexamethylene
Diisocyanate
822-06-0
Cumene
98-82-8
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0.95 0
0.55 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0.25 0
0.30 0
0.80 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
5.00 0
0.55 0
0.55 0
0.55 0
0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0.55 0
0.55 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0.98 0
0.30 0
0
0.30 0
Sunset Rail - Nephi, Utah Monthly Emissions Summary
0.55 0
0.55 0
6.15 0
0 0 0 0
0.00 0.00 0.00 0.00
PAINT ARRESTANCE FILTER TEST REPORT
Spray Removal Efficiency & Paint Holding Capacity
BASED ON 40 CFR PART 63 NATIONAL EMMISSION STANDARD
Tested For:Paint Pockets Co.
Filter Mfr.:Paint Pockets Co.
Filter Name:Paint Pockets
Report#./Test#R 266 T 372
Report Date:Jul. 19, 2000
Test Information
FILTER DESCRIPTION:
1" poly. Waffle front on 1/2" poly backing, light green
PAINT DESCRIPTION:
High Solids Baking Enamel (S.W. #1 Permaclad 2400, red)
PAINT SPRAY METHOD:
Conventional Air Gun at 40 PSI
SPRAY FEED RATE:
136 gr./min.130 cc./min.
AIR VELOCITY:
150 FPM
Test Results
INITIAL PRESSURE DROP of Clean Test Filter
0.04 in. water
FINAL PRESSURE DROP of Loaded Test Filter
0.10 in. water
WEIGHT GAON on TEST FILTER & TEST FRAME TROUGH
4354 grams
PAINT HOLDING CAPACITY of TEST FILTER
2908 grams =6.4 lbs.
PAINT RUN-OFF
1446 grams
WEIGHT GAIN on FINAL FILTER
24.9 grams =PENETRATION
AVERAGE REMOVAL EFFICIENCY of TEST FILTER
99.43 %
Test Engineer: P. Tuzinski
Supervising Engineer: K. C. Kwok, Ph.D.
Clean Filter
0.0
0.1
0.2
0.3
0.4
0.5
0 50 100 150 200 250 300
Air Velocity (FPM)
Pr
e
s
s
u
r
e

D
r
o
p

(
"
H
2O)
Pressure Drop
0.0
0.1
0.2
0.3
0.4
0.5
0 1000 2000 3000 4000 5000 6000
Wt. Paint Fed (g.)
Pr
e
s
s
u
r
e

D
r
o
p

(
"
H
2O)
Penetration
0
5
10
15
20
25
30
0 1000 2000 3000 4000 5000 6000
Wt. Paint Fed (g.)
%Removal Efficiency
90
95
100
0 1000 2000 3000 4000 5000 6000
Wt. Paint Fed (g.)
Pe
r

C
e
n
t

(
%
)

Utah Division of Air Quality
New Source Review Section Company_____________________________
Site/Source___________________________
Form 13 Date ________________________________
Spray Booths

Exhaust Gas Stream Characteristics
1. Flow Rate (acfm)
Design maximum _________

Average expected _________
2. Exhaust Stack
Temperature (oF) __________
Height (ft) __________
Diameter (ft) __________
Vertically restricted? □ Yes
□ No
3. Control Device Particulate
Loading (lb/hr)

Inlet _______ Outlet ________
Type of Coating and Maximum Rate of Use
4. Type Max. rate of use (lb/hr) Max. rate of use (ton/yr) Volatile portion (% weight)

lacquer
varnish
enamel
metal primer
metal spray
resin
sealer
shellac
stain
zinc chromate
epoxy
polyurethane
other
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______________________

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______________________
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______________________
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______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
Solvent or Coating Composition and Rate of Use
5. Chemical composition of volatiles & wt. %
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
6. Max. rate of use (lb/hr)
__________________________
__________________________
__________________________
__________________________
__________________________
7. Max rate of use (ton/yr)
_________________________
_________________________
_________________________
_________________________
_________________________
Page 1 of 2
Page 2 of 2

Form 13 - Spray Booths (Continued)

Type Control Device
8. Type of pollution control device:
□ spray chamber (use gal/hr water) __________ □ water curtain (use gal/hr water) __________
□ dry filter pads (no.) __________ (size) _____X_____ □ other (explain)
□ automated replacement □ manual replacement
9. Method of spraying:
10. _______% overspray

11. ______% efficiency
□ air atomization □ disc
□ airless electrostatic □ airless
□ air-atomized □ powdered
□ other (describe)

12. Description of items to be coated (shape and size)
Emissions Calculations (PTE)

13. Calculated emissions for this device:
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.

Attach the following:
(1) Material Safety Data Sheet for each coating or solvent.
(2) An assembly drawing (plan and elevation) of the device dimensioned and to scale clearly showing the design size
and shape.
(3) Provide sheets showing VOC emission calculations and HAP specifications.

Instructions

NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!

1. The design maximum and average flow rate of the exhaust gas stream.
2. Exhaust stack temperature, stack height, stack diameter, and whether or not the flow is vertically restricted.
3. The amount of particulate released in the paint booth and exhaust gas in pounds per hour.
4. The type of coatings and maximum amount used in an hour and a year.
5. Chemical composition of VOCs and weight in percentage.
6. Maximum rate of use in pounds per hour.
7. Maximum rate of use in tons per year.
8. The type of control equipment you are using.
9. The method of spraying. Mark appropriate box.
10. The percent of paint that is lost in overspray.
11. The percent of efficiency for the equipment.
12. The approximate shape and size of the items being coated.
13. Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete your
calculations.

U:\aq\ENGINEER\GENERIC\Forms 2010\Form13 Paint Booths.doc
Revised 12/20/10

Utah Division of Air Quality
New Source Review Section Company_____________________________
Site/Source___________________________
Form 13 Date ________________________________
Spray Booths

Exhaust Gas Stream Characteristics
1. Flow Rate (acfm)
Design maximum _________

Average expected _________
2. Exhaust Stack
Temperature (oF) __________
Height (ft) __________
Diameter (ft) __________
Vertically restricted? □ Yes
□ No
3. Control Device Particulate
Loading (lb/hr)

Inlet _______ Outlet ________
Type of Coating and Maximum Rate of Use
4. Type Max. rate of use (lb/hr) Max. rate of use (ton/yr) Volatile portion (% weight)

lacquer
varnish
enamel
metal primer
metal spray
resin
sealer
shellac
stain
zinc chromate
epoxy
polyurethane
other
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
Solvent or Coating Composition and Rate of Use
5. Chemical composition of volatiles & wt. %
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
6. Max. rate of use (lb/hr)
__________________________
__________________________
__________________________
__________________________
__________________________
7. Max rate of use (ton/yr)
_________________________
_________________________
_________________________
_________________________
_________________________
Page 1 of 2
Page 2 of 2

Form 13 - Spray Booths (Continued)

Type Control Device
8. Type of pollution control device:
□ spray chamber (use gal/hr water) __________ □ water curtain (use gal/hr water) __________
□ dry filter pads (no.) __________ (size) _____X_____ □ other (explain)
□ automated replacement □ manual replacement
9. Method of spraying:
10. _______% overspray

11. ______% efficiency
□ air atomization □ disc
□ airless electrostatic □ airless
□ air-atomized □ powdered
□ other (describe)

12. Description of items to be coated (shape and size)
Emissions Calculations (PTE)

13. Calculated emissions for this device:
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.

Attach the following:
(1) Material Safety Data Sheet for each coating or solvent.
(2) An assembly drawing (plan and elevation) of the device dimensioned and to scale clearly showing the design size
and shape.
(3) Provide sheets showing VOC emission calculations and HAP specifications.

Instructions

NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!

1. The design maximum and average flow rate of the exhaust gas stream.
2. Exhaust stack temperature, stack height, stack diameter, and whether or not the flow is vertically restricted.
3. The amount of particulate released in the paint booth and exhaust gas in pounds per hour.
4. The type of coatings and maximum amount used in an hour and a year.
5. Chemical composition of VOCs and weight in percentage.
6. Maximum rate of use in pounds per hour.
7. Maximum rate of use in tons per year.
8. The type of control equipment you are using.
9. The method of spraying. Mark appropriate box.
10. The percent of paint that is lost in overspray.
11. The percent of efficiency for the equipment.
12. The approximate shape and size of the items being coated.
13. Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete your
calculations.

U:\aq\ENGINEER\GENERIC\Forms 2010\Form13 Paint Booths.doc
Revised 12/20/10

Utah Division of Air Quality
New Source Review Section Company_____________________________
Site/Source___________________________
Form 13 Date ________________________________
Spray Booths

Exhaust Gas Stream Characteristics
1. Flow Rate (acfm)
Design maximum _________

Average expected _________
2. Exhaust Stack
Temperature (oF) __________
Height (ft) __________
Diameter (ft) __________
Vertically restricted? □ Yes
□ No
3. Control Device Particulate
Loading (lb/hr)

Inlet _______ Outlet ________
Type of Coating and Maximum Rate of Use
4. Type Max. rate of use (lb/hr) Max. rate of use (ton/yr) Volatile portion (% weight)

lacquer
varnish
enamel
metal primer
metal spray
resin
sealer
shellac
stain
zinc chromate
epoxy
polyurethane
other
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________

______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
______________________
Solvent or Coating Composition and Rate of Use
5. Chemical composition of volatiles & wt. %
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
6. Max. rate of use (lb/hr)
__________________________
__________________________
__________________________
__________________________
__________________________
7. Max rate of use (ton/yr)
_________________________
_________________________
_________________________
_________________________
_________________________
Page 1 of 2
Page 2 of 2

Form 13 - Spray Booths (Continued)

Type Control Device
8. Type of pollution control device:
□ spray chamber (use gal/hr water) __________ □ water curtain (use gal/hr water) __________
□ dry filter pads (no.) __________ (size) _____X_____ □ other (explain)
□ automated replacement □ manual replacement
9. Method of spraying:
10. _______% overspray

11. ______% efficiency
□ air atomization □ disc
□ airless electrostatic □ airless
□ air-atomized □ powdered
□ other (describe)

12. Description of items to be coated (shape and size)
Emissions Calculations (PTE)

13. Calculated emissions for this device:
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.

Attach the following:
(1) Material Safety Data Sheet for each coating or solvent.
(2) An assembly drawing (plan and elevation) of the device dimensioned and to scale clearly showing the design size
and shape.
(3) Provide sheets showing VOC emission calculations and HAP specifications.

Instructions

NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!

1. The design maximum and average flow rate of the exhaust gas stream.
2. Exhaust stack temperature, stack height, stack diameter, and whether or not the flow is vertically restricted.
3. The amount of particulate released in the paint booth and exhaust gas in pounds per hour.
4. The type of coatings and maximum amount used in an hour and a year.
5. Chemical composition of VOCs and weight in percentage.
6. Maximum rate of use in pounds per hour.
7. Maximum rate of use in tons per year.
8. The type of control equipment you are using.
9. The method of spraying. Mark appropriate box.
10. The percent of paint that is lost in overspray.
11. The percent of efficiency for the equipment.
12. The approximate shape and size of the items being coated.
13. Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete your
calculations.

U:\aq\ENGINEER\GENERIC\Forms 2010\Form13 Paint Booths.doc
Revised 12/20/10
Utah Division of Air Quality
New Source Review Section Company: _______________________
Site/Source: ______________________
Form 21 Date: ____________________________
Solvent Metal Cleaning (Degreasers)

Process Information
1. Operating schedule:

______ hrs/day

______ days/wk

______ weeks/year
2. Degreaser
Manufacturer:_________________
Model no.:____________________
Type:
□ Conveyorized □ Cold solvent
□ Open top vapor □ Batch
□ Other_______________________
3. Decription of metal parts or products
cleaned:
_______________________________
Average number of parts cleaned/hour:
_______________________________
Maximum number cleaned per hour:
_______________________________
4. Solvent usage:
Type: ____________________________
Gallons used during year: ____________
Vapor pressure: ______ (Psia @ 100 OF)
5. Solvent is: □ Sprayed □ Heated, temperature ____ OF
□ Agitated, by: □ Use of pump □ Compressed air
□ Vertical motion □ Ultrasonics
□ Other _______________________
6. Amount of solvent waste disposed of
throughout the year: _______ gallons
If known, solvent content in waste
___________________ % by volume
Method of disposal: ________________
________________________________
7. Freeboard:
a. Distance from solvent surface to top edge of degreaser
_______ inches
b. Width (not length) of tank at solvent surface _______ inches
c. Freeboard ratio, (a) above divided by (b) above
______________
8. Furnish manufacturer's Material Safety Data Sheets for all chemicals used in process.
Cold Cleaner Information
9. Equipped with cover: □ yes □ no
Easily operated with
one hand? □ yes □ no
10. Tank dimensions: Length: ________
Width: ________ Height: ________
Tank capacity: ______ gals of solvent
11. Method of draining parts:
____________________
____________________
12. Cold Cleaner has: □ Water cover □ Refrigerated chiller, operating temperature: _______ OF
□ Carbon adsorption □ Other control system: ____________________________________
□ None of the above
13. Ventilation: □ Carbon adsorption system (submit form 5)
□ None □ Other (describe) ______________________________________________

Page 1 of 3

Page 2 of 3
Form 21 – Solvent Metal Cleaning (Degreasers)
(Continued)

Open Top Vapor Degreaser and Conveyorized Degreaser Information
14. Dimensions of top opening:

Length: ______________

Width: _______________

15. Cover: □ yes □ no
Powered: □ yes □ no
Fixed spray
nozzles: □ yes □ no

16. Safety switches:

□ Condenser flow switch and thermostat which shuts off the sump heat if the
condenser coolant is either not circulating or too warm.
□ Device, other than a condenser flow switch and thermostat, which shuts off the
sump heat if the condenser coolant is either not circulating or too warm
(describe):_____________________________________________________
□ Spray safety switch which shuts off the spray pump if the vapor level drops
below any fixed spray nozzle.
□ Vapor level control thermostat which shuts off the sump heat when the vapor
level rises too high.
□ Device, other than a vapor level control thermostat, which shuts off the sump
heat when the vapor level rises too high
(describe):_____________________________________________________
______________________________________________________________
□ None of the above.

17. Indicate the type of pollution controls that open top vapor degreaser has (carbon filter, condenser, etc.):
_________________________________________________________________________________________
Conveyorized Degreaser Information
18. Type of degreaser system:
□ Cold □ Vapor
19. Operating temperature of solvent?
______________
20. Downtime covers:
□ yes □ no
21. Air/vapor interface is: ____________________sq. ft. (attach calculations )
22. Degreaser Controls:
□ Refrigerated freeboard
chiller.
□ Refrigerated condenser
coils.
□ Carbon adsorption.
□ Other control system
excluding condenser coils
and freeboard water
jacket, which reduces
solvent emission
(describe system and %
control efficiency).
□ None of the above.

23. Safety Switches:
□ Condenser flow switch and thermostat which shuts off the sump heat if the
condenser coolant is either not circulating or too warm.
□ Device, other than a condenser flow switch and thermostat, which shuts
off the sump heat if the condenser coolant is either not circulating or too
warm
(describe):________________________________________________
□ Spray safety switch which shuts off the spray pump if the vapor level drops
below any fixed spray nozzle.
□ Vapor level control thermostat which shuts off the sump heat when the
vapor level rises too high.
□ Device, other than a vapor level control thermostat, which shuts off the
sump heat when the vapor level rises too high (describe):
_________________________________________________________
_________________________________________________________
□ None of the above.
24. Conveyorized degreaser is equipped with the following equipment for preventing cleaned parts from carrying out
solvent liquid or vapor: □ None □ Drying tunnel □ Rotating basket □ Other

Page 3 of 3
Form 21 – Solvent Metal Cleaning (Degreasers)
(Continued)

Emissions Calculations (PTE)
25. Calculated emissions for each tank
VOC _________Lbs/hr_____ Tons/yr
HAPs_________Lbs/hr (speciate)______Tons/yr (speciate)
Specify the method of calculations. Also, provide manufacture’s Material Safety Data Sheets (MSDS) for
products being used. Submit calculations as an appendix.

Instructions

NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!

1. Indicate the operating schedule of the degreaser.
2. Indicate the manufacturer, model number, serial number and type of degreaser.
3. Indicate the type of parts that will be cleaned in the degreaser (attach details) and the average and maximum
number of parts cleaner per hour.
4. Indicate the type, quantity, and vapor pressure of the solvent used in the degreaser.
5. Indicate whether the solvent is sprayed, heated, agitated, and to what temperature. Indicate if and how solvent is
agitated.
6. Indicate the amount and way waste solvent is disposed.
7. Indicate the calculations for freebroad ratio.
8. Supply the manufacturer’s material safety data sheets of any chemicals used with this application.
9. Indicate whether the degreaser is covered and if that cover is easily operated with one hand.
10. Supply the tank dimensions and capacity.
11. Describe the method of draining the degreased parts.
12. Indicate if any type of controls is used with the system and what they are.
13. Describe the carbon adsorption system if applicable.
14. Give dimensions of top opening.
15. Indicate if degreaser is equipped with cover and spray nozzles.
16. Indicate the types of safety switches used on the degreaser.
17. Indicate the type of controls used on the open top vapor degreaser.
18. Tell whether the degreaser uses a cold or a vapor system.
19. Give the operating temperature of the solvent.
20. Indicate whether the conveyorized degreaser has downtime covers.
21. Provide calculations showing the air/vapor interface. This is estimated using the dimensions of the open portion of
the tank at the condenser level.
22. Indicate the degreaser controls.
23. Indicate the types of safety switches used on the degreaser.
24. Indicate the type of equipment used to prevent carry out emissions.
25. Supply calculations for all criteria pollutants and HAPs (speciate, please). Use AP-42 or manufacturers’ data to
complete your calculations.

f:\aq\ENGINEER\GENERIC\Forms 2010\Form21 Degreasers.doc
Revised 12/20/10
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process

Raw Materials

Principal Use

Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)

Item

Primary Collector

Secondary Collector

a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)

13. Stack identification:

14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:

Appendix F3
BACT Determination – Painting – “Area/Booth” #3 (PM)

Facility: Steel Coatings – Salt Lake City, UT
Process: Painting (Partial Enclosure)
Pollutant(s) Considered: Particulate Matter (PM)
Date of Determination: February 6, 2023 (Rev 8-15-23)
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants. This BACT Determination is for Area/Booth #3 (three
sided outdoor partial enclosure) (see Photo 1).
Description of Emissions – The facility receives steel parts from customers. The parts are
prepared and then painted using either powder coat (whenever possible) or solvent based paint.
Some parts are too large to be painted in enclosed booths and are painted in a partial enclosure
(top and sides enclosed). Particulate matter escapes from the two ends of this partial enclosure.

Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest ranked feasible control alternative was
determined to be Control Alternative #2.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. Fully enclose the covered partial
enclosure and add exhaust fans with
filters.
0.06 tons PM 1.079 tons PM 18,337
2. (BACT) Use HVLP guns on all jobs
possible and maintain the three sided
enclosure to maximize PM fallout.
1.139 tons PM 1.139 tons PM NA

Control Alternative 1 – Capture and Control with Filters – Fully enclose Paint Area/Booth #3 and
exhaust to floor mounted exhaust fans fitted with particulate filters.
Energy Impacts: Additional energy would be consumed using filtered exhaust. The annual
energy consumption is shown below.
Electricity = (4 x 3.73 KW) x 2,200 Hr = 32,824 KWHr x 3,412 BTU/KWHr = 111 MMBTU
Environmental Impacts: Used filters would become landfill waste.
Page 2

Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would put the company at a competitive
disadvantage.
Cost Factor Annual Cost ($)
Initial cost – Add doors and exhaust fans to semi-enclosed
outdoor paint area. Annual cost assumes a ten year equipment
life. ($70,000/10 = $7,000/yr)
7,000
Cost to finance (averaged over life) (assumes 8% rate) 3,192
Electrical cost – The fans (4 x 5 HP) would consume 3.73 KW
each and would run for 2,200 hours per year.
(4 x 3.73 KW) x 2,200 Hr = 32,824 KWHr
32,824 KWHr x $0.09/KWHr = $2,954/yr
2,954
Filter Media ($0.95/Sq Ft x (4x4x4=64) Sq Ft /week x 50 weeks) 3,040
Labor to change filters ($25/hr x 2 hrs/wk x 50 days) 2,500
Filter Disposal Cost (landfill fees) 600
Maintenance Cost 500
Total Annual Cost: 19,786
PM reduction using this alternative (95% x 1.139 tons): 1.079 tons PM
Cost per ton to control: $18,337/ton PM

Other Considerations: None.

Control Alternative 2 – Best Management Practices – Use HVLP paint guns on all jobs possible
(approximately 95% of all jobs). Maintain the partial enclosure to maximize PM fallout and
minimize emissions.
Conclusion: Control Alternative 2 was determined to constitute BACT. The other control
alternative was determined to be economically infeasible.

Photo 1: Paint Area/Booth #3 (partial enclosure)

Appendix F3
BACT Determination – Painting – “Booth” 3 (PM)

Facility: Steel Coatings – Salt Lake City, UT
Process: Indoor and Outdoor Painting (solvent based)
Pollutant(s) Considered: Particulate Matter (PM)
Date of Determination: February 6, 2023 (Rev 3-9-23)
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants. This BACT Determination is for Booth 3 (three sided
outdoor area).
Description of Emissions – The facility receives steel parts from customers. The parts are
prepared and then painted using either powder coat (whenever possible) or solvent based paint.
Some parts are too large to be painted in enclosed booths and are painted in an outdoor, three
sided (two sides and a top) booth. Particulate matter escapes from the two ends of the three
sided enclosure.

Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest ranked feasible control alternative was
determined to be Control Alternative #4.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. Fully enclose the three-sided
enclosure and add exhaust fans with
filters.
0.114 tons PM 2.164 tons PM 9,143
2. (BACT) Use HVLP guns on all jobs
possible and maintain the three sided
enclosure to maximize PM fallout.
2.164 tons PM 2.164 tons PM NA

Control Alternative 1 – Capture and Control with Filters – Fully enclose Paint Area #3 and
exhaust to floor mounted exhaust fans fitted with particulate filters.
Energy Impacts: Additional energy would be consumed using filtered exhaust. The annual
energy consumption is shown below.
Electricity = (4 x 3.73 KW) x 2,200 Hr = 32,824 KWHr x 3,412 BTU/KWHr = 111 MMBTU
Page 2

Environmental Impacts: Used filters would become landfill waste.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would put the company in a competitive
disadvantage.
Cost Factor Annual Cost ($)
Initial cost – Add doors and exhaust fans to semi-enclosed
outdoor paint area. Annual cost assumes a ten year equipment
life. ($70,000/10 = $7,000/yr)
7,000
Cost to finance (averaged over life) (assumes 8% rate) 3,192
Electrical cost – The fans (4 x 5 HP) would consume 3.73 KW
each and would run for 2,200 hours per year.
(4 x 3.73 KW) x 2,200 Hr = 32,824 KWHr
32,824 KWHr x $0.09/KWHr = $2,954/yr
2,954
Filter Media ($0.95/Sq Ft x (4x4x4=64) Sq Ft /week x 50 weeks) 3,040
Labor to change filters ($25/hr x 2 hrs/wk x 50 days) 2,500
Filter Disposal Cost (landfill fees) 600
Maintenance Cost 500
Total Annual Cost: 19,786
PM reduction using this alternative: 2.164 tons PM
Cost per ton to control: $9,143/ton PM

Other Considerations: None.

Control Alternative 2 – Best Management Practices – Use HVLP paint guns on all jobs possible
(approximately 95% of all jobs). Maintain the three sided enclosure to maximize PM fallout and
minimize emissions.
Conclusion: Control Alternative 2 was determined to constitute BACT. The other control
alternative was determined to be economically infeasible.

Appendix F2
BACT Determination – Painting – Booths 2 and 3

Facility: Steel Coatings – Salt Lake City, UT
Process: Indoor and Outdoor Painting (solvent based)
Pollutant(s) Considered: VOC and HAPs
Date of Determination: November 1, 2022
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants. This BACT Determination is for Booths 2 &3. These
booths are being considered separately from Booth 1 because the booths are separated by
hundreds of feet and using a single control device would not be possible. These two areas are
close enough that they could be exhausted to a single control device.
Description of Emissions – The facility receives steel parts from customers. The parts are
prepared and then painted using either powder coat or solvent based paint. Where allowed and
agreed by the customer, the paint applied is powder coat paint. The balance of the painting is
solvent based paint. Approximately half of all parts are painted with solvent based paint.

Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest ranked feasible control alternative was
determined to be Control Alternative #4.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. Convert to water-based paint. Not possible due to
extreme durability
requirements.
NA NA
2. Capture and thermal oxidation (RTO)
(assumes 95% capture and control)
0.390 tons VOC 7.407 tons VOC $36,773
3. Capture and carbon absorption Same as above Same as above Same as above
4. (BACT) Use powder coat paint on all
jobs possible and follow best practices
for VOC management (closed
containers, etc.)
7.797 tons VOC
(5.198 + 2.599)
7.797 tons VOC $0
5. (Baseline) Paint all parts with solvent
based paint
15.594 tons VOC
(current emissions
x 2)
0.0 tons VOC $0
Page 2

Control Alternative 1 – Convert to water-based paint. While determining BACT for its coating
operation, Steel Coatings considered the possibility of using water based or low VOC coatings.
Steel Coatings also learned that in addition to low VOC coatings there are technologies such as
E-Coat (electrodeposition) that can be used successfully to apply low VOC water based paints.
However, for the reasons below, Steel Coatings was not able to incorporate any of these coatings
or technologies into its operation.
Energy Impacts: No additional energy would re required to spray water based coatings.
Significant electricity is required for E-Coat operations.
Environmental Impacts: VOC and HAP emissions would be lower.
Economic Impacts: Because of the “Other Considerations” listed below, the economic impact
of water based paint was not calculated.
Other Considerations:
Paint Specified By Customer – The parts painted at the Steel Coatings facility are
specialty parts that are manufactured by other companies. These parts are parts from
projects that are engineered by engineering firms who specify the coatings as part of the
design process. Once Steel Coatings bids on a project and is awarded the project, the
coating type cannot be modified.

Steel Coatings deals with many customers each year. Getting even one customer to
change paints would be very difficult. There are multiple levels of vendors, contractors and
subcontractors warrantying the coatings. Steel Coatings would need to locate a paint that
would perform and then convince all of the parties involved to allow a paint substitution.

Extreme Environment Application - The parts painted by Steel Coatings are used for
outdoor industrial projects. These are applications with extreme weather and chemical
exposure conditions. Finding low VOC paints with documented performance may be
difficult.

Control Alternative 2 – Capture and Control with Thermal Oxidizer (RTO) – Paint Booth #2 and
Paint Area #3 are areas that could be enclosed and exhausted to a control device.
Energy Impacts: Additional energy would be consumed using an RTO. The annual energy
consumption is shown below.
Natural Gas = 70,000 therms x 100,000 BTU/therm = 7.0 MMBTU
Electricity = 440,000 KWHr x 3,412 BTU/KWHr = 1.5 MMBTU
Environmental Impacts: Additional green house gas (GHG) would be created from the
oxidation of natural gas and the VOCs.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would put the company in a competitive
disadvantage.
Page 3
Cost Factor Annual Cost ($)
Initial cost – One regenerative thermal oxidizer (with 24,000 CFM
accumulators) would cost approximately $1,125,000 dollars,
installed. Annual cost assumes a ten year equipment life.
112,500
Cost to finance (averaged over life) (assumes 6% rate) 37,379
Fuel cost – Even though the VOCs burned would reduce the
required fuel use, because of the high air flow, the unit would
require constant natural gas consumption. Even with the most
efficient burners, the fuel consumption is estimated as shown
below.
70,000 therms per year x $0.89 per therm = $62,300
62,300
Electrical cost – The RTO and associated fans consume 200 KW
and run for 2,200 hours per year.
200 KW x 2,200 Hr = 440,000 KWHr
440,000 KWHr x $0.08/KWHr = $35,200/yr

35,200
Maintenance Cost – Standard repairs plus media bed
maintenance.
25,000
Total Annual Cost: 272,379
VOC reduction using this alternative: 7.407 tons VOC
Cost per ton to control: $36,773/ton VOC

Other Considerations: None.

Control Alternative 3 – Capture and Control with Catalytic Oxidation or Carbon absorption –
Similar costs issues were encountered when considering these technologies.
Control Alternative 4 – Follow best practices for VOC management (keep containers closed,
etc.)
1. Use HVLP paint spray guns at least 95% of the time,
2. Operator training (to maximize paint transfer efficiency), and
3. Material management (keeping containers closed, etc.)
Energy Impacts: No additional energy is consumed with this alternative.
Environmental Impacts: VOC emissions would be less than no following the best practices
listed above.
Economic Impacts: The cost to apply powder coat paint is approximately 30% higher than the
cost to apply solvent paint. However, the cost is passed on to the customer, so using powder
coat paint does not result in a net cost to control VOC.
Other Considerations: None.
Page 4

Control Alternative 5 – Baseline is to paint all parts with solvent based paint. This results in the
lowest cost but the highest VOC (and HAP and PM) emissions.
Energy Impacts: No additional energy is consumed with this alternative.
Environmental Impacts: VOC emissions would be the highest of all alternatives and twice as
high as the method determined to be BACT.
Economic Impacts: The cost to apply powder coat paint is approximately 30% higher than the
cost to apply solvent paint. However, the cost is passed on to the customer, so using powder
coat paint does not result in a net cost to control VOC.
Other Considerations: None.

Conclusion: Control Alternative #4 was determined to constitute BACT. The other control
alternatives were either not as stringent or were determined to be infeasible.

Appendix F1
BACT Determination – Painting – Booth 1

Facility: Steel Coatings – Salt Lake City, UT
Process: Indoor Painting (solvent based)
Pollutant(s) Considered: VOC and HAPs
Date of Determination: November 1, 2022
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants.
Description of Emissions – The facility receives steel parts from customers. The parts are
prepared and then painted using either powder coat or solvent based paint. Where allowed and
agreed by the customer, the paint applied is powder coat paint. The balance of the painting is
solvent based paint. Approximately half of all parts are painted with solvent based paint.

Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest ranked feasible control alternative was
determined to be Control Alternative #4.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. Convert to water-based paint. Not possible due to
extreme durability
requirements.
NA NA
2. Capture and thermal oxidation (RTO)
(assumes 95% capture and control)
0.256 tons VOC 4.93 tons VOC $39,111
3. Capture and carbon absorption Same as above Same as above Same as above
4. (BACT) Use powder coat paint on all
jobs possible and follow best practices
for VOC management (closed
containers, etc.)
5.198 tons VOC 5.198 tons VOC $0
5. (Baseline) Paint all parts with solvent
based paint
10.396 tons VOC 0.0 tons VOC

Control Alternative 1 – Convert to water-based paint. While determining BACT for its coating
operation, Steel Coatings considered the possibility of using water based or low VOC coatings.
Page 2
Steel Coatings also learned that in addition to low VOC coatings there are technologies such as
E-Coat (electrodeposition) that can be used successfully to apply low VOC water based paints.
However, for the reasons below, Steel Coatings was not able to incorporate any of these coatings
or technologies into its operation.
Energy Impacts: No additional energy would re required to spray water based coatings.
Significant electricity is required for E-Coat operations.
Environmental Impacts: VOC and HAP emissions would be lower.
Economic Impacts: Because of the “Other Considerations” listed below, the economic impact
of water based paint was not calculated.
Other Considerations:
Paint Specified By Customer – The parts painted at the Steel Coatings facility are
specialty parts that are manufactured by other companies. These parts are parts from
projects that are engineered by engineering firms who specify the coatings as part of the
design process. Once Steel Coatings bids on a project and is awarded the project, the
coating type cannot be modified.

Steel Coatings deals with many customers each year. Getting even one customer to
change paints would be very difficult. There are multiple levels of vendors, contractors and
subcontractors warrantying the coatings. Steel Coatings would need to locate a paint that
would perform and then convince all of the parties involved to allow a paint substitution.

Extreme Environment Application - The parts painted by Steel Coatings are used for
outdoor industrial projects. These are applications with extreme weather and chemical
exposure conditions. Finding low VOC paints with documented performance may be
difficult.

Control Alternative 2 – Capture and Control with Thermal Oxidizer (RTO) – Paint Booth #1 is a
standard paint booth with exhaust. Capturing the air stream would not be difficult.
Energy Impacts: Additional energy would be consumed using an RTO. The annual energy
consumption is shown below.
Natural Gas = 50,000 therms x 100,000 BTU/therm = 5.0 MMBTU
Electricity = 330,000 KWHr x 3,412 BTU/KWHr = 1.126 MMBTU
Environmental Impacts: Additional green house gas (GHG) would be created from the
oxidation of natural gas and the VOCs.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would put the company in a competitive
disadvantage.
Cost Factor Annual Cost ($)
Initial cost – One regenerative thermal oxidizer (with 12,000 CFM
accumulators) would cost approximately $750,000 dollars,
installed. Annual cost assumes a ten year equipment life.
75,000
Page 3
Cost Factor Annual Cost ($)
Cost to finance (averaged over life) (assumes 6% rate) 24,919
Fuel cost – Even though the VOCs burned would reduce the
required fuel use, because of the high air flow, the unit would
require constant natural gas consumption. Even with the most
efficient burners, the fuel consumption is estimated as shown
below.
50,000 therms per year x $0.89 per therm = $44,500
44,500
Electrical cost – The RTO and associated fans consume 150 KW
and run for 2,200 hours per year.
150 KW x 2,200 Hr = 330,000 KWHr
330,000 KWHr x $0.08/KWHr = $26,400/yr

26,400
Maintenance Cost – Standard repairs plus media bed
maintenance.
22,000
Total Annual Cost: 192,819
VOC reduction using this alternative: 4.93 tons VOC
Cost per ton to control: $39,111/ton VOC

Other Considerations: None.

Control Alternative 3 – Capture and Control with Catalytic Oxidation or Carbon absorption –
Similar costs issues were encountered when considering these technologies.
Control Alternative 4 – Follow best practices for VOC management (keep containers closed,
etc.)
1. Use HVLP paint spray guns at least 95% of the time,
2. Operator training (to maximize paint transfer efficiency), and
3. Material management (keeping containers closed, etc.)
Energy Impacts: No additional energy is consumed with this alternative.
Environmental Impacts: VOC emissions would be less than no following the best practices
listed above.
Economic Impacts: The cost to apply powder coat paint is approximately 30% higher than the
cost to apply solvent paint. However, the cost is passed on to the customer, so using powder
coat paint does not result in a net cost to control VOC.
Other Considerations: None.

Control Alternative 5 – Baseline is to paint all parts with solvent based paint. This results in the
lowest cost but the highest VOC (and HAP and PM) emissions.
Page 4
Energy Impacts: No additional energy is consumed with this alternative.
Environmental Impacts: VOC emissions would be the highest of all alternatives and twice as
high as the method determined to be BACT.
Economic Impacts: The cost to apply powder coat paint is approximately 30% higher than the
cost to apply solvent paint. However, the cost is passed on to the customer, so using powder
coat paint does not result in a net cost to control VOC.
Other Considerations: None.

Conclusion: Control Alternative #4 was determined to constitute BACT. The other control
alternatives were either not as stringent or were determined to be infeasible.

Appendix E
BACT Determination – Abrasive Blasting

Facility: Steel Coatings – Salt Lake City, UT
Process: Abrasive Blasting
Pollutant(s) Considered: PM2.5, PM10
Date of Determination: August 7, 2023
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants.
Description of Emissions – The facility receives from customers steel assemblies and
structures to be painted. Most parts that are painted need to be abrasive blasted before being
painted. The facility operates an outdoor abrasive blasting area. This outdoor blasting results in
emissions of particulate matter.

Outdoor blasting can be conducted with sand or with grit (also called smelter sl ag or magnesium
orthosilicate). The table below (from AP42 Section 13.2.6, Table 4.2) shows that the PM
emissions while using grit are approximately 75% less than when using sand. These emission
factors will be used later in this determination to differentiate the Control Alternatives considered.

Page 2

Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest feasible control alternative was determined
to be Control Alternative #1.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. (BACT) Construct enclosed Blast
Building with dust collector. Blast
smaller parts in this building. Also
change to 80% grit and 20% silica
sand for outdoor blasting.
3.05 tons PM 12.33 tons PM $8,735

2. Continue to blast all jobs outdoors but
grit abrasive on jobs where its use is
possible and practical (80% grit).
6.08 tons PM 9.3 tons PM $5,484
3. (BASELINE) Blast with silica sand. 15.38 tons PM 0.0 tons PM Baseline
(No cost)

Control Alternative 1: Construct Building and Use Alternative Media - Construct enclosed
building and vent to dust collector with cartridge filters. Blast smaller parts in the building and the
larger parts (and parts that must be blasted with silica sand) outdoors. Use mineral grit on all
parts except those that require silica sand. Grit includes all low dust alternative such as coal and
smelter slags (i.e. Black Beauty), metallic abrasives (i.e. steel shot), synthetic abrasives (i.e.
silicon carbide and aluminum oxide) and mineral abrasives such as magnesium orthosilicate (i.e.
Page 3

Green Diamond). These alternatives all produce less PM emissions than silica sand. Grit can be
used on approximately 80% of all parts blasted outdoors and essentially all parts blasted indoors.
Energy Impacts: Additional energy would be consumed to provide lighting and electricity for
the dust collector (control device). These devices would operate 2,080 hours per year.
Lights –
40 fixtures x 0.080 KW/hr/fixture = 3.2 KW/Hr x 2,080 hrs = 6,656 KW/yr = 22.4 MMBTU/yr
Dust Collector –
5 HP x 0.746 KW/hr/HP = 3.73 KW/hr x 2,080 hrs/yr = 7,758 KW/yr = 26.5 MMBTU/yr
Environmental Impacts: PM emissions would be lowest with this alternative.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost.
Cost Factor Annual Cost ($)
Cost to change to mineral grit on 80% of parts
Mineral Grit ($180/1000 lb) x (675,000 lbs) $121,500
Silica Sand ($95/1000 lb) x (75,000 lbs) 7,125
Silica Sand ($95/1000 lb) x (750,000 lbs) -71,250
Additional Annual Cost $ 57,325
$57,375
Initial cost – Construct 80’ x 120’ (9,600 sq ft) steel building
complete with basic particulate filters mounted in front of exhaust
fans. Cost to construct is $45/sq ft = $364,800. Annual cost
assumes a twelve year equipment life.
30,400
Cost to finance (averaged over life) (assumes 8% rate) 16,985
Electrical cost (fans and light) 7,758 KW x $0.09 / KW 698
Filter Cartridges (2 cartridges x $250 each x 3 changes per year) 1,500
Labor to change filters ($250 x 3 changes per year) 750
Total Annual Cost: $107,708
PM reduction using this Control Alternative 12.33 tons PM
Cost per ton to control: $8,735/ton PM

Other Considerations: All blasting will need to be stopped to move parts from a single blast
station in and out of the building.
Control Alternative 2: Alternative Media – This Control Alternative considers blasting all parts
outdoors but using mineral grit on all parts where this can be used. Grit can be used on
approximately 80% of all parts blasted. Although grit is significantly more expensive than sand,
Steel Coatings sees this as an opportunity to change to grit as a process and safety improvement
while also significantly reducing PM emissions. Abrasive blasting with grit is preferred over silica
Page 4

sand due to respiratory hazards associated with silica sand. Additionally, grit provides process
improvements, including improved surface quality and decreased blast time.

Energy Impacts: No additional energy is used for this alternative.
Economic Impacts: The table below details the economic impact. This additional annual cost
could be tolerated by the facility.
Cost difference to use grit 80% of 750,000 lbs = 600,000 lbs
Expense Description Annual Cost ($)
Mineral Grit ($180/1000 lb) x (600,000 lbs) $108,000
Silica Sand ($95/1000 lb) x (600,000 lbs) -57,000
Additional Annual Cost $ 51,000

$51,000
Particulate Matter using 100% silica sand 15.38 tons
Particulate Matter using 80% Mineral Grit and 20% sand alternative 6.08 tons
PM reduction using this Control Alternative: 9.30 tons
Cost per ton to control: $5,484 /ton

Other Considerations: None
Conclusion: Control Alternative 1 was determined to constitute BACT. The other control
alternatives were either not as stringent or were determined to be infeasible.
Appendix E
BACT Determination – Outdoor Abrasive Blasting

Facility: Steel Coatings – Salt Lake City, UT
Process: Outdoor Abrasive Blasting
Pollutant(s) Considered: PM2.5, PM10
Date of Determination: November 1, 2022
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants.
Description of Emissions – The facility receives from customers steel assemblies and
structures to be painted. Most parts that are painted need to be abrasive blasted before being
painted. The facility operates an outdoor abrasive blasting area. This outdoor blasting results in
emissions of particulate matter.

Outdoor blasting can be conducted with sand or with grit (also called smelter slag or magnesium
orthosilicate). The table below (from AP42 Section 13.2.6, Table 4.2) shows that the PM
emissions while using grit are approximately 75% less than when using sand. These emission
factors will be used later in this determination to differentiate the Control Alternatives considered.

Page 2
Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest feasible control alternative was determined
to be Control Alternative #2.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. Construct abrasive blasting building
and use dust collector to control PM.
Assumes 5% escape through doors or
control device.
0.3 tons PM 5.78 tons PM $10,177
(not feasible)
2. Use grit abrasive on jobs where its use
is possible and practical.
6.08 tons PM 9.3 tons PM $1,000
3. Blast with silica sand. Reuse sand 2-3
times before disposal
15.38 tons PM 0.0 tons PM Baseline
(No cost)

Control Alternative 1 – Follow best practices for VOC management (keep containers closed,
etc.)
Energy Impacts: Additional energy would consumed to provide lighting and electricity for the
filtered exhaust fans (control device). These devices would operate 2,080 hours per year.
Fans –
2 x 5 HP x 0.746 KW /hr/HP = 7.46 KW /hr x 2,080 hrs/yr = 15,517 KW/yr = 52.8 MMBTU/yr
Lights –
40 fixtures x 0.080 KW/hr/fixture = 3.2 KW/Hr x 2,080 hrs = 6,656 KW/yr = 22.4 MMBTU/yr
Environmental Impacts: PM emissions would be lower.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would put the company in a competitive
disadvantage.
Cost Factor Annual Cost ($)
Initial cost – Construct 80’ x 120’ (9,600 sq ft) steel building. Cost
to construct is $45/sq ft = $364,800. Annual cost assumes a ten
year equipment life.
43,200
Cost to finance (averaged over life) (assumes 6% rate) 12,960
Electrical cost (fans and light) – 22,173 KW x $0.12 / KW . 2,661
Total Annual Cost: 58,821
PM reduction using this BACT: 5.78 tons PM
Cost per ton to control: $10,177/ton PM

Page 3
Other Considerations: None.
Control Alternative 2 – Alternative Media – Common silica sand can be used for outdoor
abrasive blasting. Low dust alternatives (also known as grit) include coal and smelter slags (i.e.
Black Beauty), metallic abrasives (i.e. steel shot), synthetic abrasives (i.e. silicon carbide and
aluminum oxide) and mineral abrasives such as magnesium orthosilicate (i.e. Green Diamond).
These alternatives all produce less PM emissions than silica sand. This Control Alternative
considers using mineral grit on all parts where this can be used. Grit can be used on
approximately 80% of all parts blasted.

Energy Impacts: No additional energy is used for this alternative.
Economic Impacts: The table below details the economic impact. This additional annual cost
could be tolerated by the facility.
Cost difference to use grit 80% of 750,000 lbs = 600,000 lbs
Expense Description Annual Cost ($)
Mineral Grit ($180/1000 lb) x (600,000 lbs) $108,000
Silica Sand ($95/1000 lb) x (600,000 lbs) -57,000
Additional Annual Cost $ 51,000

$51,000
Particulate Matter using 100% silica sand
(see calculations below)
15.38 tons
Particulate Matter using 80 % Mineral Grit and 20% sand alternative
(see calculations below)
8.08 tons
PM reduction using this alternative: 9.30 tons
Cost per ton to control: $5,484 /ton

The values in the table below report the PM emissions from abrasive blasting with and without the
use of an alternative abrasive.

Calculation for BACT
Abrasive Material
Abrasive Blasting
Silica
Sand
Mineral
Abrasive
Silica
Sand
Total abrasive used per year 750,000
Percent per abrasive material 100%80% 20%
Abrasive used (pounds)750,000 600,000 150,000
PM10 Emission Factor** (lbs/1,000 lb)0.041 0.010 0.041
PM10 Emitted (pounds)30,750 6,000 6,150
PM10 Emitted (tons)15.38 3.00 3.08
Total PM10 Emitted (tons)15.38 6.08
Difference (tons)9.30
** Emission factors are from AP-42 Section 13.2.6 Emission Factor Documentation, Table 4-2.
"Mineral Abrasive" is magnesium orthosilicate, such as Green Diamond, or equivalent.
Page 4
Other Considerations: None.
Conclusion: Control Alternative #2 was determined to constitute BACT. The other control
alternatives were either not as stringent or were determined to be infeasible.

Appendix D
BACT Determination – Vapor Degreasing

Facility: Steel Coatings – Salt Lake City, UT
Process: Indoor Painting (solvent based)
Pollutant(s) Considered: VOC and HAPs
Date of Determination: November 1, 2022
Resources Consulted: EPA’s RACT/BACT/LAER Clearinghouse (RBLC)
EPA’s Air Pollution Control Fact Sheets
Google search (Emission Control Vendors)

This determination has identified and considered all available control options (i.e. engineering
techniques, work practices and control equipment) with the potential for practical application to the
emissions unit and its associated pollutants.
Description of Emissions – The facility receives steel parts from customers. Certain metal parts
received from customers are processed in a vapor degreaser.

Control Alternatives Considered (Summary) – The following control alternatives were
considered as part of this BACT determination. They are ranked with the most stringent ranked
highest. For the reasons explained later, the highest ranked feasible control alternative was
determined to be Control Alternative #3.

Control Alternatives
(Ranked with most stringent first)
Emissions with
this Control
Alternative
(tons/yr)
Emission
Reductions
(tons/yr)
Cost per ton of
pollutant
removed
($/ton)
1. Convert to aqueous ultrasonic parts
cleaning
0.0 tons VOC 6.0 tons VOC Not calculated.
Not feasible.
2. Capture and thermal oxidation (RTO)
(assumes 95% capture and control)
0.3 tons VOC 5.70 tons VOC $26,515
3. Capture and carbon absorption Same as above Same as above Same as above
4. (BACT) Follow best practices for VOC
management (closed containers, etc.)
6.00 tons VOC 0 tons VOC $0

Control Alternative 1 – Convert to Aqueous Ultrasonic Cleaner – Because of the cleaning
method, aqueous ultrasonic cleaners have size limitations. Steel Coatings processes very large
parts in the vapor degreaser. No equipment could be located capable of cleaning the parts
processed at Steel Coatings.
Control Alternative 2 – Capture and Control (RTO) – Certain metal parts received from
customers are processed in a vapor degreaser. The degreaser is enclosed and the anticipated
capture and control rate would be 95%.
Page 2
Energy Impacts: Additional energy would be consumed using an RTO. The annual energy
consumption is shown below.
Natural Gas = 40,000 therms x 100,000 BTU/therm = 4.0 MMBTU
Electricity = 220,000 KWHr x 3,412 BTU/KWHr = 0.751 MMBTU
Environmental Impacts: Additional green house gas (GHG) would be created from the
oxidation of natural gas and the VOCs.
Economic Impacts: The table below details the economic impact. This additional annual cost
would need to be added to production cost which would put the company in a competitive
disadvantage.
Cost Factor Annual Cost ($)
Initial cost – One regenerative thermal oxidizer (with 5,000 CFM
accumulators) would cost approximately $600,000 dollars,
installed. Annual cost assumes a ten year equipment life.
60,000
Cost to finance (averaged over life) (assumes 6% rate) 19,934
Fuel cost – Even though the VOCs burned would reduce the
required fuel use, because of the high air flow, the unit would
require constant natural gas consumption. Even with the most
efficient burners, the fuel consumption is estimated as shown
below.
40,000 therms per year x $0.89 per therm = $35,600
35,600
Electrical cost – The RTO and associated fans consume 100 KW
and run for 2,200 hours per year.
100 KW x 2,200 Hr = 220,000 KWHr
220,000 KWHr x $0.08/KWHr = $17,600/yr

17,600
Maintenance Cost – Standard repairs plus media bed
maintenance.
18,000
Total Annual Cost: 151,134
VOC reduction using this alternative: 5.70 tons VOC
Cost per ton to control: $26,515/ton VOC

Other Considerations: None.

Control Alternative 3 – Capture and Control with Catalytic Oxidation or Carbon absorption –
Similar costs issues were encountered when considering these technologies.
Control Alternative 4 – Follow best practices for VOC management (keep containers closed,
etc.)
1. Keep all covers closed except when parts are added or removed,
Page 3
2. Operator training (to minimize evaporation), and
3. Material management (keeping product containers closed, etc.)

Energy Impacts: No additional energy is required.
Environmental Impacts: None identified.
Economic Impacts: None identified. Minimal cost with no impact on business.
Other Considerations: None.

Conclusion: Control Alternative #4 was determined to constitute BACT. The other control
alternatives were either not as stringent or were determined to be infeasible.

Appendix C - Site Map

Site Plan
Steel Coatings
410 S Monterey St, Salt Lake City, UT 84104
Revision Date: August 7, 2023

Outdoor
Abrasive
Blast Area
Non-Steel Coatings
Building
Non-Steel
Coatings
Mo
n
t
g
o
m
e
r
y

S
t
r
e
e
t

Stack 03 – Paint Booth #1
- 24” diameter
- Vertical discharge, 36 feet
above ground level
- Rain cap
- 9,760 CFM

365’ x 135’
(overall)

Non-Steel
Coatings
Building
Non-Steel
Coatings
Building
337’
134’
40’
250’
11’

14’
16’

16’

19’

Stack 01 – Vapor Degreaser
- 20” diameter
- Vertical discharge, 22 feet
above ground level
- No rain cap
- 4,600 CFM

Outdoor Paint
Area #3
(Covered)
(all emissions
are fugitive)
Paint Booth #2
(Exhaust is horizontal out
the north and south ends)
(17,200 + 8,860 CFM)
Stack 02 – Powder Coat Dust
Collector
- 24” diameter
- Vertical discharge, 38 feet
above ground level
- Rain cap
- 9,700 CFM

New Blast Building
85’ x 65’
Appendix C - Site Map

Site Plan
Steel Coatings
410 S Montgomery St, Salt Lake City, UT 84104
Revision Date: November 1, 2022

Outdoor
Abrasive
Blast Area
Non-Steel Coatings
Building
Non-Steel
Coatings
Mo
n
t
g
o
m
e
r
y

S
t
r
e
e
t

Stack 03 – Paint Booth #1
- 24” diameter
- Vertical discharge, 36 feet
above ground level
- Rain cap
- 9,760 CFM

365’ x 135’
(overall)

Non-Steel
Coatings
Building
Non-Steel
Coatings
Building
337’
134’
40’
250’
11’

14’
16’

16’

19’

Stack 01 – Vapor Degreaser
- 20” diameter
- Vertical discharge, 22 feet
above ground level
- No rain cap
- 4,600 CFM

Outdoor Paint
Area #3
(Covered)
(all emissions
are fugitive)
Paint Booth #2
(Exhaust is horizontal out
the north and south ends)
(17,200 + 8,860 CFM)
Stack 02 – Powder Coat Dust
Collector
- 24” diameter
- Vertical discharge, 38 feet
above ground level
- Rain cap
- 9,700 CFM

Appendix B - Area Map

Area Map
Steel Coatings Inc.
410 S Monterey Street
Salt Lake City, UT 84104
Date Drawn: November 1, 2022

Steel Coatings

Appendix A – Process Flow

Natural Gas
Metal Parts from
Customer
Stack 03 (Vertical)
VOC, HAPs, PM
Final Inspection & Shipping
Cyclone Powder Coat
Booth #1
(Blue Line)
Powder Coat
Booth #2
(Main Batch)
Powder Coat
Oven #1
Powder Coat
Oven #2a
Powder Coat
Oven #2b
Powder Coat
Oven #3
= Product Flow
= Emissions
Fugitive
Criteria
Pollutants
from
Natural
Gas
Paint Booth #1
(Solvent) (Main Bldg)
Horizontal
Discharge
VOC, HAPs, PM
Fugitive
VOC, HAPs, PM
Stack 02
PM
Paint Booth #2
(Solvent) (White Bldg)
Paint Area #3
(Solvent) (Outdoor)
Paint Hook
Burn-Off Oven Dirty Metal
Paint Hooks
Clean Metal Paint Hooks
Natural Gas
Fugitive
Criteria Pollutants
Paint
and
Thinner
Abrasive
Blasting
(Outdoor)
Fugitive
PM 2.5, PM 10
Vapor
Degreaser
Stack 01
VOC, HAPs
Integral
Filter Abrasive
Blasting
(Enclosed cabinet.
No emissions.)
GenTech
(non-TCE)
Powder Coat
Booth #3
(West Batch)
Booth
Filters
Booth
Filters
Diesel Fuel Back-up Air Compressors
(Portable, trailer mounted)
Criteria Pollutants
Abrasive
Blasting
(Blast Building)
Dust
Collector
(Rev 8-7-23)

Appendix A – Process Flow

= Product Flow
= Emissions
Metal Parts
from Customer GenTech
(non-TCE)
Natural Gas
Stack 03 (Vertical)
VOC, HAPs, PM
Final Inspection & Shipping
Baghouse

Powder Coat
Booth #1
(Blue Line)
Powder Coat
Booth #2
(Main Batch)

Powder Coat
Oven #1
Powder Coat
Oven #2a
Powder Coat
Oven #2b
Powder Coat
Oven #3
Fugitive
Criteria
Pollutants
from
Natural
Gas

Paint Booth #1
(Solvent) (Main Bldg)
Horizontal
Discharge
VOC, HAPs, PM
Fugitive
VOC, HAPs, PM
Stack 02
PM
Paint Booth #2
(Solvent) (White Bldg)
Paint Area #3
(Solvent) (Outdoor)

Paint Hook
Burn-Off Oven Dirty Metal
Paint Hooks
Clean Metal Paint Hooks
Natural Gas
Fugitive
Criteria Pollutants

Paint
and
Thinner
Abrasive
Blasting
(Outdoor)
Fugitive
PM 2.5, PM 10
Vapor
Degreaser
Stack 01
VOC, HAPs

Integral
Filter
Abrasive
Blasting
(Enclosed
cabinet. No
emissions.)
Powder Coat
Booth #3
(West Batch)
Booth
Filters
Booth
Filters

Diesel Fuel Back-up Air Compressors
(Portable, trailer mounted) Criteria Pollutants

Addendum to Approval Order Application

Facility: Steel Coatings – Salt Lake City, Utah
Date: August 15, 2023
Subject: BACT Determination – Paint Area/Booth #3 (partial enclosure)

Steel Coatings recently submitted an Addendum to Approval Order Application (August
7, 2023) which focused on the outdoor abrasive blasting operation which now includes a
blast building with dust collector to reduce PM emissions. Aside from this abrasive
blasting, the Steel Coatings facility also has particulate emissions from a partially
enclosed outdoor paint area/booth (Photo 1). The initial NOI submittal assume a 30%
paint transfer rate with no fallout and 70% of all solids sprayed being released as PM10.
Although this is clearly overestimated, Steel Coatings wanted to present the most
conservative (worst-case) scenario. However, for the reasons listed below, Steel
Coatings would like to revise the application to include calculations that more accurately
report the PM emissions from this “outdoor area/booth” painting operation.

1. Third-Party Modeling – Using the original emissions estimates, the facility-wide
PM emissions (abrasive blasting plus this painting operation) result in facility-wide PM
emissions of 5.4 tons. When determined accurately, the PM emissions from this paint
operation plus the abrasive blasting are expected to be below 4.3 tons. This may
eliminate the need for third-party PM modeling. Although third-party modeling may still
be required for HAPs emissions, not having to consider PM will simplify the process.

2. BACT - The original BACT Determination concluded that an annual expenditure
of $19,786 would be required to control 2.164 tons of PM ($9,143/ton). This resulted in
a conclusion that this was feasible and that doors and filtered exhaust would be
required. However, when the affect of the existing partially enclosed structure is
factored into emissions calculations, the actual PM emissions are reduced by 50%. With
this more accurate emissions calculation, the actual emissions are 1.139 tons.
Assuming 95% capture and control, the annual cost to enclose, ventilate and filter the
enclosure ($19,786) would now be $18,337 per ton controlled. (See updated BACT
Determination.)

The following two documents are included in support of this addendum.

SC Plant-wide Emissions (Rev 8-15-23) – This file is updated (Appendix D) to show the
emissions after considering the fallout that occurs in this partial enclosure. Although no
Page 2
fallout factor for a partial enclosure like this were located, PM fallout is well recognized
and 50% fallout in an enclosure like the one at Steel Coatings is a conservative
estimate.

Appendix E – BACT Determination – Painting “Booth” 3 (8-15-23) – The emissions
reported in this BACT Determination now include a 50% PM fallout factor.

Photo 1: Paint Area/Booth #3 (partial enclosure)

Addendum to Approval Order Application

Facility: Steel Coatings – Salt Lake City, Utah
Date: August 7, 2023
Subject: BACT Determination – Abrasive Blasting

Steel Coatings previously submitted a BACT Determination and Form 2 Process
Information for the facility’s outdoor abrasive blasting operation. Steel Coatings has
since identified an affordable opportunity to construct a building with dust collector and
perform much of the abrasive blasting indoors. This scenario significantly reduces PM
emissions. The files below are included with this submittal. Please consider these
documents in place of those previously submitted.

Appendix A – Process Flow Chart (Rev 8-7-23) – This flow chart adds the indoor
blasting process (Abrasive Blasting (Blast Building)).

Appendix C – Site Plan (Rev 8-7-23) – The updated site plan shows the location of the
new blast building.

Appendix E – BACT Determination – Abrasive Blasting (8-7-23) – This BACT
Determination includes updates to the scenario where parts are blasted using the blast
building for any parts that can be readily processed in the building.

Form 2 Process Info – Abrasive Blasting, Outdoors (8-7-23) – This is an update to the
original “Form 2 Process Info – Abrasive Blasting” form that showed 100% of abrasive
blasting completed outdoors. Outdoor blasting is still required for larger parts, but the
amount of outdoor blasting is significantly reduced.

Form 2 Process Info – Abrasive Blasting, Indoors – This is a new form showing the PM
emissions from the indoor blasting operation.

SC Plant-wide Emissions (Rev 8-7-23) – This file is updated to show the emissions
when using the blast building for any parts that can be readily processed in the building.

Addendum to Approval Order Application

Facility: Steel Coatings – Salt Lake City, Utah
Date: November 6, 2023
Subject: Reduced Vapor Degreaser Use

Steel Coatings previously submitted a Notice of Intent (NOI) requesting an Approval
Order covering all operations at it’s facility in Salt Lake City. The NOI included
calculations for emissions from its vapor degreasing operation. The emission
calculations were based on estimated use of vapor degreaser solution. Since submitting
this initial NOI Steel Coatings has closely tracked the actual the degreaser usage and
waste generation. Based on this more accurate monitoring, Steel Coatings has updated
the facility-wide emissions calculations.

The emissions of the HAP n-propyl bromide has been reduced from 5.664 tons per year
to 4.147 tons per year. Please accept the attached Plant-Wide Emissions calculations
as an addendum to the original NOI.
Facility Emissions - Plant-wide
Facility:Steel Coatings
Address:410 S Monterey Street, Salt Lake City, UT 84104
Period:Estimate of Expected Emissions for One Year
(Assumes 2,600 hours of operation annually)
Date:
Annual Emissions (tons)
Existing
Vapor
Degreaser
Abrasive
Blasting
(Outdoor)
Abrasive
Blasting
(Indoor)
Painting
Operation
(powder coat)
Painting
Operation
(solvent)
Combustion of
Natural Gas
(Powder Coat
Ovens)
Plant-wide
Total
(2,600 hrs/yr)
Potential to
Emit
(8,760 hrs/yr)
(x 3.369)
Source:Appendix A Appendix B Appendix B Appendix C Appendix D Appendix E
Criteria Pollutants
Lead (Pb)0.000 0.000 0.000
VOC 4.320 12.995 0.020 17.335 58.406
SOx (SO2)0.002 0.002 0.007
NOx 0.362 0.362 1.219
PM10 (tot)3.038 0.009 1.194 0.028 4.268 14.381
PM2.5 (tot)0.304 0.001 0.117 0.028 0.449 1.513
CO 0.304 0.304 1.024
HAPS
Xylene 1.698 1.698 5.719
Ethylbenzene 0.380 0.380 1.282
Toluene 0.263 0.263 0.888
Methyl Isobutyl Ketone 0.468 0.468 1.578
Methanol 0.073 0.073 0.247
Naphthalene 0.009 0.009 0.030
Cumene 0.015 0.015 0.049
All Other HAPS 0.088 0.088 0.296
n-propyl bromide 4.147 4.147 13.973
1,2 butylene oxide 0.043 0.043 0.146
Total HAPs 7.185 24.206
Greenhouse Gases
N2O 0.008 0.00796 0.027
N2O (CO2 Eqiv)(x 298)2.373 2.37294
Methane 0.010 0.00992 0.033
Methane (CO2 Eqiv)(x25)0.248 0.24794
CO2 379.139 379.139 1,277.407
CO2 (CO2 Eqiv)(x 1)379.14 379.139
November 6, 2023
Steel Coatings Responses (2-7-23)
BACT Analysis
BACT Determination – Vapor Degreasing
Comments: Carbon absorption is selected as one of the control alternatives. However, there are no
detailed cost analysis. From our experiences with the control technology, carbon absorption can usually
be a cheaper alternative to install, maintain, and operate. Please document cost analysis for this control
technology. Response: The BACT Determination for the vapor degreaser has been updated to include
the cost for carbon adsorption.
BACT Determination – Outdoor Abrasive Blasting
Comments:
(1) If a steel building were proposed to be built, document why the size (80’ x 120’, 9,600 sq ft) is
needed. Response: Blasting is currently being completed on a 6,000 square foot concrete pad. The
facility blasts large parts (pumps, beams, structures, etc.) As many as four blasters can operate at one
time. Parts can be moved onto and off of the pad from all four sides. Even with large doors at both ends,
in order to operate safely in an enclosed building, the building would need to be at least 50% larger than
the existing pad. Even with this size building, moving parts inside the building would be challenging.
(2) Explain why a steel building’s life is 10 years. Response: In response too this comment, the
building’s life span has been changed to twelve years. The building referenced in the analysis is a very
inexpensive structure. It is assumed that the blasting operation would remain in this building for 5-15
years. Eventually, the business will change. This may be from outgrowing the site, needing to rearrange
product flow, discontinuing blasting or if encroachment by other businesses making it difficult or
impossible to operate in this area. If the business were to change or move, the value of the building
would be essentially zero. Although no one knows how long the building will be used, the estimate is 5-
15 years. The BACT analysis now uses 12 years.
(3) When the blasting operations were conducted inside the steel building, the facility could use cheaper
abrasive materials such as sand. Instead, the NOI still proposed to use more expensive abrasive
materials such as grit, steel shot, etc. It would make more sense to use lower cost abrasive materials in
a controlled environment such as a building. In fact, if 100% sand were to be used, a steel building could
be a feasible control alternative for BACT. Response: This comment is correct. The control alternative
of using 100% silica sand indoors has been added to the BACT Determination. However, although sand is
significantly more expensive than grit, Steel Coatings sees using grit on 80% of products as an
opportunity to change to grit as a process and safety improvement while also stopping 60% of PM
emissions (Control Alternative 3). Hopefully, all production could be converted to grit in the future.
Abrasive blasting with grit is preferred over silica sand due to respiratory hazards associated with silica
sand. OSHA recommends using grit over silica sand whenever possible. Additionally, grit provides
process improvements, including improved surface quality and decreased blast time. Using silica sand
may also create more PM 2.5 that does grit. Indoor blasting with four blasters using silica sand would
create an atmosphere where respiratory protection would be required even if blasting was not being
performed.
Additionally, the BACT Determination has been updated to include the cost of filter media which makes
control significantly more expensive.

BACT Determination – Three (3) Paint Booths
Comments: (1) Provide cost analysis using carbon absorption. Carbon absorption can be usually cheaper
to install, maintain, and operate. Response: The BACT Determinations have been updated to include
the calculations for carbon adsorption. In some cases, the carbon adsorption cost per ton controlled is
as much as 35% lower.
(2) The proposed BACT does not address controls for particulate matter. Response: The following
sentence was added to cover booths 1 and 2. “PM Consideration – This determination considers only
VOC because this painting operation is indoors and exhausted to filters. The resulting PM emissions are
less than 0.03 tons per year. This existing control is BACT for particulate matter.” For Paint Booth #3, a
new BACT Determination was developed for particulate matter (PM).
Emission calculations
Please consider the suggestions above to revise the BACT. Any revision made to the BACT will have an
effect on emission calculations. Response: The BACT Determinations and all associated calculations
have been updated. The SC Plant-Wide Emissions sheet has been updated to reflect the change in
cyclone efficiency (see below).
(1) When the plant-wide total emissions are scaled up to potential to emit (PTE), BACT for some
equipment/processes may become invalid. More PTE would make some control alternatives
economically feasible. On the other hand, the scaled-up PTEs for HAPs might require modeling (need to
show why a HAP is or is not required for modeling). Response: We (Steel Coatings) assume that the
Approval Order will contain limits (to equal the emissions based on 2,600 hours per year) making the
facility a synthetic minor.
(2) As the NOI presently shows, the facility would be a major HAP source. Response: The PTE for n-
methyl bromide is over ten tons. we assume that the Approval Order will contain limits (to equal the
emissions based on 2,600 hours per year) making the facility a synthetic minor.
(3) PM emission calculations for powder coating. (a) the calculation does not include PM10 emissions.
(b) Cyclones can provide better control for large particles. The control efficiencies for small particles,
especially for PM2.5, would usually not reach 95%. The cyclone manufacturer may have control
efficiencies for different particle sizes. (c) may need to provide more proof why 3% of powder would
escape and finally be collected by cyclones. Response: Unfortunately, the facility has no performance
data for the cyclone separator. All calculations are best engineering estimates. The 3% escape to the
cyclone separator is based on the fact that powder coat transfer efficiency is much higher than solvent
paint and the configuration of the booth is such that the powder falls to the floor and only very little is
removed by room exhaust. This is supported by the absence of any color in or around the exhaust stack.
The 95% control efficiency of the cyclone separator was based on performance specs of new units, but
this may be too high. The control efficiency of the cyclone has been reduced from 95% to 80% and the
Plant-Wide Emissions spreadsheet has been updated accordingly.
(4) Paint booths. (a) Please provide filter control efficiency of 99.4% from the filter manufacturer. (b)
PM2.5 emissions were not included in the calculations. Response: See attached file named “Paint
Pockets Green - Specifications 99.4”. If Utah DAQ finds this to be inaccurate or wants a different capture
efficiency used, just let Steel Coatings know the suggested capture efficiency.
Incomplete State rules review
In the NOI, only R307-335 was reviewed, but no conclusion was provided. There are maybe other State
rules applicable to the source. Response: Although Steel Coatings is not experienced with the Utah air
permitting rules, Steel Coatings reviewed the list below and identified three that appear to be applicable
to the facility.
R307-302: Solid Fuel Burning Devices
R307-303: Commercial Cooking
R307-304: Solvent Cleaning
R307-305: Nonattainment and Maintenance Areas for PM10: Emission Standards
R307-306: PM10 Nonattainment and Maintenance Areas: Abrasive Blasting
R307-307: Road Salting and Sanding
R307-309: Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and
Fugitive Dust
R307-310: Salt Lake County: Trading of Emission Budgets for Transportation Conformity
R307-311: Utah County: Trading of Emission Budgets for Transportation Conformity
R307-312: Aggregate Processing Operations for PM2.5 Nonattainment Areas
R307-320: Ozone Maintenance Areas and Ogden City: Employer-Based Trip Reduction Program
R307-325: Ozone Nonattainment and Maintenance Areas: General Requirements
R307-326: Ozone Nonattainment and Maintenance Areas: Control of Hydrocarbon Emissions in
Petroleum Refineries
R307-327: Ozone Nonattainment and Maintenance Areas: Petroleum Liquid Storage
R307-328: Gasoline Transfer and Storage
R307-335: Degreasing
R307-341: Ozone Nonattainment and Maintenance Areas: Cutback Asphalt
R307-342: Adhesives and Sealants
R307-343: Wood Furniture Manufacturing Operations
R307-344: Paper, Film, and Foil Coatings
R307-345: Fabric and Vinyl Coatings
R307-346: Metal Furniture Surface Coatings
R307-347: Large Appliance Surface Coatings
R307-348: Magnet Wire Coatings
R307-349: Flat Wood Paneling Coatings
R307-350: Miscellaneous Metal Parts and Products Coatings
R307-351: Graphic Arts
R307-352: Metal Container, Closure, and Coil Coatings
R307-353: Plastic Parts Coatings
R307-354: Automotive Refinishing Coatings
R307-355: Aerospace Manufacture and Rework Facilities
R307-356: Appliance Pilot Light
R307-357: Consumer Products
R307-361: Architectural Coatings

NOTICE OF INTENT

APPROVAL ORDER

NOVEMBER 1, 2022

Submitted by:
Steel Coatings, Inc.
410 S Monterey Street
Salt Lake City, UT 84104

Submitted to:
Utah Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820

Page 1
TABLE OF CONTENTS

Page
Background and Process Description ..................................................... 1
Emissions Calculations ........................................................................... 1
NSPS and NESHAP ............................................................................... 2
Safety Data Sheets (submitted via e-mail) .............................................. 3
Process Flow Chart ................................................................................. Appendix A
Area Map ................................................................................................ Appendix B
Site Plan ................................................................................................. Appendix C
BACT Determination – Vapor Degreasing .............................................. Appendix D
BACT Determination – Abrasive Blasting ............................................... Appendix E
BACT Determination – Painting (Booth 1) .............................................. Appendix F1
BACT Determination – Painting (Booths 2 & 3) ...................................... Appendix F2
UDAQ Form 2 - Company Information .................................................... Attachment
UDAQ Form 2 - Process Information (5 forms) ....................................... Attachment
UDAQ Form 5 – GHG and Criteria PTE .................................................. Attachment
UDAQ Form 13 – Spray Booth (3 forms) ................................................ Attachment
UDAQ Form 21 – Solvent Metal Cleaning .............................................. Attachment
Facility-Wide Emissions (with process details) (Excel) ........................... Attachment

BACKGROUND and PROCESS DESCRIPTION
Steel Coatings operates a facility where metal parts are received, prepared and painted. The
preparation process consists of degreasing or abrasive blasting. This NOI is submitted to
request an Approval Order for the facility.

See Appendix A for a process flow chart. See Appendices B and C for details on the facility
location and layout.

EMISSIONS CALCULATIONS
Included with this NOI is a spreadsheet with worksheets demonstrating emissions calculations
for each operation. Below is discussion concerning the emission factors used.

Page 2
VOC and HAP Emissions – All VOCs and VOC HAPs used are assumed emitted.

PM2.5 and PM10 Emissions – Dust is generated during the outdoor abrasive blasting operation
and during the indoor and outdoor painting operations. The sources of emission factors used
appear with the calculations.

The facility operates an enclosed abrasive blasting cabinet for small parts. The cabinet located
indoors with no exhaust to the outdoors. This cabinet is assumed to have no emissions.

EMISSIONS CONTROLS
All emission controls are detailed on the associated process information forms.

SOURCE SIZE DETERMINATION
The facility’s potential to emit for VOC and HAPs is above the Title V limit for VOC and a single
HAP. Steel Coatings requests this Approval Order to include limits to keep actual emissions
below Title V limits. Steel Coatings hereby requests limits making the Approval Order a
synthetic minor Approval Order.

BACT ANALYSIS
Four BACT Determinations were completed and are included with this NOI.

Utah DAQ Rules Reviewed
R307-335 Degreasing

NSPS - New Source Performance Standards
The New Source Performance Standards (40 CFR 60) (NSPS) in effect at the time of this NOI
were reviewed and each was compared to the operations of this facility. No standards were
identified that applied to the facility.

NESHAP - National Emission Standards for Hazardous Air Pollutants
The area source NESHAP rules in effect at the time of this NOI (40 CFR 61 and 63) were reviewed
and each was compared to the operations of this facility. Several standards were found to cover
similar processes but were ultimately determined not to apply to the facility. The applicability
details appear below.

Page 3
NESHAP “T” (40 CFR Part 63 Subpart T) “National Emission Standard for Halogenated Solvent
Cleaning” was reviewed and determined not to apply to this facility because the solvent used at
Steel Coatings (n-propyl bromide) is not a solvent subject to this NESHAP.

NESHAP “XXXXXX” covers coating operations. Research of this NESHAP revealed that the
NESHAP only applies to area sources where the primary activity is one of the 15 activities listed
in the NESHAP. Steel Coatings’ primary business activity is coating. Steel Coatings’ NAICS
code was determined to be 332812 (SIC 3479). This NAICS code does not appear on the list of
primary activities covered by this NESHAP.

NESHAP “HHHHHH” covers coating operations. Research of this NESHAP revealed that the
NESHAP only applies to area sources where one of five target HAPs are in the coating being
sprayed. The coatings sprayed at Steel Coatings were reviewed and none of the target HAPs
were identified. For this reason, this NESHAP does not apply.

NESHAP “MMMM” covers coating operations. Research of this NESHAP revealed that the
NESHAP only applies to major sources that apply HAP containing coatings. This NOI is
submitted to request an Approval Order with emission limits less than major source levels. For
this reason, this NESHAP is not applicable.

SAFETY DATA SHEETS SUBMITTED
The Safety Data Sheets listed below and on the next page were sent to [e-mail].
These SDSs cover the coatings, abrasives and vapor degreaser.

Page 4
SAFETY DATA SHEETS SUBMITTED (continued)