DAQ-2024-011088

DAQE-AN125380010-24

{{$d1 }}

Jacob Coulson
Liberty Safe and Security Products, Inc.
1199 West Utah Avenue
Payson, UT 84651
[e-mail]

Dear Mr. Coulson:

Re: Approval Order: Modification to Approval Order DAQE-AN125380008-19 to Add a Sheetrock
Shredding Operation
Project Number: N125380010

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on June 4,
2024. Liberty Safe and Security Products, Inc. must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

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

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:KA:jg

cc: Utah County Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

September 27, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN125380010-24
Modification to Approval Order DAQE-AN125380008-19
to Add a Sheetrock Shredding Operation

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

Issued to
Liberty Safe and Security Products, Inc. - Payson Manufacturing Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 27, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 4
Source Classification .............................................................................................................. 4
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 11
PERMIT HISTORY ................................................................................................................... 15
ACRONYMS ............................................................................................................................... 16

DAQE-AN125380010-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Liberty Safe and Security Products, Inc. Liberty Safe and Security Products, Inc. - Payson Manufacturing Plant

Mailing Address Physical Address
1199 West Utah Avenue 1199 West Utah Avenue
Payson, UT 84651 Payson, UT 84651

Source Contact UTM Coordinates
Name: Jacob Coulson 435,794 m Easting
Phone: [phone],432,755 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3499 (Fabricated Metal Products, NEC)

SOURCE INFORMATION
General Description
Liberty Safe and Security Products, Inc. (Liberty Safe) owns and operates a safe and gun vault
manufacturing plant in Payson, Utah County.

The safes are cut, formed, and folded from rolled coil steel, then welded together in the metal shop. After
forming and welding, the safes are placed on a metal prep line for grinding and sanding. The safes are
then conveyed through a 5-stage washer to be cleaned. After exiting the washer, the safes are oven dried
before entering into either one of two powder coating booths or one of two wet coating booths for surface
coating.

Some safes are painted with a primer, baked, sanded, top coated with liquid paint, and baked, while others
are painted directly with a powder coating. Each powder booth is vented to a cartridge filtering system
that recirculates filtered exhaust air back into the building. There are no VOCs present in the powder
coating process. Powder-coated safes are conveyed to a curing oven and transferred into the final
assembly area to be finished.

The safes that have been painted with a primer are conveyed to a sanding booth. After sanding, they
receive a final coat of automotive-quality wet paint. They are then hand-sprayed with a coat of glossy
paint in one of several colors. The wet painted safes are conveyed through a drying oven and allowed to
air-dry. Paint overspray and VOC emissions are pulled through each booth's bank of paint particulate
filters. All of the paint booths are equipped with paint arrestor filters. The VOCs pass through the filters
and are vented through each booth's exhaust stack.

DAQE-AN125380010-24
Page 4

NSR Classification
Minor Modification at Minor Source

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

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), XXXXXX: National Emission Standards for Hazardous Air Pollutants Area
Source Standards for Nine Metal Fabrication and Finishing Source Categories

Project Description
Liberty Safe is proposing to install a sheetrock shredding operation to convert used sheetrock slabs to
crushed gypsum powder.

Liberty Safe uses sheetrock as a fire retardant in their safe manufacturing process. With the current
system, the sheetrock is shaped with a wet-jet cutting system, and the excess sheetrock is hauled away via
a third party. The installation of the sheetrock shredder allows Liberty Safe to process the waste material
into a crushed powder for disposal. The crushed powder gypsum is hauled off by a third party.

The new sheetrock shredding operation is composed of a large hopper that sits above a grinder, a product
recovery cyclone, an airlock, a screw auger, and a gypsum collector unit. Waste sheetrock is fed into the
large hopper where it then falls into the grinder to be mechanically crushed into a powdered gypsum
material. The material falls into an air stream, which pneumatically conveys the material into a product
recovery cyclone. The material collected by the cyclone passes through an airlock into the screw
conveyor and is deposited into a haul-off dumpster. The cyclone is not considered a control technology
because the cyclone is integral to the sheetrock shredding process; thus, the cyclone is considered as
being a part of the process.

The air that is separated from the gypsum powder in the product recovery cyclone is sent through a filter
baghouse that achieves a 95% reduction of particulate matter emissions.

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 16426.36
Carbon Monoxide 0 4.73
Nitrogen Oxides 0 10.47
Particulate Matter - PM10 0.76 1.77
Particulate Matter - PM2.5 0.76 1.77
DAQE-AN125380010-24
Page 5

Sulfur Oxides 0 0.11
Volatile Organic Compounds 0 33.70

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 0 2020
Generic HAPs (CAS #GHAPS) 0 2140
Methanol (CAS #67561) 0 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 8028
Naphthalene (CAS #91203) 0 3700
Styrene (CAS #100425) 0 241
Toluene (CAS #108883) 0 6940
Xylenes (Isomers And Mixture) (CAS #1330207) 0 8580
Change (TPY) Total (TPY)
Total HAPs 0 15.89

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] 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]
DAQE-AN125380010-24
Page 6

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Manufacturing Plant Safe and Security Products
II.A.2 Paint Booth A
Equipment ID: WPB-A#1
Emission Point ID: WPB-A#1
System: High End Wet Coat

II.A.3 Paint Booth B Equipment ID: WPB-B#1 Emission Point ID: WPB-B#1 System: High End Wet Coat
II.A.4 Paint Booth C
Equipment ID: WPB-C#1
Emission Point ID: WPB-C#1
System: High End Wet Coat

II.A.5 Paint Booth D Equipment ID: WPB-D#1 Emission Point ID: WPB-D#1 System: High End Wet Coat
II.A.6 Paint Booth E
Equipment ID: WPB-E#1
Emission Point ID: WPB-E#1
System: High End Wet Coat

II.A.7 Paint Booth F Equipment ID: WPB-F#1 Emission Point ID: WPB-F#1 System: High End Wet Coat
II.A.8 Paint Booth G
Equipment ID: WPB-G#1
Emission Point ID: WPB-G#1
System: High End Wet Coat

II.A.9 Primer Booth H Equipment ID: WCTUB#1 Emission Point ID: WCTUB#1 System: High End Wet Coat
II.A.10 Powder Coating Booth
Equipment ID: PB#1
Emission Point ID: Discharges to PCS#1 System: CN Line

DAQE-AN125380010-24
Page 7

II.A.11 Powder Coating Dust Collector and Cyclone Sep. Equipment ID: PCS#1 Emission Point ID: PDC#1 System: CN Line *Noted for informational purposes only as this system discharges inside the building. II.A.12 Secondary Powder Coat Dust Collector and Baghouse Equipment ID: PDC#1
Emission Point ID: Discharge into Building System: CN Line *Noted for informational purposes only.

II.A.13 Powder Coating Booth A#2 Equipment ID: PB-A#2 Emission Point ID: PCS-A#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.14 Powder Coating Dust Collector and Cyclone Sep. A#2 Equipment ID: PCS-A#2
Emission Point ID: PDC-A#2
System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.

II.A.15 Secondary Powder Coating Dust Collector, Cyclone A#2 Equipment ID: PDC-A#2 Emission Point ID: Discharge into Building System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.16 Powder Coating Booth B#2
Equipment ID: PB-B#2 Emission Point ID: PCS-B#2
System: High Volume Powder Coat
*Noted for informational purposes only as this system discharges inside the building.
II.A.17 Powder Coating Dust Collector and Cyclone Sep. B#2 Equipment ID: PCS-B#2 Emission Point ID: PDC-B#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building. II.A.18 Secondary Powder Coat Dust Collector, Baghouse B#2
Equipment ID: PDC-B#2
Emission Point ID: Discharge into Building
System: High Volume Powder Coat
*Noted for informational purposes only as this system discharges inside the building.

II.A.19 Wood Cutting System with Dust Collector Equipment ID: RWDC#1 Emission Point ID: RWDC#1 System: CN Line *Noted for informational purposes only as this system discharges inside the building.
DAQE-AN125380010-24
Page 8

II.A.20 Cure Oven #1 with Burner Equipment ID: WCOB#1 Emission Point ID: WCOE#1 A, B, & C Maximum Burner Rating: 3.0 MMBTU/hr System: High End Wet Coat Fuel Type: Natural Gas II.A.21 Cure Oven #2 with Burner
Equipment ID: WCOB#2 Emission Point ID: WCOE#2 A, B, & C Maximum Burner Rating: 3.0 MMBTU/hr
System: High End Wet Coat Fuel Type: Natural Gas
II.A.22 Sanding Booth #1 Equipment ID: WSB#1 Equipment ID: WSBE#1 A, B, & C Control Equipment: Dust Control Filters System: High End Wet Coat
II.A.23 Sanding Booth #2
Equipment ID: WCOB#2 Emission Point ID: WCOE#2 A, B, & C
Control Equipment: Dust Control Filters
System: High End Wet Coat
II.A.24 Paint Kitchen #1 Enclosed Room for Paint Storage Equipment ID: PKE#1 Emission Point ID: PKE#1 System: High End Wet Coat II.A.25 Metal Water Wash System with Boiler
Equipment ID: WSB#1
Emission Point ID: WSE-A#1 and WSE-B#1 System: CN Line

One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr
Fuel Type: Natural Gas

II.A.26 Dry-Off/Cure Combo Oven with Burners Equipment ID: PCOB#1 Emission Point ID: PCOE#1 System: CN Line Maximum Equipment Rating: 4.0 MMBTU/hr Fuel Type: Natural Gas
II.A.27 Metal Water Wash System with Boiler
Equipment ID: WSB#2
Emission Point ID: WSE-A#2 and WSE-B#2
System: High Volume Powder Coat

One (1) Boiler
Maximum Equipment Rating: 4.25 MMBTU/hr
Fuel Type: Natural Gas

DAQE-AN125380010-24
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II.A.28 Dry-Off/Cure Combo Oven with Burners Equipment ID: PDOB#2 Emission Point ID: PCOE-A#2 and PCOE-B#2 System: High Volume Metal Shop Maximum Equipment Rating: 7.6 MMBTU/hr (Includes 2-2.4 MMBTU/hr and 1-2.8 MMBTU/hr burners) Fuel Type: Natural Gas II.A.29 Burn-Off Oven with Burners Equipment ID: BOO#1
Emission Point ID: BOO#1 System: High Volume Powder Coat
Equipment: Two (2) Burners
Maximum Equipment Rating: 0.48 MMBTU/hr (each)
Fuel Type: Natural Gas
II.A.30 Comfort Heaters Various natural gas-fueled comfort heating devices rated less than 5 MMBtu/hr - each Listed for information purposes only.
II.A.31 Baghouse #1 Type: Pulse Jet
Equipment ID: WJDC-#1
Emission Point ID: Discharges into Building Equipment Location: Water Jet Room System
*Noted for informational purposes only.

II.A.32 Water Jet Cutter A Equipment ID: WJC-A Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1
II.A.33 Water Jet Cutter B Equipment ID: WJC-B
Emission Point ID: Discharges to WJDC-#1
Equipment Location: Water Jet Room Control Equipment: Baghouse #1

II.A.34 Two (2) Robotic Welders and Hoods Equipment ID: WDC#1 Emission Point ID: Dust Collector System: CN Line *Noted for informational purposes only as the system discharges internally.
II.A.35 Robotic Welder with Smoke/Dust Collector A
Equipment ID: WDC-A
Emission Point ID: Discharges into Building
Equipment Location: High Volume Metal Shop
*Noted for informational purposes only.

DAQE-AN125380010-24
Page 10

II.A.36 Robotic Welder with Smoke/Dust Collector B Equipment ID: WDC-B Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only. II.A.37 Back Square Tack Welder with Smoke/Dust Collect C Equipment ID: WDC-C
Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.

II.A.38 Face Corner Welder with Smoke/Dust Collector D Equipment ID: WDC-D Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.39 Door Build Welder with Smoke/Dust Collector E Equipment ID: WDC-E
Emission Point ID: Discharges into Building
Equipment Location: High Volume Metal Shop *Noted for informational purposes only.

II.A.40 Door Build Welder with Smoke/Dust Collector F Equipment ID: WDC-F Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.41 Grinders
Equipment ID: PGA#1 Emission Point ID: Discharges into Building
System: CN Line
*Noted for informational purposes only.
II.A.42 Infrared Pre-Cure Oven Equipment ID: IPCO#1 Emission Point ID: Discharges to Building System: High Volume Powder Coat *Noted for informational purposes only as unit uses infrared heating. II.A.43 Spray/Bake Combo Oven with Burner
Equipment ID: VDP-A
Emission Point ID: VDP-A#1
System: Vault Door Line
Control Equipment: Dust Control Filters

One (1) Burner
Maximum Equipment Rating: 1.44 MMBtu/hr
Fuel Type: Natural Gas

II.A.44 Sanding Booth Equipment ID: VDS-A System: Vault Door Line *Noted for informational purposes only as this system discharges inside the building.
DAQE-AN125380010-24
Page 11

II.A.45 One (1) Sheetrock Shredder (NEW) Emission Unit ID: SS-1 System: Gypsum Collection Control: Baghouse (95% PM10 control efficiency)

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 The Safe Manufacturing Plant shall be subject to the following limitations:
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Paint spray booth exhaust stacks - 10% opacity. B. Powder coating booth exhaust stacks - 10% opacity. C. Sanding booth exhaust stacks - 10% opacity. D. Boiler and natural gas-fired burner exhaust stacks - 10% opacity. E. Sheetrock Shredder Baghouse - 10% opacity. F. Fugitive Emissions - 15% opacity. G. All other points - 20% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not produce more than 3,120 tons of powdered gypsum material per rolling 12-month period. [R307-401-8]
II.B.1.b.1 The owner/operator shall:
A. Determine production by scale house records, belt scale records, or manifest
statements.
B. Record production on a daily basis.

C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 month.
D. Keep the production records for all periods the plant is in operation.
[R307-401-8]
DAQE-AN125380010-24
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II.B.1.c The owner/operator shall not emit more than the following from all coating, painting, and other non-combustion processes: A. 33.70 tons per rolling 12-month period for VOCs. B. 4.29 tons per rolling 12-month period for Xylene. C. 4.01 tons per rolling 12-month period for Methyl Isobutyl Ketone. D. 3.47 tons per rolling 12-month period for Toluene. E. 1.85 tons per rolling 12-month period for Naphthalene. F. 1.00 tons per rolling 12-month period for Ethyl Benzene. G. 0.12 tons per rolling 12-month period for Styrene. H. 0.07 tons per rolling 12-month period for Methanol. I. 14.82 tons per rolling 12-month period for all combined HAPs. [R307-401-8]
II.B.1.c.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 this mass-balance method:
VOCs = [%VOCs by Weight/100] x [Density] x [Volume Consumed].
HAP = [%HAP by Weigh/100] x [Density] x [Volume Consumed].

[R307-401-8]
II.B.1.c.2 The owner/operator shall maintain records of each month of the following for VOC- and/or HAP-emitting materials: A. Name of the VOC- or HAP-emitting material, such as paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon). C. Percent by weight of each VOCs or HAPs in each material used. D. Gallons of each VOC- or HAP-emitting material used. E. The amount of VOCs or HAPs emitted monthly from each material used. F. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC, or HAP emissions. G. VOC or HAP emissions from the fuel burning devices (products of incomplete combustion generated by the comfort heating devices) are NOT included in the above total. [R307-401-8]
DAQE-AN125380010-24
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II.B.1.d The owner/operator shall use particulate filters to control particulate emissions from the spray booths and powder coating booths. All exhaust air from the spray booths and powder coating booths shall be routed through the particulate filters installed in each booth prior to being vented to the atmosphere. [R307-401-8]
II.B.1.e The owner/operator shall ensure that all paint and solvent drums or containers are closed/sealed while not in use in Paint Kitchen #1. Additionally, only two (2) drums shall be open at any one time in Paint Kitchen #1. [R307-401-8]

II.B.1.f The following equipment and their associated collection/emission points shall be vented or routed back into the safe manufacturing building: 1) Water Jet Cutter A - WJC-A; 2) Water Jet Cutter B - WJC-B; 3) Baghouse #1 - WJDC-#1; 4) Robotic Welders and Hoods - WDC#1; 5) Robotic Welder with Smoke/Dust Collector A - WDC-A; 6) Robotic Welder with Smoke/Dust Collector B - WDC-B; 7) Back Square Tack Welder with Smoke/Dust Collector C - WDC-C; 8) Face Corner Welder with Smoke/Dust Collector D - WDC-D; 9) Door Build Welder with Smoke/Dust Collector E - WDC-E; 10) Door Build Welder with Smoke/Dust Collector F - WDC-F; 11) Powder Coating Booth PB#1, Dust Collector and Cyclone Separator - PCS#1, Secondary Powder Coat Dust Collector and Baghouse - PDC#1; 12) Powder Coating Booth - A#2, Powder Coating Dust Collector and Cyclone Separator - A#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-A#2; 13) Powder Coating Booth - B#2, Powder Coating Dust Collector and Cyclone Separator - B#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-B#2. 14) Grinders - CN Line - PGA#1; 15) Infrared Pre-Cure Oven - High Volume Powder Coat - IPCO #1; 16) Sanding Booth - Vault Door Line - VDS-A; 17) Sheetrock Shredder - SS-1. [R307-401]
II.B.1.g The owner/operator shall comply with all applicable requirements of UAC R307-350 for
Miscellaneous Metal Parts and Products Coatings. [R307-350]

II.B.2 Fuel Combustion Requirements
II.B.2.a The owner/operator shall only use natural gas as fuel in all on-site equipment. [R307-401-8]

DAQE-AN125380010-24
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II.B.2.b The owner/operator shall not consume more than 239,823 decatherms of natural gas per rolling 12-month period. [R307-401-8] II.B.2.b.1 The owner/operator shall:
A. Determine fuel consumption by examination of fuel supplier billing records. B. Record fuel consumption on a monthly basis.
C. Use the monthly consumption data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months.
D. Keep records of fuel consumption for all periods when the plant is in operation.
[R307-401-8]
II.B.3 Sheetrock Shredder Baghouse and Spray/Powder Coating Booth Particulate Filter Conditions
II.B.3.a The owner/operator shall control particulate emissions from the Sheetrock Shredder with a baghouse. [R307-401-8]

II.B.3.b The owner/operator shall install a baghouse on the Sheetrock Shredder with a PM10 control efficiency of no less than 95%. [R307-401-8]
II.B.3.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's control efficiency guarantee for the installed baghouse. [R307-401-8]
II.B.3.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the Sheetrock Shredder baghouse and across each spray and powder coating booth particulate filter. [R307-401-8]
II.B.3.c.1 Each pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]
II.B.3.c.2 Each pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.3.d During operation of the Sheetrock Shredder baghouse, the owner/operator shall maintain the
static pressure drop within the range recommended by the manufacturer for normal operation.
[R307-401-8]
II.B.3.d.1 The owner/operator shall record the pressure drop at least once per operating day while the Sheetrock Shredder baghouse is operating. [R307-401-8] II.B.3.d.2 The owner/operator shall maintain the following records of the pressure drop readings of the
Sheetrock Shredder baghouse:

A. Unit Identification.

B. Manufacturer recommended static pressure drop for the unit.

C. Date of reading.

D. Daily static pressure drop readings.

[R307-401-8]

DAQE-AN125380010-24
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II.B.3.e At least once every 12 months, the owner/operator shall calibrate the Sheetrock Shredder baghouse pressure gauge in accordance with the manufacturer's instructions or replace the gauge. [R307-401-8] II.B.3.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]
II.B.3.f The owner/operator shall replace the particulate filters in the spray booths and powder coating booths when the pressure differential exceeds manufacturer's recommended operating ranges. [R307-401-8] II.B.3.f.1 The owner/operator shall record the pressure drop weekly for each spray and powder coating
booth in operation. [R307-401-8]
II.B.3.f.2 The owner/operator shall maintain records of the spray booth and powder coating booth particulate filter replacements. [R307-401-8] II.B.3.f.3 The owner/operator shall maintain the following records of the pressure drop readings of the
spray and powder coating booths:
A. Booth Identification.

B. Weekly pressure drop readings.
C. Date of reading.
D. Date of particulate filter replacement.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN125380008-19 dated March 11, 2019 Is Derived From NOI dated June 4, 2024 Incorporates Additional Information dated July 12, 2024
DAQE-AN125380010-24
Page 16

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-IN125380010-24

August 22, 2024

Jacob Coulson
Liberty Safe and Security Products, Inc.
1199 West Utah Ave
Payson, UT 84651
[e-mail]

Dear Mr. Coulson:

Re: Intent to Approve: Modification to Approval Order DAQE-AN125380008-19 to Add a Sheetrock
Shredding Operation
Project Number: N125380010

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

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:KA:jg

cc: Utah County Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN125380010-24
Modification to Approval Order DAQE-AN125380008-19 to Add a
Sheetrock Shredding Operation

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

Issued to
Liberty Safe and Security Products, Inc. - Payson Manufacturing Plant

Issued On
August 22, 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 .................................................................................................................. 4
Source Classification .............................................................................................................. 4
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 12
PERMIT HISTORY ................................................................................................................... 16
ACRONYMS ............................................................................................................................... 17

DAQE-IN125380010-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Liberty Safe and Security Products, Inc. Liberty Safe and Security Products, Inc. - Payson Manufacturing Plant

Mailing Address Physical Address
1199 West Utah Ave 1199 West Utah Ave
Payson, UT 84651 Payson, UT 84651

Source Contact UTM Coordinates
Name: Jacob Coulson 435,794 m Easting
Phone: [phone],432,755 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3499 (Fabricated Metal Products, NEC)

SOURCE INFORMATION
General Description
Liberty Safe and Security Products, Incorporated (Liberty Safe) owns and operates a safe and gun vault
manufacturing plant in Payson, Utah County.

The safes are cut, formed, and folded from rolled coil steel, then welded together in the metal shop. After
forming and welding, the safes are placed on a metal prep line for grinding and sanding. The safes are
then conveyed through a 5-stage washer to be cleaned. After exiting the washer, the safes are oven dried
before entering either one of two powder coating booths or one of two wet coating booths for surface
coating.

Some safes are painted with a primer, baked, sanded, top coated with liquid paint, and baked, while others
are painted directly with a powder coating. Each powder booth is vented to a cartridge filtering system
that recirculates filtered exhaust air back into the building. There are no VOCs present in the powder
coating process. Powder-coated safes are conveyed to a curing oven and transferred into the final
assembly area to be finished.

The safes that have been painted with primer are conveyed to a sanding booth. After sanding, they receive
a final coat of automotive-quality wet paint. They are then hand-sprayed with a coat of glossy paint in one
of several colors. The wet-painted safes are conveyed through a drying oven and allowed to air-dry. Paint
overspray and VOC emissions are pulled through each booth's bank of paint particulate filters. All of the
paint booths are equipped with paint arrestor filters. The VOCs pass through the filters and are vented
through each booth's exhaust stack.

DAQE-IN125380010-24
Page 4

NSR Classification
Minor Modification at Minor Source

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

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), XXXXXX: National Emission Standards for Hazardous Air Pollutants Area
Source Standards for Nine Metal Fabrication and Finishing Source Categories

Project Description
Liberty Safe is proposing to install a sheetrock shredding operation to convert used sheetrock slabs to a
crushed gypsum powder.

Liberty Safe uses sheetrock as a fire retardant in their safe manufacturing process. With the current
system, the sheetrock is shaped with a wet-jet cutting system, and the excess sheetrock is hauled away via
a third party. The installation of the sheetrock shredder allows Liberty Safe to process the waste material
into a crushed powder for disposal. The crushed powder gypsum is hauled off by a third party.

The new sheetrock shredding operation is composed of a large hopper that sits above a grinder, a product
recovery cyclone, an airlock, a screw auger, and a gypsum collector unit. Waste sheetrock is fed into the
large hopper, where it then falls into the grinder to be mechanically crushed into a powdered gypsum
material. The material falls into an air stream, which pneumatically conveys the material into a product
recovery cyclone. The material collected by the cyclone passes through an airlock into the screw
conveyor and is deposited in a haul-off dumpster. The cyclone is not considered a control technology
because the cyclone is integral to the sheetrock shredding process; thus, the cyclone is considered as
being a part of the process.

The air that is separated from the gypsum powder in the product recovery cyclone is sent through a filter
baghouse that achieves 95% a reduction in particulate matter emissions.

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 16426.36
Carbon Monoxide 0 4.73
Nitrogen Oxides 0 10.47
Particulate Matter - PM10 0.76 1.77
Particulate Matter - PM2.5 0.76 1.77
DAQE-IN125380010-24
Page 5

Sulfur Oxides 0 0.11
Volatile Organic Compounds 0 33.70

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 0 2020
Generic HAPs (CAS #GHAPS) 0 2140
Methanol (CAS #67561) 0 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 8028
Naphthalene (CAS #91203) 0 3700
Styrene (CAS #100425) 0 241
Toluene (CAS #108883) 0 6940
Xylenes (Isomers And Mixture) (CAS #1330207) 0 8580
Change (TPY) Total (TPY)
Total HAPs 0 15.89

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in The Daily Herald on August 24, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

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

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
DAQE-IN125380010-24
Page 6

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 Manufacturing Plant Safe and Security Products II.A.2 Paint Booth A Equipment ID: WPB-A#1 Emission Point ID: WPB-A#1 System: High-End Wet Coat
II.A.3 Paint Booth B Equipment ID: WPB-B#1 Emission Point ID: WPB-B#1 System: High-End Wet Coat
II.A.4 Paint Booth C Equipment ID: WPB-C#1 Emission Point ID: WPB-C#1
System: High-End Wet Coat
II.A.5 Paint Booth D Equipment ID: WPB-D#1 Emission Point ID: WPB-D#1 System: High-End Wet Coat
DAQE-IN125380010-24
Page 7

II.A.6 Paint Booth E Equipment ID: WPB-E#1 Emission Point ID: WPB-E#1 System: High-End Wet Coat
II.A.7 Paint Booth F Equipment ID: WPB-F#1 Emission Point ID: WPB-F#1
System: High-End Wet Coat
II.A.8 Paint Booth G Equipment ID: WPB-G#1 Emission Point ID: WPB-G#1 System: High-End Wet Coat
II.A.9 Primer Booth H Equipment ID: WCTUB#1
Emission Point ID: WCTUB#1
System: High-End Wet Coat
II.A.10 Powder Coating Booth Equipment ID: PB#1 Emission Point ID: Discharges to PCS#1 System: CN Line
II.A.11 Powder Coating Dust Collector and Cyclone Sep. Equipment ID: PCS#1
Emission Point ID: PDC#1
System: CN Line *Noted for informational purposes only as this system discharges inside the building.

II.A.12 Secondary Powder Coat Dust Collector and Baghouse Equipment ID: PDC#1 Emission Point ID: Discharge into Building System: CN Line *Noted for informational purposes only.
II.A.13 Powder Coating Booth A#2
Equipment ID: PB-A#2 Emission Point ID: PCS-A#2
System: High-Volume Powder Coat
*Noted for informational purposes only as this system discharges inside the building.
II.A.14 Powder Coating Dust Collector and Cyclone Sep. A#2 Equipment ID: PCS-A#2 Emission Point ID: PDC-A#2 System: High-Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.15 Secondary Powder Coating Dust Collector, Cyclone A#2
Equipment ID: PDC-A#2
Emission Point ID: Discharge into Building
System: High-Volume Powder Coat
*Noted for informational purposes only as this system discharges inside the building.

DAQE-IN125380010-24
Page 8

II.A.16 Powder Coating Booth B#2 Equipment ID: PB-B#2 Emission Point ID: PCS-B#2 System: High-Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building. II.A.17 Powder Coating Dust Collector and Cyclone Sep B#2 Equipment ID: PCS-B#2
Emission Point ID: PDC-B#2 System: High-Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.

II.A.18 Secondary Powder Coat Dust Collector, Baghouse B#2 Equipment ID: PDC-B#2 Emission Point ID: Discharge into Building System: High-Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.19 Wood Cutting System with Dust Collector Equipment ID: RWDC#1
Emission Point ID: RWDC#1
System: CN Line *Noted for informational purposes only as this system discharges inside the building.

II.A.20 Cure Oven #1 with Burner Equipment ID: WCOB#1 Emission Point ID: WCOE#1 A, B, & C Maximum Burner Rating: 3.0 MMBTU/hr System: High-End Wet Coat Fuel Type: Natural Gas
II.A.21 Cure Oven #2 with Burner Equipment ID: WCOB#2
Emission Point ID: WCOE#2 A, B, & C
Maximum Burner Rating: 3.0 MMBTU/hr System: High-End Wet Coat
Fuel Type: Natural Gas

II.A.22 Sanding Booth #1 Equipment ID: WSB#1 Equipment ID: WSBE#1 A, B, & C Control Equipment: Dust Control Filters System: High-End Wet Coat
II.A.23 Sanding Booth #2
Equipment ID: WCOB#2
Emission Point ID: WCOE#2 A, B, & C
Control Equipment: Dust Control Filters
System: High-End Wet Coat

II.A.24 Paint Kitchen #1 Enclosed Room for Paint Storage Equipment ID: PKE#1 Emission Point ID: PKE#1 System: High-End Wet Coat
DAQE-IN125380010-24
Page 9

II.A.25 Metal Water Wash System with Boiler Equipment ID: WSB#1 Emission Point ID: WSE-A#1 and WSE-B#1 System: CN Line One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr Fuel Type: Natural Gas II.A.26 Dry-Off/Cure Combo Oven with Burners Equipment ID: PCOB#1
Emission Point ID: PCOE#1 System: CN Line
Maximum Equipment Rating: 4.0 MMBTU/hr Fuel Type: Natural Gas

II.A.27 Metal Water Wash System with Boiler Equipment ID: WSB#2 Emission Point ID: WSE-A#2 and WSE-B#2 System: High Volume Powder Coat One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr Fuel Type: Natural Gas
II.A.28 Dry-Off/Cure Combo Oven with Burners
Equipment ID: PDOB#2 Emission Point ID: PCOE-A#2 and PCOE-B#2
System: High Volume Metal Shop
Maximum Equipment Rating: 7.6 MMBTU/hr
(Includes 2 - 2.4 MMBTU/hr and 1 - 2.8 MMBTU/hr burners)
Fuel Type: Natural Gas
II.A.29 Burn-Off Oven with Burners Equipment ID: BOO#1 Emission Point ID: BOO#1 System: High Volume Powder Coat Equipment: Two (2) Burners Maximum Equipment Rating: 0.48 MMBTU/hr (each) Fuel Type: Natural Gas
II.A.30 Comfort Heaters
Various natural gas fueled comfort heating devices rated less than 5 MMBtu/hr - each

Listed for information purposes only.

II.A.31 Baghouse #1 Type: Pulse Jet Equipment ID: WJDC-#1 Emission Point ID: Discharges into Building Equipment Location: Water Jet Room System *Noted for informational purposes only.
DAQE-IN125380010-24
Page 10

II.A.32 Water Jet Cutter A Equipment ID: WJC-A Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1 II.A.33 Water Jet Cutter B Equipment ID: WJC-B
Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1

II.A.34 Two (2) Robotic Welders and Hoods Equipment ID: WDC#1 Emission Point ID: Dust Collector System: CN Line *Noted for informational purposes only as the system discharges internally
II.A.35 Robotic Welder with Smoke/Dust Collector A Equipment ID: WDC-A
Emission Point ID: Discharges into Building
Equipment Location: High-Volume Metal Shop *Noted for informational purposes only.

II.A.36 Robotic Welder with Smoke/Dust Collector B Equipment ID: WDC-B Emission Point ID: Discharges into Building Equipment Location: High-Volume Metal Shop *Noted for informational purposes only.
II.A.37 Back Square Tack Welder with Smoke/Dust Collect C
Equipment ID: WDC-C Emission Point ID: Discharges into Building
Equipment Location: High-Volume Metal Shop
*Noted for informational purposes only.
II.A.38 Face Corner Welder with Smoke/Dust Collector D Equipment ID: WDC-D Emission Point ID: Discharges into Building Equipment Location: High-Volume Metal Shop *Noted for informational purposes only. II.A.39 Door Build Welder with Smoke/Dust Collector E
Equipment ID: WDC-E
Emission Point ID: Discharges into Building
Equipment Location: High-Volume Metal Shop
*Noted for informational purposes only.

II.A.40 Door Build Welder with Smoke/Dust Collector F Equipment ID: WDC-F Emission Point ID: Discharges into Building Equipment Location: High-Volume Metal Shop *Noted for informational purposes only.
DAQE-IN125380010-24
Page 11

II.A.41 Grinders Equipment ID: PGA#1 Emission Point ID: Discharges into Building System: CN Line *Noted for informational purposes only. II.A.42 Infrared Pre-Cure Oven Equipment ID: IPCO#1
Emission Point ID: Discharges to Building System: High-Volume Powder Coat *Noted for informational purposes only as unit uses infrared heating.

II.A.43 Spray/Bake Combo Oven with Burner Equipment ID: VDP-A Emission Point ID: VDP-A#1 System: Vault Door Line Control Equipment: Dust Control Filters One (1) Burner Maximum Equipment Rating: 1.44 MMBtu/hr Fuel Type: Natural Gas II.A.44 Sanding Booth
Equipment ID: VDS-A
System: Vault Door Line *Noted for informational purposes only as this system discharges inside the building.

II.A.45 One (1) Sheetrock Shredder (NEW) Emission Unit ID: SS-1 System: Gypsum Collection Control: Baghouse (95% PM10 control efficiency)

DAQE-IN125380010-24
Page 12

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 The Safe Manufacturing Plant shall be subject to the following limitations:
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Paint spray booth exhaust stacks - 10% opacity. B. Powder coating booth exhaust stacks - 10% opacity. C. Sanding booth exhaust stacks - 10% opacity. D. Boiler and natural gas fired burner exhaust stacks - 10% opacity. E. Sheetrock Shredder Baghouse - 10% opacity. F. Fugitive Emissions - 15% opacity. G. All other points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not produce more than 3,120 tons of powdered gypsum material per rolling 12-month period. [R307-401-8] II.B.1.b.1 The owner/operator shall: A. Determine production by scale house records, belt scale records, or manifest statements. B. Record production on a daily basis. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8]
DAQE-IN125380010-24
Page 13

II.B.1.c The owner/operator shall not emit more than the following from all coating, painting, and other non-combustion processes: A. 33.70 tons per rolling 12-month period for VOCs. B. 4.29 tons per rolling 12-month period for Xylene. C. 4.01 tons per rolling 12-month period for Methyl Isobutyl Ketone. D. 3.47 tons per rolling 12-month period for Toluene. E. 1.85 tons per rolling 12-month period for Naphthalene. F. 1.00 tons per rolling 12-month period for Ethyl Benzene. G. 0.12 tons per rolling 12-month period for Styrene. H. 0.07 tons per rolling 12-month period for Methanol. I. 14.82 tons per rolling 12-month period for all combined HAPs. [R307-401-8]
II.B.1.c.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 this mass-balance method:
VOCs = [%VOCs by Weight/100] x [Density] x [Volume Consumed].
HAP = [%HAP by Weigh/100] x [Density] x [Volume Consumed].

[R307-401-8]
II.B.1.c.2 The owner/operator shall maintain records of each month of the following for VOC- and/or HAP-emitting materials: A. Name of the VOC- or HAP-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon). C. Percent by weight of each VOCs or HAPs in each material used. D. Gallons of each VOC- or HAP-emitting material used. E. The amount of VOCs or HAPs emitted monthly from each material used. F. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC, or HAP emissions. G. VOC or HAP emissions from the fuel burning devices (products of incomplete combustion generated by the comfort heating devices) are NOT included in the above total. [R307-401-8]
DAQE-IN125380010-24
Page 14

II.B.1.d The owner/operator shall use particulate filters to control particulate emissions from the spray booths and powder coating booths. All exhaust air from the spray booths and powder coating booths shall be routed through the particulate filters installed in each booth prior to being vented to the atmosphere. [R307-401-8]
II.B.1.e The owner/operator shall ensure that all paint and solvent drums or containers are closed/sealed while not in use in Paint Kitchen #1. Additionally, only two drums shall be open at any one time in Paint Kitchen #1. [R307-401-8]

II.B.1.f The following equipment and their associated collection/emission points shall be vented or routed back into the safe manufacturing building: 1) Water Jet Cutter A - WJC-A; 2) Water Jet Cutter B - WJC-B; 3) Baghouse #1 - WJDC-#1; 4) Robotic Welders and Hoods - WDC#1; 5) Robotic Welder with Smoke/Dust Collector A - WDC-A; 6) Robotic Welder with Smoke/Dust Collector B - WDC-B; 7) Back Square Tack Welder with Smoke/Dust Collector C - WDC-C; 8) Face Corner Welder with Smoke/Dust Collector D - WDC-D; 9) Door Build Welder with Smoke/Dust Collector E - WDC-E; 10) Door Build Welder with Smoke/Dust Collector F - WDC-F; 11) Powder Coating Booth PB#1, Dust Collector and Cyclone Separator - PCS#1, Secondary Powder Coat Dust Collector and Baghouse - PDC#1; 12 Powder Coating Booth - A#2, Powder Coating Dust Collector and Cyclone Separator - A#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-A#2; 13) Powder Coating Booth - B#2, Powder Coating Dust Collector and Cyclone Separator - B#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-B#2. 14) Grinders - CN Line - PGA#1; 15) Infrared Pre-Cure Oven - High Volume Powder Coat - IPCO #1; 16) Sanding Booth - Vault Door Line - VDS-A; 17) Sheetrock Shredder - SS-1. [R307-401]
II.B.1.g The owner/operator shall comply with all applicable requirements of UAC R307-350 for
Miscellaneous Metal Parts and Products Coatings. [R307-350]

II.B.2 Fuel Combustion Requirements
II.B.2.a The owner/operator shall only use natural gas as fuel in all on-site equipment. [R307-401-8]

DAQE-IN125380010-24
Page 15

II.B.2.b The owner/operator shall not consume more than 239,823 decatherms of natural gas per rolling 12-month period. [R307-401-8] II.B.2.b.1 The owner/operator shall:
A. Determine fuel consumption by examination of fuel supplier billing records. B. Record fuel consumption on a monthly basis.
C. Use the monthly consumption data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months.
D. Keep records of fuel consumption for all periods when the plant is in operation.
[R307-401-8]
II.B.3 Sheetrock Shredder Baghouse and Spray/Powder Coating Booth Particulate Filter Conditions
II.B.3.a The owner/operator shall control particulate emissions from the Sheetrock Shredder with a baghouse. [R307-401-8]

II.B.3.b The owner/operator shall install a baghouse on the Sheetrock Shredder with a PM10 control efficiency of no less than 95%. [R307-401-8]
II.B.3.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's control efficiency guarantee for the installed baghouse. [R307-401-8]
II.B.3.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the Sheetrock Shredder baghouse and across each spray and powder coating booth particulate filter. [R307-401-8]
II.B.3.c.1 Each pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]
II.B.3.c.2 Each pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.3.d During operation of the Sheetrock Shredder baghouse, the owner/operator shall maintain the
static pressure drop within the range recommended by the manufacturer for normal operation.
[R307-401-8]
II.B.3.d.1 The owner/operator shall record the pressure drop at least once per operating day while the Sheetrock Shredder baghouse is operating. [R307-401-8] II.B.3.d.2 The owner/operator shall maintain the following records of the pressure drop readings of the
Sheetrock Shredder baghouse:

A. Unit identification.

B. Manufacturer recommended static pressure drop for the unit.

C. Date of reading.

D. Daily static pressure drop readings.

[R307-401-8]

DAQE-IN125380010-24
Page 16

II.B.3.e At least once every 12 months, the owner/operator shall calibrate the Sheetrock Shredder baghouse pressure gauge in accordance with the manufacturer's instructions or replace the gauge. [R307-401-8] II.B.3.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]
II.B.3.f The owner/operator shall replace the particulate filters in the spray booths and powder coating booths when the pressure differential exceeds manufacturer's recommended operating ranges. [R307-401-8] II.B.3.f.1 The owner/operator shall record the pressure drop weekly for each spray and powder coating
booth in operation. [R307-401-8]
II.B.3.f.2 The owner/operator shall maintain records of the spray booth and powder coating booth particulate filter replacements. [R307-401-8] II.B.3.f.3 The owner/operator shall maintain the following records of the pressure drop readings of the
spray and powder coating booths:
A. Booth identification.

B. Weekly pressure drop readings.
C. Date of reading.
D. Date of particulate filter replacement.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN125380008-19 dated March 11, 2019 Is Derived From NOI dated June 4, 2024 Incorporates Additional Information dated July 12, 2024
DAQE-IN125380010-24
Page 17

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

Daily Herald
Publication Name:
Daily Herald
Publication URL:
Publication City and State:
Provo, UT
Publication County:
Utah
Notice Popular Keyword Category:
Notice Keywords:
liberty
Notice Authentication Number:
202408261328350689960
1761527914
Notice URL:
Back
Notice Publish Date:
Saturday, August 24, 2024
Notice Content
NOTICE Company Name: Liberty Safe and Security Products, Inc. Location: Liberty Safe and Security Products, Inc. - Payson Manufacturing
Plant - 1199 West Utah Ave, Payson, UT Project Description: Liberty Safe and Security Products, Incorporated (Liberty Safe) owns and
operates a safe and gun vault manufacturing plant in Payson, Utah County. The safes are cut, formed, and folded from rolled coil steel, then
welded together in the metal shop. The safes then go through various grinding, sanding, painting, and manufacturing processes for the final
production. Liberty Safe uses sheetrock as a fire retardant in their safe manufacturing process. Liberty Safe is proposing to install a sheetrock
shredding operation to convert used sheetrock slabs to crushed gypsum powder. The installation of the sheetrock shredder allows Liberty
Safe to process the waste material into a crushed powder for disposal. The crushed powder gypsum is hauled off by a third party. The new
sheetrock shredding operation is composed of a large hopper that sits above a grinder, a product recovery cyclone, an airlock, a screw auger,
and a gypsum collector unit. Waste sheetrock is fed into the large hopper, where it then falls into the grinder to be mechanically crushed into
a powdered gypsum material. The material falls into an air stream, which pneumatically conveys the material into a product recovery
cyclone. The material collected by the cyclone passes through an airlock into the screw conveyor and is deposited in a haul-off dumpster. The
cyclone is not considered a control technology because the cyclone is integral to the sheetrock shredding process; thus, the cyclone is
considered as being a part of the process. The air that is separated from the gypsum powder in the product recovery cyclone is sent through
a filter baghouse that achieves 95% a reduction in particulate matter emissions. 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 September 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: August 24, 2024 Legal Notice 13166
Published in the Daily Herald on August 24, 2024
Back

DAQE-NN125380010-24

August 22, 2024

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

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald on August
24, 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: Utah County
cc: Mountainland Association of Governments

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN125380010-24
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: Liberty Safe and Security Products, Inc.
Location: Liberty Safe and Security Products, Inc. - Payson Manufacturing Plant – 1199
West Utah Ave, Payson, UT
Project Description: Liberty Safe and Security Products, Incorporated (Liberty Safe) owns and
operates a safe and gun vault manufacturing plant in Payson, Utah County. The
safes are cut, formed, and folded from rolled coil steel, then welded together in
the metal shop. The safes then go through various grinding, sanding, painting,
and manufacturing processes for the final production. Liberty Safe uses sheetrock
as a fire retardant in their safe manufacturing process. Liberty Safe is proposing
to install a sheetrock shredding operation to convert used sheetrock slabs to
crushed gypsum powder.

The installation of the sheetrock shredder allows Liberty Safe to process the
waste material into a crushed powder for disposal. The crushed powder gypsum
is hauled off by a third party.

The new sheetrock shredding operation is composed of a large hopper that sits
above a grinder, a product recovery cyclone, an airlock, a screw auger, and a
gypsum collector unit. Waste sheetrock is fed into the large hopper, where it then
falls into the grinder to be mechanically crushed into a powdered gypsum
material. The material falls into an air stream, which pneumatically conveys the
material into a product recovery cyclone. The material collected by the cyclone
passes through an airlock into the screw conveyor and is deposited in a haul-off
dumpster. The cyclone is not considered a control technology because the
cyclone is integral to the sheetrock shredding process; thus, the cyclone is
considered as being a part of the process.

The air that is separated from the gypsum powder in the product recovery
cyclone is sent through a filter baghouse that achieves 95% a reduction in
particulate matter emissions.

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 September 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: August 24, 2024

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

DAQE-

RN125380010 August 9, 2024 Jacob Coulson Liberty Safe and Security Products, Inc. 1199 West Utah Ave Payson, UT 84651
[e-mail] Dear Jacob Coulson,
Re: Engineer Review: Modification to Approval Order DAQE-AN125380008-19 to Add a Sheetrock Shredding Operation
Project Number: N125380010 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. Liberty Safe and Security Products, Inc. should complete this review within 10 business days of receipt.
Liberty Safe and Security Products, Inc. should contact Katie Andersen at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Liberty Safe and Security Products, Inc. does not respond to this letter within 10 business days, the
project will move forward without source concurrence. If Liberty Safe and Security Products, 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 N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N125380010 Owner Name Liberty Safe and Security Products, Inc. Mailing Address 1199 West Utah Ave Payson, UT, 84651 Source Name Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant Source Location 1199 West Utah Ave Payson, UT 84651
UTM Projection 435,794 m Easting, 4,432,755 m Northing UTM Datum NAD83
UTM Zone UTM Zone 12 SIC Code 3499 (Fabricated Metal Products, NEC)
Source Contact Jacob Coulson Phone Number [phone] Email [e-mail]
Billing Contact Jacob Coulson Phone Number [phone] Email [e-mail] Project Engineer Katie Andersen, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 4, 2024 Date of Accepted Application July 12, 2024

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 2
SOURCE DESCRIPTION General Description
Liberty Safe and Security Products, Incorporated (Liberty Safe) owns and operates a safe and gun vault manufacturing plant in Payson, Utah County.
The safes are cut, formed, and folded from rolled coil steel, then welded together in the metal shop. After forming and welding, the safes are placed on a metal prep line for grinding and sanding. The safes are then conveyed through a 5-stage washer to be cleaned. After exiting the
washer, the safes are oven dried before entering into either one of two powder coating booths or one of two wet coating booths for surface coating.
Some safes are painted with a primer, baked, sanded, top coated with liquid paint and baked while others are painted directly with a powder coating. Each powder booth is vented to a cartridge filtering system that recirculates filtered exhaust air back into the building. There are no
VOCs present in the powder coating process. Powder coated safes are conveyed to a curing oven, and transferred into the final assembly area to be finished. The safes that have been painted with a primer are conveyed to a sanding booth. After sanding, they receive a final coat of automotive quality wet paint. They are then hand-sprayed with a coat of glossy paint in one of several colors. The wet painted safes are conveyed through a drying oven and allowed to air-dry. Paint overspray and VOC emissions are pulled through each booth's bank of paint particulate filters. All of the paint booths are equipped with paint arrestor filters.
The VOCs pass through the filters and are vented through each booth's exhaust stack. NSR Classification:
Minor Modification at Minor Source Source Classification
Located in the Southern Wasatch Front O3 NAA and Provo UT PM2.5 NAA Utah County Airs Source Size: B
Applicable Federal Standards MACT (Part 63), A: General Provisions
MACT (Part 63), XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories Project Proposal Modification to Approval Order DAQE-AN125380008-19 to Add a Sheetrock Shredding
Operation Project Description
Liberty Safe is proposing to install a sheetrock shredding operation to convert used sheetrock slabs to a crushed gypsum powder.
Liberty Safe uses sheetrock as a fire retardant in their safe manufacturing process. With the current system, the sheetrock is shaped with a wet-jet cutting system and the excess sheetrock is hauled away via a 3rd party. The installation of the sheetrock shredder allows Liberty Safe to
process the waste material into a crushed powder for disposal. The crushed powder gypsum is

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 3
hauled off by a 3rd party.
The new sheetrock shredding operation is composed of a large hopper that sits above a grinder, a product recovery cyclone, an airlock, a screw auger, and a gypsum collector unit. Waste sheetrock is fed into the large hopper where it then falls into the grinder to be mechanically
crushed into a powdered gypsum material. The material falls into an air stream which pneumatically conveys the material into a product recovery cyclone. The material collected by the cyclone passes through an airlock into the screw conveyor and is deposited into a haul-off
dumpster. The cyclone is not considered a control technology because the cyclone is integral to the sheetrock shredding process; thus, the cyclone is considered as being a part of the process. The air that is separated from the gypsum powder in the product recovery cyclone is sent through a filter baghouse that achieves 95% reduction of particulate matter emissions. EMISSION IMPACT ANALYSIS All criteria and HAPs pollutant increases are below the modeling thresholds contained in R307-410-4 and R307-410-5. Therefore, modeling is not required for this modification. [Last updated July 17, 2024]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 4
SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 16426.36
Carbon Monoxide 0 4.73
Nitrogen Oxides 0 10.47
Particulate Matter - PM10 0.76 1.77
Particulate Matter - PM2.5 0.76 1.77
Sulfur Oxides 0 0.11 Volatile Organic Compounds 0 33.70 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethyl Benzene (CAS #100414) 0 2020
Generic HAPs (CAS #GHAPS) 0 2140
Methanol (CAS #67561) 0 140
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 8028 Naphthalene (CAS #91203) 0 3700 Styrene (CAS #100425) 0 241
Toluene (CAS #108883) 0 6940
Xylenes (Isomers And Mixture) (CAS #1330207) 0 8580
Change (TPY) Total (TPY)
Total HAPs 0 15.89
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 5
Review of BACT for New/Modified Emission Units 1. BACT review regarding New Equipment
A BACT analysis was conducted on the Sheetrock Shredder and Gypsum Recovery process. Shredder
Emissions from the shredder include fugitive PM10 and PM2.5 emissions. These emissions will be low in volume (less than 0.2 tpy, each). The fugitive PM10 and PM2.5 emissions will not be vented outdoors. Therefore, a BACT analysis is not required. The other emissions from the shredder are directed into the Gypsum Recovery Process. Gypsum Recovery Process PM10/PM2.5 The gypsum recovery process has the potential to emit PM10 and PM 2.5 emissions. The following
have been identified for PM10 and PM2.5 emission control for this type of operation: electrostatic precipitators, fabric filters, wet scrubbers, and cyclones. The use of fabric filters, cyclones, and electrostatic precipitators is technically feasible to control emissions from the gypsum recovery
process. The wet scrubber is technically infeasible due to the mixture of gypsum and water creating a very sticky sludge which would cause haul away and disposal issues. The sludge would also clog the systems and render it dysfunctional. The cyclone was eliminated because the process currently relies on a cyclone to recover gypsum, thus the cyclone is not considered a control device. An additional cyclone will not improve the control efficiency necessary for efficient operation. The electrostatic precipitator was eliminated because they are typically used in high volume gas streams to remove ash and dust. Liberty Safe anticipates a low volume of air and a low level of emissions associated with the gypsum recovery process. Thus, the electrostatic precipitator would be economically infeasible. The DAQ considers the use of filter fabrics with at least a 95% efficiency and a 10% opacity
limitation as BACT for the Gypsum Recovery Process. The fabric filter will reduce PM10 and PM2.5 emissions from 3.13 tpy to 0.12 tpy. Fugitive Emissions PM10/PM2.5
Fugitive emissions are expected to come from the unloading of the material from the airlock of the product cyclone through a screw auger to be disposed of in a dumpster. Due to an inconsistent and low volume of PM10/PM2.5 emissions from unloading operations (less than 0.5 tpy, each), there are
no economically feasible add-on control options for these emissions. Therefore, BACT is best operating practices. The DAQ considers minimizing the fall distance of the material into the dumpster, preventing cross winds on the dumping steps, and a 15% opacity limitation (as required by R307-309-4) as
BACT for Fugitive Emissions. [Last updated July 22, 2024]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 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 Manufacturing Plant Safe and Security Products

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 7
II.A.2 Paint Booth A Equipment ID: WPB-A#1 Emission Point ID: WPB-A#1 System: High End Wet Coat
II.A.3 Paint Booth B Equipment ID: WPB-B#1 Emission Point ID: WPB-B#1
System: High End Wet Coat II.A.4 Paint Booth C Equipment ID: WPB-C#1
Emission Point ID: WPB-C#1 System: High End Wet Coat
II.A.5 Paint Booth D
Equipment ID: WPB-D#1 Emission Point ID: WPB-D#1 System: High End Wet Coat

II.A.6 Paint Booth E Equipment ID: WPB-E#1 Emission Point ID: WPB-E#1
System: High End Wet Coat
II.A.7 Paint Booth F Equipment ID: WPB-F#1 Emission Point ID: WPB-F#1
System: High End Wet Coat II.A.8 Paint Booth G Equipment ID: WPB-G#1
Emission Point ID: WPB-G#1 System: High End Wet Coat
II.A.9 Primer Booth H
Equipment ID: WCTUB#1 Emission Point ID: WCTUB#1 System: High End Wet Coat

II.A.10 Powder Coating Booth Equipment ID: PB#1 Emission Point ID: Discharges to PCS#1
System: CN Line

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 8
II.A.11 Powder Coating Dust Collector and Cyclone Sep. Equipment ID: PCS#1 Emission Point ID: PDC#1 System: CN Line *Noted for informational purposes only as this system discharges inside the building.
II.A.12 Secondary Powder Coat Dust Collector and Baghouse Equipment ID: PDC#1
Emission Point ID: Discharge into Building System: CN Line *Noted for informational purposes only.
II.A.13 Powder Coating Booth A#2 Equipment ID: PB-A#2 Emission Point ID: PCS-A#2
System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.14 Powder Coating Dust Collector and Cyclone Sep. A#2
Equipment ID: PCS-A#2 Emission Point ID: PDC-A#2 System: High Volume Powder Coat
*Noted for informational purposes only as this system discharges inside the building. II.A.15 Secondary Pwdr Coating Dust Collector, Cyclone A#2 Equipment ID: PDC-A#2
Emission Point ID: Discharge into Building System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.

II.A.16 Powder Coating Booth B#2 Equipment ID: PB-B#2 Emission Point ID: PCS-B#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.17 Powder Coating Dust Collector and Cyclone Sep B#2 Equipment ID: PCS-B#2 Emission Point ID: PDC-B#2 System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.
II.A.18 Secondary Pwdr Coat Dust Collector, Baghouse B#2 Equipment ID: PDC-B#2 Emission Point ID: Discharge into Building
System: High Volume Powder Coat *Noted for informational purposes only as this system discharges inside the building.

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 9
II.A.19 Wood Cutting System with Dust Collector Equipment ID: RWDC#1 Emission Point ID: RWDC#1 System: CN Line *Noted for informational purposes only as this system discharges inside the building.
II.A.20 Cure Oven #1 with Burner Equipment ID: WCOB#1
Emission Point ID: WCOE#1 A,B, & C Maximum Burner Rating: 3.0 MMBTU/hr System: High End Wet Coat Fuel Type: Natural Gas II.A.21 Cure Oven #2 with Burner Equipment ID: WCOB#2
Emission Point ID: WCOE#2 A,B, & C Maximum Burner Rating: 3.0 MMBTU/hr System: High End Wet Coat Fuel Type: Natural Gas II.A.22 Sanding Booth #1 Equipment ID: WSB#1
Equipment ID: WSBE#1 A,B, & C Control Equipment: Dust Control Filters System: High End Wet Coat

II.A.23 Sanding Booth #2 Equipment ID: WCOB#2 Emission Point ID: WCOE#2 A,B, & C
Control Equipment: Dust Control Filters System: High End Wet Coat
II.A.24 Paint Kitchen #1 Enclosed Room for Paint Storage Equipment ID: PKE#1 Emission Point ID: PKE#1
System: High End Wet Coat II.A.25 Metal Water Wash System with Boiler Equipment ID: WSB#1 Emission Point ID: WSE-A#1 and WSE-B#1 System: CN Line One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr Fuel Type: Natural Gas

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 10
II.A.26 Dry-Off/Cure Combo Oven with Burners Equipment ID: PCOB#1 Emission Point ID: PCOE#1 System: CN Line
Maximum Equipment Rating: 4.0 MMBTU/hr
Fuel Type: Natural Gas II.A.27 Metal Water Wash System with Boiler Equipment ID: WSB#2
Emission Point ID: WSE-A#2 and WSE-B#2 System: High Volume Powder Coat One (1) Boiler Maximum Equipment Rating: 4.25 MMBTU/hr Fuel Type: Natural Gas
II.A.28 Dry-Off/Cure Combo Oven with Burners Equipment ID: PDOB#2 Emission Point ID: PCOE-A#2 and PCOE-B#2
System: High Volume Metal Shop Maximum Equipment Rating: 7.6 MMBTU/hr (Includes 2 - 2.4 MMBTU/hr and 1 - 2.8 MMBTU/hr burners) Fuel Type: Natural Gas

II.A.29 Burn-Off Oven with Burners Equipment ID: BOO#1 Emission Point ID: BOO#1
System: High Volume Powder Coat Equipment:
Two (2) Burners Maximum Equipment Rating: 0.48 MMBTU/hr (each) Fuel Type: Natural Gas
II.A.30 Comfort Heaters Various natural gas fueled comfort heating devices rated less than 5 MMBtu/hr - each Listed for information purposes only.
II.A.31 Baghouse #1 Type: Pulse Jet Equipment ID: WJDC-#1 Emission Point ID: Discharges into Building Equipment Location: Water Jet Room System *Noted for informational purposes only.

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 11
II.A.32 Water Jet Cutter A Equipment ID: WJC-A Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1
II.A.33 Water Jet Cutter B Equipment ID: WJC-B
Emission Point ID: Discharges to WJDC-#1 Equipment Location: Water Jet Room Control Equipment: Baghouse #1
II.A.34 Two (2) Robotic Welders and Hoods Equipment ID: WDC#1 Emission Point ID: Dust Collector
System: CN Line *Noted for informational purposes only as the system discharges internally
II.A.35 Robotic Welder with Smoke/Dust Collector A
Equipment ID: WDC-A Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop
*Noted for informational purposes only. II.A.36 Robotic Welder with Smoke/Dust Collector B Equipment ID: WDC-B
Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.

II.A.37 Back Square Tack Welder with Smoke/Dust Collect C Equipment ID: WDC-C Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.38 Face Corner Welder with Smoke/Dust Collector D Equipment ID: WDC-D Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.39 Door Build Welder with Smoke/Dust Collector E Equipment ID: WDC-E Emission Point ID: Discharges into Building
Equipment Location: High Volume Metal Shop *Noted for informational purposes only.

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 12
II.A.40 Door Build Welder with Smoke/Dust Collector F Equipment ID: WDC-F Emission Point ID: Discharges into Building Equipment Location: High Volume Metal Shop *Noted for informational purposes only.
II.A.41 Grinders Equipment ID: PGA#1
Emission Point ID: Discharges into Building System: CN Line *Noted for informational purposes only.
II.A.42 Infrared Pre-Cure Oven Equipment ID: IPCO#1 Emission Point ID: Discharges to Building
System: High Volume Powder Coat *Noted for informational purposes only as unit uses infrared heating.
II.A.43 Spray/Bake Combo Oven with Burner
Equipment ID: VDP-A Emission Point ID: VDP-A#1 System: Vault Door Line
Control Equipment: Dust Control Filters One (1) Burner Maximum Equipment Rating: 1.44 MMBtu/hr Fuel Type: Natural Gas

II.A.44 Sanding Booth
Equipment ID: VDS-A System: Vault Door Line *Noted for informational purposes only as this system discharges inside the building.
II.A.45 NEW One (1) Sheetrock Shredder (NEW) Emission Unit ID: SS-1 System: Gypsum Collection
Control: Baghouse (95% PM10 control efficiency)
SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 The Safe Manufacturing Plant shall be subject to the following limitations:

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 13
II.B.1.a NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Paint spray booth exhaust stacks - 10% opacity B. Powder coating booth exhaust stacks - 10% opacity
C. Sanding booth exhaust stacks - 10% opacity
D. Boiler and natural gas fired burner exhaust stacks - 10% opacity
E. Sheetrock Shredder Baghouse - 10% opacity F. Fugitive Emissions - 15% opacity G. All other points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b NEW The owner/operator shall not produce more than 3,120 tons of powdered gypsum material per rolling 12-month period. [R307-401-8]
II.B.1.b.1 NEW The owner/operator shall: A. Determine production by scale house records, belt scale records, or manifest
statements
B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 month
D. Keep the production records for all periods the plant is in operation. [R307-401-8]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 14
II.B.1.c NEW The owner/operator shall not emit more than the following from all coating, painting, and other non-combustion processes: A. 33.70 tons per rolling 12-month period for VOCs B. 4.29 tons per rolling 12-month period for Xylene
C. 4.01 tons per rolling 12-month period for Methyl Isobutyl Ketone
D. 3.47 tons per rolling 12-month period for Toluene
E. 1.85 tons per rolling 12-month period for Naphthalene F. 1.00 tons per rolling 12-month period for Ethyl Benzene G. 0.12 tons per rolling 12-month period for Styrene H. 0.07 tons per rolling 12-month period for Methanol I. 14.82 tons per rolling 12-month period for all combined HAPs. [R307-401-8]
II.B.1.c.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 this mass-balance method: VOCs = [%VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [%HAP by Weigh/100] x [Density] x [Volume Consumed]. [R307-401-8]
II.B.1.c.2 NEW The owner/operator shall maintain records of each month of the following for VOC- and/or HAP- emitting materials: A. Name of the VOC- or HAP-emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon) C. Percent by weight of each VOCs or HAPs in each material used D. Gallons of each VOC- or HAP-emitting material used E. The amount of VOCs or HAPs emitted monthly from each material used F. The amount of VOCs, or HAPs reclaimed for the month shall be similarly quantified
and subtracted from the quantities calculated above to provide the monthly total VOC,
or HAP emissions G. VOC or HAP emissions from the fuel burning devices (products of incomplete
combustion generated by the comfort heating devices) are NOT included in the above
total. [R307-401-8]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 15
II.B.1.d NEW The owner/operator shall use particulate filters to control particulate emissions from the spray booths and powder coating booths. All exhaust air from the spray booths and powder coating booths shall be routed through the particulate filters, installed in each booth, prior to being vented to the atmosphere. [R307-401-8]
II.B.1.e NEW The owner/operator shall ensure that all paint and solvent drums or containers are closed/sealed while not in use in Paint Kitchen #1. Additionally, only two drums shall be open at any one time in Paint Kitchen #1. [R307-401-8]

II.B.1.f NEW The following equipment and their associated collection/emission points shall be vented or routed back into the safe manufacturing building: 1) Water Jet Cutter A - WJC-A; 2) Water Jet Cutter B - WJC-B; 3) Baghouse #1 - WJDC-#1;
4) Robotic Welders and Hoods - WDC#1;
5) Robotic Welder with Smoke/Dust Collector A - WDC-A;
6) Robotic Welder with Smoke/Dust Collector B - WDC-B; 7) Back Square Tack Welder with Smoke/Dust Collector C - WDC-C; 8) Face Corner Welder with Smoke/Dust Collector D - WDC-D; 9) Door Build Welder with Smoke/Dust Collector E - WDC-E; 10) Door Build Welder with Smoke/Dust Collector F - WDC-F;
11) Powder Coating Booth PB#1, Dust Collector and Cyclone Separator - PCS#1, Secondary
Powder Coat Dust Collector and Baghouse - PDC#1; 12 Powder Coating Booth - A#2, Powder Coating Dust Collector and Cyclone Separator - A#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-A#2; 13) Powder Coating Booth - B#2, Powder Coating Dust Collector and Cyclone Separator - B#2, Secondary Powder Coat Dust Collector and Baghouse - PDC-B#2. 14) Grinders - CN Line - PGA#1; 15) Infrared Pre-Cure Oven - High Volume Powder Coat - IPCO #1; 16) Sanding Booth - Vault Door Line - VDS-A; 17) Sheetrock Shredder - SS-1. [R307-401]
II.B.1.g NEW The owner/operator shall comply with all applicable requirements of UAC R307-350 for Miscellaneous Metal Parts and Products Coatings. [R307-350]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 16
II.B.2 Fuel Combustion Requirements
II.B.2.a The owner/operator shall only use natural gas as fuel in all on-site equipment. [R307-401-8]

II.B.2.b NEW The owner/operator shall not consume more than 239,823 decatherms of natural gas per rolling 12-month period. [R307-401-8]
II.B.2.b.1 NEW The owner/operator shall: A. Determine fuel consumption by examination of fuel supplier billing records B. Record fuel consumption on a monthly basis. C. Use the monthly consumption data to calculate a new 12-month total by the 20th
day of each month using data from the previous 12 months. D. Keep records of fuel consumption for all periods when the plant is in operation. [R307-401-8]
II.B.3
NEW
Sheetrock Shredder Baghouse and Spray/Powder Coating Booth Particulate Filter Conditions
II.B.3.a NEW The owner/operator shall control particulate emissions from the Sheetrock Shredder with a baghouse. [R307-401-8]
II.B.3.b NEW The owner/operator shall install a baghouse on the Sheetrock Shredder with a PM10 control efficiency of no less than 95%. [R307-401-8]
II.B.3.b.1 NEW To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's control efficiency guarantee for the installed baghouse. [R307-401-8]

II.B.3.c NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the Sheetrock Shredder baghouse and across each spray and powder coating booth particulate filter. [R307-401-8]

II.B.3.c.1 NEW Each pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.3.c.2 NEW Each pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8]

II.B.3.d NEW During operation of the Sheetrock Shredder baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operation. [R307-401-8]

II.B.3.d.1 NEW The owner/operator shall record the pressure drop at least once per operating day while the Sheetrock Shredder baghouse is operating. [R307-401-8]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 17
II.B.3.d.2 NEW The owner/operator shall maintain the following records of the pressure drop readings of the Sheetrock Shredder baghouse: A. Unit identification B. Manufacturer recommended static pressure drop for the unit
C. Date of reading
D. Daily static pressure drop readings. [R307-401-8]

II.B.3.e
NEW
At least once every 12 months, the owner/operator shall calibrate the Sheetrock Shredder
baghouse pressure gauge in accordance with the manufacturer's instructions or replace the gauge. [R307-401-8]
II.B.3.e.1
NEW
The owner/operator shall maintain records of the pressure gauge calibrations and
replacements. [R307-401-8] II.B.3.f NEW The owner/operator shall replace the particulate filters in the spray booths and powder coating booths when the pressure differential exceeds manufacturer's recommended operating ranges.
[R307-401-8]
II.B.3.f.1 NEW The owner/operator shall record the pressure drop weekly for each spray and powder coating booth in operation. [R307-401-8]
II.B.3.f.2
NEW
The owner/operator shall maintain records of the spray booth and powder coating booth
particulate filter replacements. [R307-401-8] II.B.3.f.3 NEW The owner/operator shall maintain the following records of the pressure drop readings of the spray and powder coating booths:
A. Booth identification B. Weekly pressure drop readings C. Date of reading D. Date of particulate filter replacement. [R307-401-8]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 18
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN125380008-19 dated March 11, 2019
Is Derived From NOI dated June 4, 2024 Incorporates Additional Information dated July 12, 2024
REVIEWER COMMENTS 1. Comment regarding Minor Modification at a Minor Source: Liberty Safe requested this minor modification to add a sheetrock shredding operation to their site.
For this modification, the Summary of Emissions table, the Approved Equipment list, and the Requirements and Limitations section have been updated to reflect the modification and new associated requirements. In addition to this modification the language and format of the following
conditions has been updated to reflect current DAQ standards: II.B.1.b, II.B.1.b.1, II.B.1.b.2, II.B.1.c, II.B.1.d, II.B.2.b, and II.B.2.b.1. [Last updated July 17, 2024] 2. Comment regarding Emission Calculations: Emissions were estimated for the sheetrock shredder, gypsum collection cyclone, and the control
baghouse. PM10 from the shredder were estimated using AP-42 Table 11.16-2, EPA Fire Emission Factors, and manufacturer data. PM10 emissions from transferring and conveying the gypsum were estimated from emission factors found in EPA FIRE and manufacturer data. Calculations were done
assuming a maximum hourly throughput of 1,500 lbs. Assuming 20 hours of operation per day for 4 days a week and 52 weeks per year, this equates to a maximum annual throughput of 3,120 tons of gypsum. The baghouse has a PM control efficiency of 95%. The total increase in controlled PM10
emissions is estimated to be 0.76 tpy. PM2.5 emissions were estimated to be equal to the PM10 emissions. Fugitive emissions from the shredder were calculated but are provided for informational purposes only as they are emitted into the building. These emissions are estimated to be 0.17 tpy of PM10, and
0.17 tpy of PM2.5. Other fugitive emissions result from loading the product into a dumpster and equal 0.47 tpy of PM10, and 0.47 tpy of PM2.5. [Last updated July 22, 2024] 3. Comment regarding NSPS and MACT Applicability: NSPS 40 CFR 60 NSPS Subpart EE - Standards of Performance for Surface Coating of Metal Furniture 40 CFR 60 Subpart EE applies to facilities where organic coatings are applied to metal furniture and where more than 3,842 liters of coating are applied per year. Metal furniture means furniture or components of furniture constructed either entirely or partially from metal. A definition of metal
furniture is not included in NSPS Subpart EE, so the definition in 40 CFR 63 Subpart RRRR was used. Metal furniture in 40 CFR 63 Subpart RRRR includes but is not limited to components of the following types of products as well as the products themselves: household, office, institutional,
laboratory, hospital, public building, restaurant, barber and beauty shop, and dental furniture; office and store fixtures; partitions; shelving; lockers; lamps and lighting fixtures; and wastebaskets. Liberty Safe manufactures gun vaults and safes, which do fall under the definition of metal furniture

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 19
in this Subpart. Therefore, NSPS 40 CFR 60 Subpart EE does not apply to this source.
40 CFR 60 NSPS Subpart OOO- Standards of Performance for Nonmetallic Mineral Processing Plants 40 CFR 60 Subpart OOO applies to each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading station at a facility. Facilities are exempt from this subpart if the capacities are less than 25 tons per hour. Liberty Safe has one (1) crusher for the sheetrock shredding operations with a maximum production of 1,500 pounds per hour (0.75 tons per hour). Therefore, NSPS 40 CFR 60 Subpart OOO does not apply to this source.
MACT 40 CFR 63 MACT Subpart RRRR - National Emission Standards for Hazardous Air Pollutants for
Surface Coating of Metal Furniture 40 CFR 63 Subpart RRRR applies to metal furniture coating facilities that emit 10 tons per year of any single HAP or 25 tons per year of any combination of HAPs. Liberty Safe emissions fall below the thresholds for major HAPs source and is therefore, not subject to MACT 40 CFR 63 Subpart RRRR.
40 CFR 63 MACT Subpart MMMM - National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products This subpart applies to owners or operators of new, reconstructed, or existing affected sources that use 946 liters (250 gallons) per year or more of coatings that contain HAPs in the surface coating of miscellaneous metal parts and products; and that are major sources of HAPs. This source is not considered a major source of HAPs; therefore, MACT Subpart MMMM does not apply to this facility. 40 CFR 63 MACT Subpart XXXXXX - National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories
40 CFR 63 Subpart XXXXXX apply to sources that are primarily engaged in one of the nine listed source categories. Category 2 is Fabricated Metal Products and is defined in the subpart as "establishments primarily engaged in manufacturing fabricated metal products, such as fire or burglary resistive steel safes and vaults and similar fire or burglary resistive products; and collapsible tubes of thin flexible metal. Also, establishments primarily engaged in manufacturing powder metallurgy products, metal boxes; metal ladders; metal household articles, such as ice cream freezers and ironing boards; and other fabricated metal products not elsewhere classified". Liberty Safe manufactures gun vaults and safes, which falls under the listed source categories in this Subpart. Therefore, MACT Subpart XXXXXX applies to the source. [Last updated August 9, 2024]
4. Comment regarding State Rule Applicability: R307-347 applies to large appliance surface coating operations located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties. Large appliance means doors, cases, lids, panels, and
interior support parts of residential and commercial washers, dryers, ranges, refrigerators, freezers, water heaters, dishwashers, trash compactors, air conditioners, and other similar products. The safes and gun vaults manufactured by Liberty Safe and Supply do not fit into this category, so R307-347
does not apply to this source. R307-350 applies to any facility using more than 20 gallons/yr of coating products and associated solvents and any industrial category that coats metal parts or products under the standard Industrial Classification Code (ICC) of major group 34 (fabricated metal products). Liberty Safe uses more

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 20
than 20 gallons/yr of coating products and associated solvents and falls under this ICC. Therefore, R307-350 applies to this source.
R307-325 applies to all sources located in any nonattainment or maintenance area for ozone. Liberty Safe is located in the Southern Wasatch Front Ozone Nonattainment Area. Therefore, R307-325 applies to the source. [Last updated July 22, 2024] 5. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source; 2. Any source subject to a standard, limitation, or other requirements under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants; 4. Any Title IV affected source. This source is not a major source nor a Title IV affected source. This source is not subject to 40 CFR 60 (NSPS) nor 40 CFR 61 (NESHAP) requirements. The source is subject to 40 CFR 63 (MACT) Subpart XXXXXX, which exempts a source from the obligation to obtain a Title V permit. There are no other reasons why this source would be required to obtain a Title V permit; therefore, Title V does not apply to this source. [Last updated August 9, 2024]

Engineer Review N125380010: Liberty Safe and Security Products, Inc.- Payson Manufacturing Plant August 9, 2024 Page 21
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
Table #1 -Emission Summary
Appendix A - Emission Calculations
Liberty Safe and Security Products, Inc
Payson, Utah
lb/hr tpy lb/hr tpy lb/hr tpy
Shredder - Fugitive SS-1 SS-Fug 0.098 0.203 0.083 0.172 0.083 0.172
Shredder - Filter SS-1 SS-Filter 1.634 3.398 1.505 3.129 1.505 3.129
Dumpster Conveyance SS-1 SS-Convey 0.225 0.468 0.225 0.468 0.225 0.468
1.956 4.068 1.812 3.769 1.812 3.769
lb/hr tpy lb/hr tpy lb/hr tpy
Shredder - Fugitive SS-1 SS-Fug 0.098 0.203 0.083 0.172 0.083 0.172
Shredder - Stack SS-1 SS-Filter 0.066 0.136 0.060 0.124 0.060 0.124
Dumpster Conveyance SS-1 SS-Convey 0.225 0.468 0.225 0.468 0.225 0.468
0.388 0.807 0.367 0.764 0.367 0.764

Emissions

Increases

Emissions
Tons / yr Tons / yr Tons / yr
PM10 Total 0.990 0.764 1.754
PM10 Fugitive 0.000 0.640 0.640
PM2.5 0.990 0.764 1.754
Nox 14.930 0.000 14.930
SO2 0.110 0.000 0.110
CO 4.620 0.000 4.620
VOC 33.700 0.000 33.700
VOC Fugitive 0.000 0.000 0.000
CO2e 16,423 0 16,423
*Refer to Form 5 in Appendix B for the completed emission increase summary
Emission Point
Total
Criteria Pollutant
Summary
Total
PTE With Controls for New Sources
Emission Source Emission Unit PM PM10 PM2.5
PTE for New Sources
Emission Source Emission Unit Emission Point PM PM10 PM2.5
Table #2 - Shredder Emission Calculations
Appendix A - Emission Calculations
Liberty Safe and Security Products, Inc
Payson, Utah
1,500 lb/hr
3,120 tpy 20 hours a day, 4 days a week, 52 weeks a year
Process Pollutant EF Units Source
PM 2.600 lb/ton product SCC 3-05-015-02
PM10 2.200 lb/ton product SCC 3-05-015-02
Transfer PM 2.00 lb/ton product SCC 3-02-005-02
PM 0.150 lb/ton product SCC 3-05-015-04
# Transfers 2
Shredder Capture1 95%Got the manufacturer's statement to back this. AKA. 5% goes into the air
Cyclone PM10 - Control2 60%Fair assumption, based on conversation with Alan.
Baghouse PM10 - Control3 95%verified against manufacturer specs
1 95% removal efficiency per manufacturer statement
2 Removal eficiency for a medium efficiency cyclone per MPCA control equipment standard
3 Per manufacturer specification sheet
Potential To Emit Good. Good. Good
Pollutants Shredder Conveyor Drops Exhaust from Cyclone Total Units
PM 0.098 0.225 1.311 1.634
PM10 0.083 0.225 1.197 1.505
PM 0.203 0.468 2.727 3.398
PM10 0.172 0.468 2.490 3.129
Potential To Emit with Controls
Pollutants Shredder Conveyor Drops Exhaust from Filter Total Units
PM 0.098 0.225 0.066 0.388
PM10 0.083 0.225 0.060 0.367
PM 0.203 0.468 0.136 0.807
PM10 0.172 0.468 0.124 0.764
lb/hr
ton/yr
lb/hr
ton/yr
Emission Factor
Throughput
Shredder
Conveyor
Table 11.16-2 checked against AP-42 and EPA FIRE
checked against AP-42 and EPA FIRE
checked against AP-42 and EPA FIRE
checked against AP-42 and EPA FIRE
as fugitive emissions

135 Vista Centre Dr
Forest, VA 24551-3964
Phone [phone]
Fax [phone]
www.sterlingblower.com

SHAKER FELT FILTER BAG SPECIFICATION

CONSTRUCTION: Unsupported needle felt

COMPOSITION: 100% Polyester singed one side

WEIGHT: 8.00-10.00 oz. / yd2

THICKNESS: 0.035” – 0.055”

AIR PERMEABILITY: 90 -120 CFM @ ½” WG

EFFICIENCY: 95% @ 10 micron

MINIMUM MULLEN BURSTING STRENGTH: 250 lbs. / in2

Katie Andersen <[e-mail]>
Liberty Safe DAQ NOI Application
4 messages
Katie Andersen <[e-mail]>Thu, Aug 1, 2024 at 12:27 PM
To: "Larson, Chris" <[e-mail]>, Jacob Coulson <[e-mail]>
Hello Chris and Jacob,
I wanted to provide you with an update on the NOI application that was submitted for Liberty Safe. The draft permit has
been written and is going through the process of internal reviews. During one of the reviews, our Compliance group noted
some differences/clarifications in equipment and processes from their latest inspection. Below you will find their inspection
comments.
Additional equipment and process information gathered at the time of inspection:
II.A.9 Paint Booth H is a primer booth.
II.A.19 Wood Cutting System with Dust Collector is controlled by a Donaldson Torit dust collector that vents internally.
II.A.22 Sanding Booth #1 and II.A.23 Sanding Booth #2 only one sanding booth is currently in use.
II.A.24 Paint Kitchen #1 is a completely enclosed room used for paint storage rather outdoors.
II.A.25 Metal Water Wash System with Boiler and II.A.26 Dry-Off/Cure Combo Oven with Burners are a single unit.
II.A.27 Metal Water Wash System with Boiler - is equipped with a 5 MMBtu/hr Rite-brand Boiler.
II.A.29 Burn-Off Oven with Burners is equipped with a primary burner and an afterburner.
II.A.31 Baghouse #1 is a pulse jet baghouse. The magnehelic gauge was observed to be at 4.8 inches of water column at
the time of inspection.
II.A.34 Two (2) Robotic Welders and Hoods vent into a dust collector before being discharged back into the building.
II.A.37 Dack Square Tack Welder with Smoke/Dust Collect C has some typos. It should read Back Square Tack Welder
with Smoke/Dust Collector C.
All hand welding and grinding operations are controlled by vacuum dust collection systems that vent internally.
The source also operates two compliant parts washers that utilize Safety-Kleen
Armakleen 4 in 1 cleaning solution.
Would you like to update the permit to reflect these differences/clarifications? If so, would you provide additional
information as necessary or how you would like the changes to be reflected in the new AO?
Cheers,
Katie Andersen
--

8/8/24, 2:55 PM State of Utah Mail - Liberty Safe DAQ NOI Application
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r283547668370174502&simpl=msg-a:r8988400479971690…1/5
Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Larson, Chris <[e-mail]>Tue, Aug 6, 2024 at 9:23 AM
To: Katie Andersen <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Katie,

Thanks for chatting yesterday. As we discussed, if it is possible we would like to administratively address the
items that can be done through an administrative update in this permit as to expedite the issuance for the
sheetrock shredder. I have indicated in the response to the previous email which ones we’d like to address
now.

As discussed yesterday, the site did exceed styrene emissions from painting earlier this year which was
sent to UDAQ compliance as a notice of deviation. The site has since stopped using that paint and are
tracking to get back into compliance for styrene once the 12-month window rolls through. We have a plan to
submit a permit modification to give the site more painting flexibility in the current booths and adjust the
current limits. There won’t be any new construction at this time associated with these changes, just creating
more favorable limits based on current operations. At that time, we would plan to address those other
changes from the list below.

Please let us know if this is agreeable and/or if compliance has any thoughts on it.

Chris Larson, PE (MN, TX)
Project Engineer I Regulatory Compliance

13400 15th Ave N Suite A I Minneapolis, MN 55441
D [phone] I M [phone]
[e-mail] I Terracon.com

þ Please consider the environment before printing this email ü

8/8/24, 2:55 PM State of Utah Mail - Liberty Safe DAQ NOI Application
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r283547668370174502&simpl=msg-a:r8988400479971690…2/5
From: Kae Andersen <[e-mail]>
Sent: Thursday, August 1, 2024 1:27 PM
To: Larson, Chris <[e-mail]>; Jacob Coulson <[e-mail]>
Subject: Liberty Safe DAQ NOI Applicaon

Hello Chris and Jacob,

I wanted to provide you with an update on the NOI application that was submitted for Liberty Safe. The draft permit has
been written and is going through the process of internal reviews. During one of the reviews, our Compliance group noted
some differences/clarifications in equipment and processes from their latest inspection. Below you will find their inspection
comments.

Additional equipment and process information gathered at the time of inspection:

II.A.9 Paint Booth H is a primer booth. Administrative
II.A.19 Wood Cutting System with Dust Collector is controlled by a Donaldson Torit dust collector that vents internally.
Administrative
II.A.22 Sanding Booth #1 and II.A.23 Sanding Booth #2 only one sanding booth is currently in use. Will update with future
NOI
II.A.24 Paint Kitchen #1 is a completely enclosed room used for paint storage rather outdoors. Administrative
II.A.25 Metal Water Wash System with Boiler and II.A.26 Dry-Off/Cure Combo Oven with Burners are a single unit.
Administrative (can do with NOI if needed)
II.A.27 Metal Water Wash System with Boiler - is equipped with a 5 MMBtu/hr Rite-brand Boiler. Administrative (can do
with NOI if needed)
II.A.29 Burn-Off Oven with Burners is equipped with a primary burner and an afterburner. Administrative (can do with NOI
if needed)
II.A.31 Baghouse #1 is a pulse jet baghouse. The magnehelic gauge was observed to be at 4.8 inches of water column at
the time of inspection. Administrative
II.A.34 Two (2) Robotic Welders and Hoods vent into a dust collector before being discharged back into the building.
Administrative
II.A.37 Dack Square Tack Welder with Smoke/Dust Collect C has some typos. It should read Back Square Tack Welder
with Smoke/Dust Collector C. Administrative

All hand welding and grinding operations are controlled by vacuum dust collection systems that vent internally.
Administrative
The source also operates two compliant parts washers that utilize Safety-Kleen Will update with future NOI
8/8/24, 2:55 PM State of Utah Mail - Liberty Safe DAQ NOI Application
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r283547668370174502&simpl=msg-a:r8988400479971690…3/5
Armakleen 4 in 1 cleaning solution.

Would you like to update the permit to reflect these differences/clarifications? If so, would you provide additional
information as necessary or how you would like the changes to be reflected in the new AO?

Cheers,
Katie Andersen

--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered with
responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink, please e-mail
sender.
Katie Andersen <[e-mail]>Thu, Aug 8, 2024 at 2:28 PM
To: "Larson, Chris" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Chris,
I've heard back from Compliance. Updating the equipment in another NOI is acceptable. They wanted me to specifically
include that in the next NOI you will need to add in the Safety-Kleen parts washers.
The permit is almost through all of the internal review process. I am hopeful that I can send it to you for your review next
week.
Cheers,
Katie Andersen
8/8/24, 2:55 PM State of Utah Mail - Liberty Safe DAQ NOI Application
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r283547668370174502&simpl=msg-a:r8988400479971690…4/5
[Quoted text hidden]
--

[Quoted text hidden]
Larson, Chris <[e-mail]>Thu, Aug 8, 2024 at 2:32 PM
To: Katie Andersen <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Katie,

That’s fantastic. Thank you for the update. We will plan to remove the one sander and add in the parts
washers with the next NOI.
[Quoted text hidden]
8/8/24, 2:55 PM State of Utah Mail - Liberty Safe DAQ NOI Application
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r283547668370174502&simpl=msg-a:r8988400479971690…5/5
Katie Andersen <[e-mail]>
Re: NOI Submittal - Liberty Safe and Security
23 messages
Alan Humpherys <[e-mail]>Tue, Jun 4, 2024 at 10:28 AM
To: "Larson, Chris" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>, Jesse Enciso <[e-mail]>, "Steinbrueck, Leah D."
<[e-mail]>, Katie Andersen <[e-mail]>
Chris,
We received your application, and I assigned the project to Katie Andersen. She will reach out with any questions that she might have. If you
have any questions in the meantime, please let us know.
Thanks,
Alan
On Tue, Jun 4, 2024 at 8:42 AM Larson, Chris <[e-mail]> wrote:
Mr. Humphreys,

Liberty Safe has submitted a NOI through the ‘Submit NOI NSR’ link on the Air Permitting page of the UDAQ site. Attached is a copy of that
application for reference. The facility currently operates under Air Permit AN125380008-19 and is looking to install a sheetrock shredder for a
waste management project. A physical copy is being shipped to UDAQ via Fed Ex and will arrive later this week.

Liberty would like to work towards expediting this review and issuance of the permit. Per the Form 2 document in the application, I was
instructed to talk to you about working towards that. If you need anything additional from us regarding that request, please let me know.

Otherwise, If you have any questions, please don’t hesitate to reach out to myself or Mr. Jacob Coulson from Liberty (cc’d).

Thanks!

Chris Larson, PE (MN, TX)
Project Engineer I Regulatory Compliance

13400 15th Ave N Suita A I Minneapolis, MN 55441
D [phone] I M [phone]
[e-mail] I Terracon.com

þ Please consider the environment before printing this email ü

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered with responsiveness,
resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink, please e-mail sender.
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…1/11
--Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Katie Andersen <[e-mail]>Thu, Jun 6, 2024 at 9:46 AM
To: "Larson, Chris" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>, Jesse Enciso <[e-mail]>, "Steinbrueck, Leah D."
<[e-mail]>
Chris,
I've completed my preliminary review of the NOI application. It seems like all of the pieces are there. I will be starting my review for accuracy and
completeness and will let you know if I have questions. For now, will you please send me your spreadsheet where you completed your emission
calculations?
Cheers,
Katie Andersen
[Quoted text hidden]
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Larson, Chris <[e-mail]>Thu, Jun 6, 2024 at 10:16 AM
To: Katie Andersen <[e-mail]>
Cc: Jacob Coulson <[e-mail]>, Jesse Enciso <[e-mail]>, "Steinbrueck, Leah D."
<[e-mail]>
Katie,

That’s fantastic. Please see the attached spreadsheet for the emission calculations regarding the shredder.

If you have any other questions, please don’t hesitate to reach out.

Thanks,

Chris Larson, PE (MN, TX)
Project Engineer I Regulatory Compliance

7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…2/11
13400 15th Ave N Suita A I Minneapolis, MN 55441
D [phone] I M [phone]
[e-mail] I Terracon.com

þ Please consider the environment before printing this email ü

[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--

[Quoted text hidden]
Liberty - Appendix A - Emission calculations.xlsx
21K
Larson, Chris <[e-mail]>Mon, Jun 17, 2024 at 11:39 AM
To: Katie Andersen <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…3/11
Hi Katie,

Hope you’ve been well. I just wanted to check-in and see how the review was coming and if there were any questions you had
that I could answer at this time.

Thanks!

Chris
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Jun 25, 2024 at 2:11 PM
To: "Larson, Chris" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Hi Chris,
Apologies, I thought I clicked send on my response to your last email. Turns out the email was still a draft, and then I was out of town last week.
I've finished my review of the calculations. I noticed that the shredder's capture efficiency is based on the manufacturer's statement. Would you
mind sending that statement to me so that I can verify the statement and have it for our record? Or send me the link where I can find the
statement?
Once I have that, I will start writing the permit. From there, it will go through our internal review process before being sent to you for your review.
If you have any questions, please reach out.
Thank you!
Cheers,
Katie
[Quoted text hidden]
--

[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 3, 2024 at 2:58 PM
To: "Larson, Chris" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Hello Chris,
I'm following up with you regarding my request for the manufacturer's statement about the shredder's capture efficiency. In your calculation
submission, you note that the Shredder has a 95% capture efficiency per the manufacturer's statement. Can you send me documentation to
support this assumption?
Cheers,
Katie Andersen
[Quoted text hidden]
Larson, Chris <[e-mail]>Tue, Jul 9, 2024 at 11:59 AM
To: Katie Andersen <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
HI Katie,

7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…4/11
I apologize for the delay. Jacob (cc’d) was given that number over the telephone from the manufacturer, which was what we put
into the application. We were struggling to make contact with them over the holiday week to get it provided to us in a certificationstatement / email etc… We’re still trying to reach out though this week.

Would a verbal statement be sufficient for this application? Or will you need a certification statement from the manufacturer.

Thanks!

Chris Larson, PE (MN, TX)
Project Engineer I Regulatory Compliance

13400 15th Ave N Suita A I Minneapolis, MN 55441
D [phone] I M [phone]
[e-mail] I Terracon.com

þ Please consider the environment before printing this email ü

[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Jul 9, 2024 at 12:18 PM
To: "Larson, Chris" <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Chris,
I would prefer a written/certification statement so that it can be included in the project file. It is easier to defend the calculations and justify any
conditions when we have a written statement.
Cheers,
Katie
[Quoted text hidden]
--

[Quoted text hidden]
Larson, Chris <[e-mail]>Tue, Jul 9, 2024 at 12:59 PM
To: Katie Andersen <[e-mail]>
Cc: Jacob Coulson <[e-mail]>
Katie,

7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…5/11
Understood. We’ll work on getting that from the vendor still. Apologies for the delay. Is there any other information you need for
the file at this time?

Chris
[Quoted text hidden]
Jacob Coulson <[e-mail]>Fri, Jul 12, 2024 at 8:29 AM
To: Katie Andersen <[e-mail]>, "Larson, Chris" <[e-mail]>
Kae,
This is what I received from the manufacturer:
Best,

Jacob Coulson, CSP
Safety Manager
Liberty Safe & Security

509-845-9910
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…6/11
[e-mail]
From: Kae Andersen <[e-mail]>
Sent: Tuesday, July 9, 2024 12:18 PM
[Quoted text hidden]

[Quoted text hidden]
Katie Andersen <[e-mail]>Fri, Jul 12, 2024 at 9:03 AM
To: Jacob Coulson <[e-mail]>, "Larson, Chris" <[e-mail]>
Jacob,
This is great. If they could provide a drawing that would be perfect.
Chris,
In response to your last question, can you send me the manufacturer specs for the crusher and a drawing for the baghouse?
Thank you!
Katie
[Quoted text hidden]
Larson, Chris <[e-mail]>Fri, Jul 12, 2024 at 9:11 AM
To: Katie Andersen <[e-mail]>, Jacob Coulson <[e-mail]>
Katie,

Here are the drawings I have for the baghouse along with the filter specifications.

@Jacob Coulson can you please provide Katie with the manufacturer specifications for the shredder?

Chris Larson, PE (MN, TX)
Project Engineer I Regulatory Compliance

13400 15th Ave N Suite A I Minneapolis, MN 55441
[Quoted text hidden]
[Quoted text hidden]
2 attachments
Apppendix F - Filter bag material specification.pdf
87K
approval drawing - general layout updated - Liberty Safe.pdf
253K
Jacob Coulson <[e-mail]>Fri, Jul 12, 2024 at 4:59 PM
To: "Larson, Chris" <[e-mail]>, Katie Andersen <[e-mail]>
Kae,
Aached is the drawing Weima provided.
Best,
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…7/11

Jacob Coulson, CSP
Safety Manager
Liberty Safe & Security

509-845-9910
[e-mail]
From: Larson, Chris <[e-mail]>
Sent: Friday, July 12, 2024 9:11 AM
To: Kae Andersen <[e-mail]>; Jacob Coulson <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
WL 8 Hopperhood.pdf
121K
Jacob Coulson <[e-mail]>Mon, Jul 15, 2024 at 10:21 AM
To: "Larson, Chris" <[e-mail]>, Katie Andersen <[e-mail]>
Katie,
Attached are the shredder specs.
Best,
Jake
From: Jacob Coulson <[e-mail]>
Sent: Friday, July 12, 2024 4:59:48 PM
To: Larson, Chris <[e-mail]>; Kae Andersen <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
pro-OkpQKnGb.jpeg
724K
Jacob Coulson <[e-mail]>Tue, Jul 16, 2024 at 2:12 PM
To: "Larson, Chris" <[e-mail]>, Katie Andersen <[e-mail]>
Kae,
I just wanted to follow up. Is there anything else that you are waing on?
Best,
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…8/11

Jacob Coulson, CSP
Safety Manager
Liberty Safe & Security

509-845-9910
[e-mail]
From: Jacob Coulson <[e-mail]>
Sent: Monday, July 15, 2024 10:21 AM
[Quoted text hidden]

[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Jul 16, 2024 at 2:14 PM
To: Jacob Coulson <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>
Jacob,
Not at the moment. I've written a draft permit and sent it in for our internal review process. The reviewer may have comments that require
additional information from you and I will reach out if that is the case.
Cheers,
Katie
[Quoted text hidden]
--

[Quoted text hidden]
Jacob Coulson <[e-mail]>Tue, Jul 16, 2024 at 2:44 PM
To: Katie Andersen <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>
Sounds good, thanks!
From: Kae Andersen <[e-mail]>
Sent: Tuesday, July 16, 2024 2:14 PM
To: Jacob Coulson <[e-mail]>
Cc: Larson, Chris <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
Larson, Chris <[e-mail]>Wed, Jul 17, 2024 at 7:22 AM
To: Katie Andersen <[e-mail]>
Hi Katie,
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:1800948704533284…9/11

I got your voicemail while I was out on PTO. Do you still need to have a call to discuss the calculations?

If so, I am free today from 1-2 and 3-4 CT. I am open most of tomorrow as well except from 10-11 CT.

Thanks!

Chris Larson, PE (MN, TX)
Project Engineer I Regulatory Compliance

13400 15th Ave N Suite A I Minneapolis, MN 55441
D [phone] I M [phone]
[e-mail] I Terracon.com

þ Please consider the environment before printing this email ü

From: Kae Andersen <[e-mail]>
Sent: Tuesday, July 16, 2024 3:15 PM
To: Jacob Coulson <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 17, 2024 at 8:02 AM
To: "Larson, Chris" <[e-mail]>
Chris,
I was able to sort it out! Thank you!
Cheers,
Katie
[Quoted text hidden]
--

[Quoted text hidden]
Larson, Chris <[e-mail]>Wed, Jul 17, 2024 at 8:24 AM
To: Katie Andersen <[e-mail]>
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:180094870453328…10/11
Fantastic! Thank you!

Chris
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 17, 2024 at 1:12 PM
To: "Larson, Chris" <[e-mail]>
Chris,
Quick clarifying question for you. The sheetrock shredder, cyclone, and baghouse systems are operated electronically correct? There is no
generator that is being installed along with these?
Cheers,
Katie
[Quoted text hidden]
--

[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 31, 2024 at 12:52 PM
To: "Larson, Chris" <[e-mail]>
Hi Chris,
I just want to confirm with you that the sheetrock shredder, cyclone, and baghouse systems are operated electronically and that there is no
generator that is being installed with the system.
If you could let me know as soon as you can, that would be awesome.
Cheers,
Katie Andersen
[Quoted text hidden]
Larson, Chris <[e-mail]>Wed, Jul 31, 2024 at 1:08 PM
To: Katie Andersen <[e-mail]>
Yes, it's on building power.
Get Outlook for Android
From: Kae Andersen <[e-mail]>
Sent: Wednesday, July 31, 2024 1:52:36 PM
To: Larson, Chris <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
7/31/24, 1:34 PM State of Utah Mail - Re: NOI Submittal - Liberty Safe and Security
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1800948704533284740&simpl=msg-f:180094870453328…11/11
Notice of Intent Application
Liberty Safe and Security Products, Inc
1199 W. Utah Avenue
Payson, Utah 84651
Utah County
June 3, 2024
Terracon Project No. MP237148
Prepared for:
Liberty Safe and Security Products, Inc
Payson, Utah
Prepared by:
Terracon Consultants, Inc.
Minneapolis, Minnesota
June 3, 2024
Mr. Alan Humpherys
Utah Department of Environmental Quality
Division of Air Quality
195 N 1950 W.
Salt Lake City, UT 84114
RE:Notice of Intent Application
Liberty Safet and Security Products, Inc
1199 W. Utah Avenue
Payson, Utah 84651
Dear Mr. Humpherys:
Terracon is submitting the attached Notice of Intent (NOI)Application along with all the
supporting information on behalf of Liberty Safe and Security Products, Inc (Liberty)in
Payson, Utah.The facility is looking to install a sheetrock shredding operation to convert used
sheetrock slabs to a crushed gypsum powder for haul-off to a 3rd party.
The NOI includes all the requested information on the NOI checklist.The attached NOI also
includes the required regulation review.The facility currently operates under Air Permit
AN125380008-19.
If you have any questions on the information contained in the NOI,please contact Chris Larson
at 763-489-3153.
Sincerely,
Terracon Consultants, Inc.
Chris Larson,PE (in MN,TX)Travis W. Knisley, PE (in MN)
Project Engineer –Chemical Senior Associate |Senior Engineer -Chemical
Enc.Notice of Intent
cc:Mr.Jacob Coulson
Travis W. Knisley
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
3
CONTENTS
INTRODUCTION.........................................................................................................................4
PROCESSES..................................................................................................................................4
BACT...............................................................................................................................................5
EMISSIONS IMPACT ANALYSIS –APPROVED MODELING PROTOCOL ................8
NONATTAINMENT/MAINTENANCE AREAS –MAJOR NSR/MINOR........................8
MAJOR SOURCES IN ATTAINMENT OR UNCLASSIFIED AREAS ..............................9
Appendix List
A –Emission Calculations
B –Plot Plan
C –Process Flow Diagram
D –Permit Forms
E –Minor Source Offset Flowchart
F –Equipment Specification Pages
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
4
INTRODUCTION
Description of Facility Operations
Liberty Safe and Security Products, Inc (Liberty) operates a facility at 1199 W. Utah
Avenue in Payson,Utah. The facility operates under air permit authorization
AN125380008-19. The facility manufactures gun safes for residential sale. The facility
has various operations that are permitted which include but are not limited to surface
coating, cure-off ovens, natural gas combustion,and cutting operations.The facility
already has a permit to operate but Liberty is looking to install and operate a
sheetrock shredding operation. A description of this process is described in section
2.0.
PROCESSES
2.1 Sheetrock Shredder (SS-1)
Liberty is looking to install and operate a sheetrock shredder at the facility. Currently
sheetrock is cut using a water jet for installation as a fire-retardant portion of their
safe manufacturing process. The leftover pieces were hauled away as waste via a 3rd
party. With the installation of a shredder, Liberty can then process the waste pieces
into a crushed powder which is a preferred method of disposal of the material. The
waste pieces are fed into a large hopper that sits above the grinder. The sheetrock
falls into the grinder where it is mechanically crushed into a powdered gypsum
material. The material falls into an air stream which pneumatically conveys the
material to a product recovery cyclone. The product passes through an airlock into a
screw conveyor at which point it then drops into one of two haul-off dumpsters to be
taken away. The air from the product cyclone that is separated from the gypsum then
goes through a filter baghouse that achieves 95% reduction of particulate matter
emissions.The cyclone is being considered as part of the process since the equipment
could not operate without cyclone collecting the powdered material. The fabric filter
will be claimed as a control device.
The filter baghouse does not have a stack. The filters are aligned in a 3x2 array. The
air exhausts directly from the bags as a volume source from the filters. The unit is
outside of the main building and below the roof height. The average height of release
is approximately 12’ from the ground with the bags ranging from 6’ to 18’ off of the
ground.
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
5
Hourly and annual emission rates were calculated utilizing the maximum hourly and
maximum annual sheetrock waste amounts that can be put through the shredder
along with representative EPA AP-42 factors.The shredder emissions were calculated
using the crushing emission factor from AP-42 Chapter 11.16. The emissions from
the pneumatic transfer utilize AP-42 Chapter 9.9.1.The emissions from the
conveyance and transfer into the dumpster also utilized AP-42 Chapter 11.16
emission factors.The specific Source Classification Codes (SCC) are included in
Appendix A following this application.
Please refer to Table 2 in Appendix A for the calculations of both the potential-to-
emit and the controlled potential to emit emissions from this emission point.A write-
up on how the emissions from each of the emission sources are calculated is included
below.
Emissions from Shredder
𝐸𝑙𝑖𝑟𝑟𝑖𝑙𝑙𝑟൬𝑙𝑎
ℎ𝑟൰ =𝑅ℎ𝑟𝑎𝑎𝑅𝑎𝑟𝑎൬𝑟𝑙𝑙
ℎ𝑟൰ ∗𝐸𝐸𝑆ℎ𝑟𝑐𝑐൬ 𝑙𝑎
𝑟𝑙𝑙൰ ∗(1 −𝑎𝑎𝑙𝑟𝑟𝑟𝑎𝑎𝑎𝑎𝑖𝑎𝑖𝑎𝑙𝑦(%))
Emissions from Fabric Filter
𝐸𝑙𝑖𝑟𝑟𝑖𝑙𝑙𝑟൬𝑙𝑎
ℎ𝑟൰ =𝑅ℎ𝑟𝑎𝑎𝑅𝑎𝑟𝑎൬𝑟𝑙𝑙
ℎ𝑟൰∗൫𝐸𝐸𝑆ℎ𝑟𝑐𝑐+𝐸𝐸𝑆𝑟𝑎𝑛𝑟)൯ ∗𝑎𝑎𝑙𝑟𝑟𝑟𝑎𝑎𝑎𝑖𝑎𝑖𝑎𝑙𝑎𝑦(%)∗൫1−𝐶𝐸𝐶𝑦𝑐𝑙𝑛𝑛𝑐൯ ∗(1 −𝐶𝐸𝐹𝑖𝑙𝑟𝑐𝑟)
Emissions from Conveyance
𝐸𝑙𝑖𝑟𝑟𝑖𝑙𝑙𝑟൬𝑙𝑎
ℎ𝑟൰ =𝑅ℎ𝑟𝑎𝑎𝑅𝑎𝑟𝑎൬𝑟𝑙𝑙
ℎ𝑟൰ ∗𝐸𝐸𝐶𝑛𝑛௩𝑐𝑦𝑎𝑛𝑐𝑐൬ 𝑙𝑎
𝑟𝑙𝑙൰∗(#𝑅𝑟𝑎𝑙𝑟𝑎𝑎𝑟𝑟)
BACT
3.1 Sheetrock Shredder (EP001)
Process:Sheetrock Shredder
Emission Unit ID:SS-1
Control Device ID:SSDC-1
Capture 95% (Manufacturer Statement)
Control Type:Baghouse
Rating:95% Efficient for PM, PM10,PM2.5
Controlled Potential To Emit Emission Summary per Unit (PM)
Pollutant PM PM10 PM2.5
Emissions
(lb/hr)
0.388 0.367 0.367
Emissions
(tons/yr)
0.807 0.764 0.764
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
6
Please refer to Section 2.1 for process description and emission calculation
demonstrations along with Appendix A,Table 2 for the emissions from this process
unit. Emission Factors from AP-42 Chapter 11.16 and 9.9.2 were used. A fabric filter
with a 95% removal efficiency was used to calculate projected a controlled PTE of
0.807 tons PM/year from the shredding system.The emissions are distributed as
coming fugitively from the hopper of the shredder, from the filling of the dumpsters,
and the exhaust from the fabric filters.
A top-down Best Available Control Technology (BACT) analysis consists of the 5 steps
detailed below.
Step 1 –Identify all control technologies
Step 2 –Eliminate technically infeasible options
Step 3 –Rank remaining control technologies by control effectiveness
Step 4 –Evaluate most effective controls and document results
Step 5 –Select BACT
1.Identify Control Technologies
The most common types of particulate control devices include the following.
electrostatic precipitators (wet and dry types),
fabric filters (also called baghouses),
wet scrubbers, and
cyclones (or multiclones)
2.Eliminate technically infeasible options
All of the control technologies identified in Step 1 are classified as technically feasible
to control the particulate emissions from the shredding operations.
The wet scrubber was eliminated due to the mixture of gypsum and water creating a
very sticky sludge which would cause haul away and disposal issues of the removed
material. The system would also likely clog up and not be functional. The system also
has a cyclone on the unit that is part of the process and is not considered a control
device. An additional cyclone likely would not provide the control efficiency necessary
for the unit to operate efficiently.
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
7
3.Rank remaining control technologies by control effectiveness
The controls identified in Step 1 above have been ranked from the most efficient to
the least efficient.
1.Electrostatic Precipitator (98%)
2.Fabric Filters (95%)
4.Evaluate most effective controls and document results
A fabric filter has been identified as being the most effective control technology.
Electrostatic Precipitators are typically used in high volume gas streams to remove
ash and dust. Due to the low volume of air and the low level of emissions associated
with this process an electrostatic precipitator was not evaluated further due to the
expected high cost associated with these types of controls.In addition, the shredder
system is equipped with a fabric filter baghouse from the manufacturer.
5.Select BACT
Based on this analysis,Liberty is proposing to continue to use its fabric filter baghouse
and is asking that it be classified as BACT for controlling the emissions from the
sheetrock shredder.Liberty will continue to use the fabric filter baghouse to control
the emissions, operate the baghouse within manufacturer’s recommended
parameters, and perform maintenance as recommended by the manufacturer.
The control equipment evaluated above is for the emissions from the product cyclone.
There are a small amount of uncontrolled fugitive emissions from the process. The
sheetrock hopper has a manufacturer provided capture rate of 95%of the emissions
generated by the shredder. This results in emissions of 0.203 tons of PM / year from
the hopper. There is no economically feasible control option for the emissions from
the top of the shredder, therefore BACT will be following procedures to minimize
emissions. The emissions would be fugitive indoors from the top of the shredder.
There are also emissions from the unloading of the material from the airlock of the
product cyclone through a screw auger where it is then dumped into a dumpster.
These emissions are fugitive outdoors and are 0.468 tons of PM per year. There are
no economically feasible control options to control these emissions. The facility will
follow procedures such as preventing cross winds on the dumping steps and
minimizing the distance the material will fall into the dumpster.
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
8
EMISSIONS IMPACT ANALYSIS –APPROVED
MODELING PROTOCOL
Liberty reviewed the Emissions Impact Assessment Guideline from UDAQ to
determine the need for an emissions impact analysis. Upon review of this document,
it was determined that Liberty does not need to provide any emissions impact
analysis modeling based on the emissions from the site and its location in Utah
County. The area is in an area classified as in maintenance for PM10 and non-
attainment for PM2.5.
Particulate Matter
Liberty reviewed the Emissions Impact Assessment Guideline from UDAQ to
determine the need for an emissions impact analysis. Upon review of this document,
it was determined that Liberty does not need to provide an emissions impact analysis
based on the emissions from the site and its location in Utah County. The area is
already classified as in maintenance for PM10 and nonattainment for PM2.5.A review
of the Minor Source Offset flow diagram indicated that the facility is not required to
obtain offsets. This completed table can be seen in Appendix E.
NONATTAINMENT/MAINTENANCE AREAS –MAJOR
NSR/MINOR
Per R307-403-2(1)this section is only applicable for new major stationary sources or
major modifications that are major for the pollutant or precursor pollutant for which
the area is designated nonattainment. Utah County is classified as non-attainment
for PM10 and PM2.5. A project is a major modification for a regulated NSR pollutant
if it causes two types of emissions increases,a significant emissions increase (as
defined in 40 CFR 51.165(a)(1)(xxvii)), and a significant net emissions increase (as
defined in 40 CFR 51.165(a)(1)(vi) and (x)). The project is not a major modification
if it does not cause a significant emissions increase.
Liberty is not emitting nor do they have the potential to emit 100 tons per year or
more of any regulated NSR pollutant after previously established limits in their
existing air permit. Therefore, this facility does not meet the criteria of a major source
and this section does not apply.
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
9
MAJOR SOURCES IN ATTAINMENT OR UNCLASSIFIED
AREAS
Liberty is not a major source therefore this section is not applicable.
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
10
APPENDIX A
EMISSION CALCULATIONS
Table #1 -Emission Summary
Appendix A - Emission Calculations
Liberty Safe and Security Products, Inc
Payson, Utah
lb/hr tpy lb/hr tpy lb/hr tpy
Shredder - Fugitive SS-1 SS-Fug 0.098 0.203 0.083 0.172 0.083 0.172
Shredder - Filter SS-1 SS-Filter 1.634 3.398 1.505 3.129 1.505 3.129
Dumpster Conveyance SS-1 SS-Convey 0.225 0.468 0.225 0.468 0.225 0.468
1.956 4.068 1.812 3.769 1.812 3.769
lb/hr tpy lb/hr tpy lb/hr tpy
Shredder - Fugitive SS-1 SS-Fug 0.098 0.203 0.083 0.172 0.083 0.172
Shredder - Stack SS-1 SS-Filter 0.066 0.136 0.060 0.124 0.060 0.124
Dumpster Conveyance SS-1 SS-Convey 0.225 0.468 0.225 0.468 0.225 0.468
0.388 0.807 0.367 0.764 0.367 0.764
Permitted
Emissions
Emissions
Increases
Proposed
Emissions
Tons / yr Tons / yr Tons / yr
PM10 Total 0.990 0.764 1.754
PM10 Fugitive 0.000 0.640 0.640
PM2.5 0.990 0.764 1.754
Nox 14.930 0.000 14.930
SO2 0.110 0.000 0.110
CO 4.620 0.000 4.620
VOC 33.700 0.000 33.700
VOC Fugitive 0.000 0.000 0.000
CO2e 16,423 0 16,423
*Refer to Form 5 in Appendix B for the completed emission increase summary
PTE for New Sources
PTE With Controls for New Sources
Emission Source
Emission Source Emission Unit Emission Point
Emission Unit Emission Point
Total
PM PM10 PM2.5
PM PM10 PM2.5
Criteria Pollutant
Summary
Total
Table #2 - Shredder Emission Calculations
Appendix A - Emission Calculations
Liberty Safe and Security Products, Inc
Payson, Utah
1,500 lb/hr
3,120 tpy
Process Pollutant EF Units Source
PM 2.600 lb/ton product SCC 3-05-015-02
PM10 2.200 lb/ton product SCC 3-05-015-02
Transfer PM 2.00 lb/ton product SCC 3-02-005-02
PM 0.150 lb/ton product SCC 3-05-015-04
# Transfers 2
Shredder Capture1 95%
Cyclone PM10 - Control2 60%
Baghouse PM10 - Control3 95%
1 95% removal efficiency per manufacturer statement
2 Removal eficiency for a medium efficiency cyclone per MPCA control equipment standard
3 Per manufacturer specification sheet
Potential To Emit
Pollutants Shredder Conveyor Drops Exhaust from Cyclone Total Units
PM 0.098 0.225 1.311 1.634
PM10 0.083 0.225 1.197 1.505
PM 0.203 0.468 2.727 3.398
PM10 0.172 0.468 2.490 3.129
Potential To Emit with Controls
Pollutants Shredder Conveyor Drops Exhaust from Filter Total Units
PM 0.098 0.225 0.066 0.388
PM10 0.083 0.225 0.060 0.367
PM 0.203 0.468 0.136 0.807
PM10 0.172 0.468 0.124 0.764
Throughput
lb/hr
ton/yr
lb/hr
ton/yr
Conveyor
Shredder
Emission Factor
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
11
APPENDIX B
PLOT PLAN

SITE DIAGRAM
13400 15th Ave N
Plymouth, MN 55441-4532
MP237148 AERIAL PHOTOGRAPHY PROVIDED BY
MICROSOFT BING MAPS
Liberty Safe
1199 W Utah Ave Payson, UT DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION
PURPOSES
Project Manager:
Drawn by:
Checked by:
Approved by:
CEL
TWK
LDS
LDS
SiteDiagram
5/23/2024
Scale:
Project No.
File
Date:
AS SHOWN 1
Exhibit
APPROXIMATE
SITE BOUNDARY
Sheetrock Shredder
Product Cyclone, Fabric Filter,
and Haul-Off Dumpster
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
12
APPENDIX C
PROCESS FLOW DIAGRAMS
PROCESS FLOW DIAGRAM
SHEETROCK SHREDDER SYSTEM
LIBERTY SAFE AND SECURITY PRODUCTS, INC
PAYSON, UTAH
1
13400 15th Avenue North Minneapolis, Minnesota 55441
PH. [phone] FAX. [phone]
MP237148
05/29/2024
LDS
CEL
TWK
TWK
N.T.S.
Project Manager:
Drawn by:
Checked by:
Approved by:
Project No.
Scale:
File Name:
Date:
Figure
SSPFDDIAGRAM IS FOR GENERAL LOCATION
ONLY, AND IS NOT INTENDED FOR
CONSTRUCTION PURPOSES
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
13
APPENDIX D
PERMIT FORMS
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
6/3/2024
Liberty Safe and Security Products, Inc
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
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:
6/3/2024
4
Liberty Safe and Security
1199 West Utah Avenue
Payson, Utah 84651
Jacob Coulson
[phone]
[e-mail]
Utah
12
435794.49
4432755
3499
AN125380008-19 3 11 19
Addition of a sheetrock shredder to the site.
4
Safety manager
Jacob Coulson
6/3/24
[e-mail]
509 845-9910
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information - For New Permit ONLY
1.Name of process:2.End product of this process:
3.Process Description*:
Operating Data
4.Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5.Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6.Maximum Hourly production (indicate units.):
_____________
7.Maximum annual production (indicate units):
________________
8.Type of operation:
Continuous Batch Intermittent
9.If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
Liberty Safe and Security
Payson, Utah
Sheetrock Shredder Ground Gypsum
Sheetrock used in safe manufacturing is loaded into a hopper after
leaving the wet-jet cutting system. The hopper feeds down into a
grinding system which grinds the sheetrock into a fine gypsum powder.
The powder is then pneumatically transferred to a cyclone to collect the
product. The product goes through conveyors to a storage unit. The air
from the cyclone is treated by a fabric filter baghouse.
20
4
52
25%
25%
25%
25%
1,500 3,120
4
Sheetrock 3,120.00
SS 1,500 lbs/hr 05/01/24
lbs/hr tons per year
tons / year
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
Liberty Safe and Security Products, Inc
Payson, Utah
0.99 0.76 1.75
0.00 0.64 0.64
0.99 0.76 1.54
14.93 0.00 14.93
0.11 0.00 0.11
4.62 0.00 4.62
33.70 0.00 33.70
0.00 0.00
16,422.86 0.00 16,422.86
16,422.86 0.00 16,422.86
Xylene 4.29 0.00 4.29 0.00
Methyl Isobutyl kethoe 4.01 0.00 4.01 0.00
Toluene 3.47 0.00 3.47 0.00
Naphthalene 1.85 0.00 1.85 0.00
Ethyl Benzene 1.00 0.00 1.00 0.00
Styrene 0.12 0.00 0.12 0.00
Methanol 0.07 0.00 0.07 0.00
Generic HAPS 1.01 0.00 1.01 0.00
14.82 0.00 14.82

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
Sheetrock Shredder Powdered Gypsum
1,500 1,500
2024
Payson
Liberty Safe and Security
Shredder
25%
25%25%
25%
1,500 1,500
X
Sheetrock 1,500 lb/hrFire Retardant for Safes
WEIMA
WLK 8
X
20
4
52
N/A
N/A
3,120 tons
0%
X Fugitive Source
Explained in the report
body
6/3/2024
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.
X
70
X
Fabric Filter
Sterling Blower
6TAND 10
2024
87179
Particulate Matter
95%
95%
Unknown
SS-1
12
Below Roof
Volume Source - Explained in
Application Document
X
12'6'
2,100
0.367 0.3670.764 0.764
To Be Determined
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. 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
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Sheetrock Shredder makes gypsum powder which is pneumatically trans-
ferred to a collection cyclone.This baghouse controls the air exhaust
from the cyclone.
Ambient
70 F
1,350
2,100 1,350
95%
6
10 HP -2100 CFM
20
1920
Liberty Safe and Securities
Payson
Unknown Unknown
Sterling Blower 6TAND 10
16 12
Vol Source
X
Replace as needed4.48
0.367 0.3670.764 0.764
TBD TBD
X
6/3/2024
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
14
APPENDIX E
FLOWCHARTS
Page2
Source Tvne Determination
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. (801) 5364414
www.deq.utah.gov
Printed on 100% recYcled PaPer
Will annual potential
emissions be less than 5
tons for any criteria
pollutant, 500 pounds for
any HAP, and 2,000
pounds for all HAPs
Will annual potential
emissions, including
fugitives, be less than 100
tons for any criteria
pollutant, 10 tons for any
HAP, 25 tons for all HAPs
combined, and 100,000 tons
Source is a Small Source
(AO not required. Source may
register as a small source, but
registration is not required)
Source is a
Minor Source
Are non-fugitive**
annual potential
emissions less than 100
tons for any criteria
pollutant, 10 tons for any
HAP,25 tons for all
HAPs combined, and
Source is a Title V Major Source.
PSD may apply; contact a DAQ NSR
Engineer for details.
Page2
Location Determination
I
xlmpact means having an increase greater than the increments listed in R307-403-3.
This document is intended for guidance and educational purposes only. It is not intended to include all possible
scenarios. The DAQ NSR Section should be contacted for site specific requirements.
Is the source located
in or impact*:
Duchesne County or
Uintah County?
Source is located in an
unclassifiable area for ozone
and an attainment area for all
other pollutants.
Is the source located in
or impact*: Box Elder
County, Cache County,
or Tooele County?
Source may be located in or
impact* a PM2 r nonattainment
area. Contact a DAQ NSR permit
engineer for area boundaries, rules,
and requirements.
Is the source
located in or
impact* Weber
County?
Is the source
located in or
impact*
Ogden City?
Source is located in a
nonattainment area for PM,u.
Source is located in a
maintenance area lor CO.
Page 3
*Impact means having an increase greater than the increments listed in R307-403-3.
This document is intended for guidance and educational purposes only. It is not intended to include all possible
scenarios. The DAQ NSR Section should be contacted for site specific requirements.
Is the source
located in or
impact* Salt
Lake County?
Is the source
located in or
impact* Salt
Lake City?
Source is located in a
nonattainment area for
PMlo, PM2 5, and SO2.
Source is located in a
maintenance area for
ozone.
Is the source
located in or
impact* Utah
Corurty?
Is the source
located in or
impact*
Provo City?
Source is located in
a nonattainment area
for PM16, and PMr.r.
Is the source
located in or
impact+ Davis
Cormty?
Source is located in a
nonattainment area for PM2.5.
Source is located in a
maintenance area for ozone.
Source is located in an
attainment area for all
pollutants.
Minor Source Offset Requirements
Source is required to
obtain VOC offsets on
a 1.2 to 1 basis.
(R307-420-3)
f l,'1 I i, O t"i scl illl:-:i:'e;r'icttrs
YES'---+
J*,
Source is
required to obtain
offsets on a I to 1
basis.
(R307-403-5)
*Impact means having an increase greater than the increments listed in R307-403-3.
This document is intended for guidance and educational purposes only. It is not intended to include all
possible scenarios. The DAQ NSR Section should be contacted for site specific requirements.
Is the source
located in or
impact* Davis or
Salt Lake County?
Are total voc
emissions
greater than or
equal to 50
tpy?
Will the source
have an increase
in VOC's greater
than or equal to
25 tpy?
Is the source
located in or impact
Salt Lake County,
Utah County, or
Ogden City?
Are the increases
ofNOy, SO2, and
PM16 greater than
or equal to 25 tpy
combined?
Are the ihcreases
ofNOa, SO2, and
PMro greater than
or equal to 50 tpy
combined?
Source is
required to
obtain offsets
on a 1.2 to I
basis.
(R307-403-5)Source is not
required to
obtain offsets.
(R307-403-5)
Notice of Intent Application
Liberty Safe and Securities, Inc ■Payson, Utah
June 3, 2024 ■Terracon Project No. MP237148
15
APPENDIX F
EQUIPMENT SPECIFICATIONS

135 Vista Centre Dr
Forest, VA 24551-3964
Phone [phone]
Fax [phone]
www.sterlingblower.com

SHAKER FELT FILTER BAG SPECIFICATION

CONSTRUCTION: Unsupported needle felt

COMPOSITION: 100% Polyester singed one side

WEIGHT: 8.00-10.00 oz. / yd2

THICKNESS: 0.035” – 0.055”

AIR PERMEABILITY: 90 -120 CFM @ ½” WG

EFFICIENCY: 95% @ 10 micron

MINIMUM MULLEN BURSTING STRENGTH: 250 lbs. / in2