DAQ-2024-011375

DAQE-AN108330007-24

{{$d1 }}

Eva Snow
Valmont Coatings, Inc.
1085 West 400 North
Lindon, UT 84042
[e-mail]

Dear Ms. Snow:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN108330005-12 for a
10-Year Review and Permit Updates
Project Number: N108330007

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a
10-year administrative review of this source and its respective AO. Valmont Coatings, Inc. must
comply with the requirements of this AO, all applicable state requirements (R307), and Federal
Standards.

The project engineer for this action is Lucia Mason, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:LM: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

November 3, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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

APPROVAL ORDER
DAQE-AN108330007-24
Administrative Amendment to Approval Order
DAQE-AN108330005-12 for a 10-Year Review
and Permit Updates

Prepared By
Lucia Mason, Engineer
[phone]
[e-mail]

Issued to
Valmont Coatings, Inc. - Intermountain Galvanizing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

November 3, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN108330007-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Valmont Coatings, Inc. Valmont Coatings, Inc. - Intermountain Galvanizing Facility

Mailing Address Physical Address
1085 West 400 North 1085 West 400 North
Lindon, UT 84042 Lindon, UT 84042

Source Contact UTM Coordinates
Name: Philip Nicholes 436,968 m Easting
Phone: [phone],466,117 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 3479 (Coating, Engraving, & Allied Services, NEC)

SOURCE INFORMATION
General Description
Valmont Coating, Inc. operates a hot dip steel galvanizing and painting facility in Lindon. Steel is delivered
to the facility by trucks before being unloaded by forklifts and moved into the receiving yard. At the facility,
steel can be galvanized, painted, or both. To be galvanized, steel is moved inside the building to a "racking
area," where each piece is chained/attached to an overhead crane (racked) before being dipped into a series of
tanks. The tanks include: two caustic soda tanks, a caustic rinse tank, four sulfuric acid descaling tanks, two
sulfuric acid rinse tanks, a zinc/ammonium chloride pre-flux tank, one molten zinc kettle, and one water
quench tank. The facility also operates a powder coat line where steel is blasted and painted. Finished steel
products are moved to the shipping yard before being loaded onto trucks. The water used in process tanks is
heated by means of two natural gas-fired boilers.

NSR Classification
10-Year Review

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

DAQE-AN108330007-24
Page 4

Applicable Federal Standards
None
Project Description
This is an administrative amendment to DAQE-AN108330005-12 dated November 28, 2012. The DAQ is
conducting a 10-year review and is updating the language and format of the 2012 AO.

According to a DAQ compliance inspection memorandum (see DAQC-410-24 dated March 19, 2024), the 9
MMBtu/hr kettle listed in DAQE-AN108330005-12 was taken offline with no plans for further use. On
August 23, 2024, the source verified they no longer use the 9 MMBtu/kettle and indicated the only kettle
they would like included on their permit is the 6 MMBtu/hr kettle listed in DAQE-AN108330005-12. The 9
MMBtu/hr kettle is being removed from the AO accordingly.

On October 10, 2024, the source confirmed that the chromate quench tank listed in DAQE-AN108330005-12
condition II.A.13 has been removed from the facility and should not be referenced in the AO. The chromate
quench tank is being removed from the permit.

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 13551.00
Carbon Monoxide 0 2.84
Nitrogen Oxides 0 9.29
Particulate Matter - PM10 0 11.04
Particulate Matter - PM2.5 0 5.52
Sulfur Dioxide 0 0.07
Volatile Organic Compounds 0 0.66

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Lead (CAS #7439921) 20
Change (TPY) Total (TPY)
Total HAPs 0 0.01

SECTION I: GENERAL PROVISIONS

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

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

DAQE-AN108330007-24
Page 5

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 years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Valmont Coatings, Inc. Steel Galvanizing Facility II.A.2 Various Natural Gas-Fired Boilers Less than 5 MMBtu/hr each Listed for informational proposes only
II.A.3 Two Caustic Soda Tanks Tanks #1 and #2 Listed for informational purposes only II.A.4 One Caustic Rinse Tank Listed for informational purposes only
II.A.5 Four Sulfuric Acid Descaling Tanks II.A.6 Two Sulfuric Acid Rinse Tanks
II.A.7 One Zinc/Ammonium Chloride Pre-flux Tank Listed for informational purposes only
DAQE-AN108330007-24
Page 6

II.A.8 One Molten Zinc Kettle Rating: 6 MMBtu/hr Fuel type: Natural gas II.A.9 One Metallic Zinc Recovery (MZR) Unit
Zinc recovery unit to retrieve metallic zinc from the kettleskims Model: 750 Capacity 1,329 lbs/batch
Rating: 0.4 MMBtu/hr Fuel type: Natural gas
Listed for informational purposes only
II.A.10 One Water Quench Tank Listed for informational purposes only
II.A.11 One Shot Blaster with Attached Dust Collector
Airless centrifugal steel shot blaster Equipped with a dust collector discharged inside the building
Manufacturer: Wheelabrator

II.A.12 One Coating Booth with Attached Dust Collector Electrostatic powder coating booth Equipped with a cartridge dust collector discharged into the building Designer: Valmont Industries
II.A.13 One Curing Oven
Manufacturer: Milbank Systems Rating: 1 MMBtu/hr
Fuel type: Natural gas
For informational purposes only

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements
II.B.1.a The owner/operator shall only use natural gas as fuel at the plant. [R307-401-8]
II.B.1.b The owner/operator shall only operate a batch-type galvanizing process. [R307-401-8]
II.B.1.c The owner/operator shall not exceed the specified usage/consumption limits on the following materials per rolling 12-month period:
A. 4,980 tons of zinc for coatings. B. 229,000 decatherms of natural gas.
C. 1,700 tons of kettleskims processed in the MZR unit.
[R307-401-8]
DAQE-AN108330007-24
Page 7

II.B.1.c.1 The owner/operator shall determine usage/consumption of the following materials through examination of: A. Zinc: a usage log which is kept on site at all times. The log shall track zinc delivery and drawdown in real time as the zinc inventory changes. B. Natural gas: the natural gas fuel bill. C. Kettleskims: an inventory log that records the number of kettle-skims processed in the MZR unit. [R307-401-8] II.B.1.c.2 The owner/operator shall determine a new rolling 12-month total of each tracked material by:
A. Using material usage/consumption records to calculate a new rolling 12-month total
by the 20th day of each month using data from the previous 12 months.
B. Keeping records for all periods the plant is in operation.

[R307-401-8]
II.B.2 Opacity Requirements
II.B.2.a The owner/operator shall not exceed the following opacity limits for indicated emission units:
A. Shot blasting operation - 20% opacity.

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

II.B.2.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.2.a.2 Opacity observations from mobile, intermittent, and fugitive sources shall be conducted using 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at
15-second intervals over a six-minute period shall not apply. The number of observations and the
time period shall be determined by the length of the intermittent or mobile source operation. [R307-309-4, R307-401-8]

II.B.2.a.3 The owner/operator shall only operate dry-type kettle operations. The flux shall be skimmed off as necessary to comply with the opacity limits in this AO. [R307-401-8]
II.B.3 Tank Temperature and Concentration Requirements
II.B.3.a The owner/operator shall not exceed the specified temperatures in the following tanks: A. Caustic soda tanks: 180 degrees Fahrenheit. B. Zinc/ammonium chloride pre-flux tank: 160 degrees Fahrenheit. C. Sulfuric acid descaling tanks: 160 degrees Fahrenheit. [R307-401-8]
DAQE-AN108330007-24
Page 8

II.B.3.a.1 The owner/operator shall determine the temperature of the caustic soda tanks, the zinc/ammonium chloride pre-flux tank and the sulfuric acid descaling tanks by: A. Equipping each tank with a thermometer to measure tank temperature. B. Positioning each thermometer such that the temperature can be safely read at all times. C. Recording the temperature of each tank in a log at least once a week. [R307-401-8] II.B.3.b The owner/operator shall:
A. Determine the concentration of sodium hydroxide in the caustic soda tanks using a method which has been approved by the Director.

B. Record the concentration at least once a week.
C. Keep a log of the concentration.
[R307-401-8]

II.B.3.c The owner/operator shall maintain a specific gravity of 10-18 Degrees Baume (Be) in the zinc/ammonium chloride pre-flux tank. [R307-401-8]
II.B.3.c.1 The owner/operator shall:
A. Record the Baume of the zinc/ammonium chloride tanks at least once a week.

B. Keep a log of the concentration.
[R307-401-8]

II.B.3.d The owner/operator shall not exceed a sulfuric acid concentration of 15% weight in the sulfuric acid descaling tanks. [R307-401-8]
II.B.3.d.1 The owner/operator shall:
A. Determine the concentration of sulfuric acid in the sulfuric acid descaling tanks using a
method which has been approved by the Director.
B. Record the concentration at least two times per week.
C. Keep a log of the concentration.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN108330005-12 dated November 28, 2012
DAQE-AN108330007-24
Page 9

ACRONYMS

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

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

DAQE-

RN108330007 October 9, 2024 Eva Snow
Valmont Coatings, Inc. 1085 West 400 North Lindon, UT 84042
[e-mail] Dear Eva Snow,
Re: Engineer Review - Administrative Amendment to Approval Order DAQE-AN108330005-12 for a 10-Year Review and Permit Updates Project Number: N108330007 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 (NSR) permitting program. Valmont Coatings, Inc. should complete this review within 10 business days of receipt. Valmont Coatings, Inc. should contact Lucia Mason at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Lucia Mason at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Valmont Coatings, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Valmont Coatings, Inc. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.
Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N108330007 Owner Name Valmont Coatings, Inc. Mailing Address 1085 West 400 North
Lindon, UT, 84042 Source Name Valmont Coatings, Inc. - Intermountain Galvanizing-
Galvanizing Facility Source Location 1085 West 400 North Lindon, UT 84042
UTM Projection 436,968 m Easting, 4,466,117 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 3479 (Coating, Engraving, & Allied Services, NEC) Source Contact Philip Nicholes Phone Number [phone] Email [e-mail] Billing Contact Eva Snow
Phone Number [phone] Email [e-mail]
Project Engineer Lucia Mason, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted July 10, 2024 Date of Accepted Application August 20, 2024

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 2
SOURCE DESCRIPTION General Description
Valmont Coating, Inc. operates a hot dip steel galvanizing and painting facility in Lindon. Steel is delivered to the facility by trucks before being unloaded by forklifts and moved into the receiving yard. At the facility, steel can be galvanized, painted, or both. To be galvanized, steel is moved
inside the building to a "racking area" where each piece is chained/attached to an overhead crane (racked) before being dipped into a series of tanks. The tanks include: two caustic soda tanks, a caustic rinse tank, four sulfuric acid descaling tanks, two sulfuric acid rinse tanks, a zinc/ammonium chloride pre-flux tank, one molten zinc kettle, and one water quench tank. The facility also operates a powder coat line where steel is blasted and painted. Finished steel products are moved to the shipping yard before being loaded onto trucks. The water used in process tanks is heated by means of two natural gas-fired boilers. NSR Classification: 10 Year Review
Source Classification Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA Utah County
Airs Source Size: B Applicable Federal Standards
None Project Proposal Administrative Amendment to Approval Order DAQE-AN108330005-12 for a 10-Year Review and Permit Updates
Project Description This is an administrative amendment to DAQE-AN108330005-12 dated November 28, 2012. The DAQ is conducting a 10-year review and is updating the language and format of the 2012 AO. According to a DAQ Compliance Inspection Memorandum (see DAQC-410-24 date March 19, 2024), the 9 MMBtu/hr kettle listed in DAQE-AN108330005-12 was taken offline with no plans for further use. On August 23, 2024, the source verified they no longer use the 9 MMBtu/kettle and indicated the only kettle they would like included on their permit is the 6 MMBtu/hr kettle
listed in DAQE-AN108330005-12. The 9 MMBtu/hr kettle is being removed from the AO accordingly.
On October 10, 2024, the source confirmed that the chromate quench tank listed in DAQE-AN108330005-12 condition II.A.13 has been removed from the facility and should not be referenced in the AO. The chromate quench tank is being removed from the permit.
EMISSION IMPACT ANALYSIS This is a 10-year review. No equipment is being added and no emissions are increasing. Therefore, modeling is not currently required. [Last updated September 10, 2024]

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 13551.00 Carbon Monoxide 0 2.84
Nitrogen Oxides 0 9.29
Particulate Matter - PM10 0 11.04
Particulate Matter - PM2.5 0 5.52
Sulfur Dioxide 0 0.07
Volatile Organic Compounds 0 0.66 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Lead (CAS #7439921) 20
Change (TPY) Total (TPY)
Total HAPs 0 0.01

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

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review
This is a 10-year review. No equipment is being added and no emissions are increasing. Therefore, a BACT analysis is not currently required. [Last updated September 10, 2024]
SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] 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]

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 5
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 Valmont Coatings, Inc. Steel Galvanizing Facility
II.A.2 Various Natural Gas-fired Boilers Less than 5 MMBtu/hr each
Listed for informational proposes only

II.A.3 Two (2) Caustic Soda Tanks Tanks #1 and #2 Listed for informational purposes only
II.A.4 NEW One (1) Caustic Rinse Tank Listed for informational purposes only
II.A.5 Four (4) Sulfuric Acid Descaling Tanks

II.A.6 NEW Two (2) Sulfuric Acid Rinse Tanks

II.A.7 One (1) Zinc/Ammonium Chloride Pre-flux Tank
Listed for informational purposes only

II.A.8 One (1) Molten Zinc Kettle Rating: 6 MMBtu/hr Fuel type: Natural gas

II.A.9 One (1) Metallic Zinc Recovery (MZR) Unit
Zinc recovery unit to retrieve metallic zinc from the kettle-skims Model: 750 Capacity 1,329 lbs/batch Rating: 0.4 MMBtu/hr Fuel type: Natural gas Listed for informational purposes only

II.A.10 NEW One (1) Water Quench Tank Listed for informational purposes only

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 6
II.A.11 One (1) Shot Blaster with Attached Dust Collector Airless centrifugal steel shot blaster Equipped with a dust collector discharged inside the building
Manufacturer: Wheelabrator
II.A.12 One (1) Coating Booth with Attached Dust Collector Electrostatic powder coating booth Equipped with a cartridge dust collector discharged into the building Designer: Valmont Industries
II.A.13 One (1) Curing Oven Manufacturer: Milbank Systems Rating: 1 MMBtu/hr Fuel type: Natural gas For informational purposes only

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1
NEW
Site-wide Requirements
II.B.1.a NEW The owner/operator shall only use natural gas as fuel at the plant. [R307-401-8]
II.B.1.b NEW The owner/operator shall only operate a batch-type galvanizing process. [R307-401-8] II.B.1.c NEW The owner/operator shall not exceed the specified usage/consumption limits on the following materials per rolling 12-month period:
A. 4,980 tons of zinc for coatings B. 229,000 decatherms of natural gas C. 1,700 tons of kettle-skims processed in MZR unit [R307-401-8]

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 7
II.B.1.c.1 NEW The owner/operator shall determine usage/consumption of the following materials through examination of: A. Zinc: a usage log which is kept on site at all times. The log shall track zinc
delivery and drawdown in real time as the zinc inventory changes B. Natural gas: the natural gas fuel bill C. Kettle-skims: an inventory log that records the number of kettle-skims
processed in the MZR unit [R307-401-8]
II.B.1.c.2
NEW
The owner/operator shall determine a new rolling 12-month total of each tracked material by:
A. Using material usage/consumption records to calculate a new rolling 12-month total
by the 20th day of each month using data from the previous 12 months
B. Keeping records for all periods the plant is in operation
[R307-401-8]
II.B.2
NEW
Opacity Requirements
II.B.2.a NEW The owner/operator shall not exceed the following opacity limits for indicated emission units:
A. Shot blasting operation - 20% opacity
B. All other points - 10% opacity [R307-401-8]
II.B.2.a.1
NEW
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A Method 9. [R307-401-8] II.B.2.a.2 NEW Opacity observations from mobile, intermittent, and fugitive sources shall be conducted using 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15 second intervals over a six-minute period shall not apply. The number of observations and the time period shall be determined by the length of the intermittent or mobile source operation. [R307-309-4, R307-401-8]

II.B.2.a.3 NEW The owner/operator shall only operate dry-type kettle operations. The flux shall be skimmed off as necessary to comply with the opacity limits in this AO. [R307-401-8] II.B.3 NEW Tank Temperature and Concentration Requirements

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 8
II.B.3.a NEW The owner/operator shall not exceed the specified temperatures in the following tanks:
A. Caustic soda tanks: 180 degrees Fahrenheit
B. Zinc/ammonium chloride pre-flux tank: 160 degrees Fahrenheit C. Sulfuric acid descaling tanks: 160 degrees Fahrenheit [R307-401-8]
II.B.3.a.1 NEW The owner/operator shall determine the temperature of the caustic soda tanks, the zinc/ammonium chloride pre-flux tank and the sulfuric acid descaling tanks by:
A. Equipping each tank with a thermometer to measure tank temperature
B. Positioning each thermometer such that the temperature can be safely read at all
times
C. Recording the temperature of each tank in a log at least once a week
[R307-401-8]

II.B.3.b NEW The owner/operator shall:
A. Determine the concentration of sodium hydroxide in the caustic soda tanks using a
method which has been approved by the Director
B. Record the concentration at least once a week
C. Keep a log of the concentration
[R307-401-8]

II.B.3.c
NEW
The owner/operator shall maintain a specific gravity of 10-18 Degrees Baume (Be) in the
zinc/ammonium chloride pre-flux tank. [R307-401-8] II.B.3.c.1 NEW The owner/operator shall: A. Record the Baume of the zinc/ammonium chloride tanks at least once a week B. Keep a log of the concentration [R307-401-8] II.B.3.d NEW The owner/operator shall not exceed a sulfuric acid concentration of 15% weight in the sulfuric acid descaling tanks. [R307-401-8]

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 9
II.B.3.d.1 NEW The owner/operator shall:
A. Determine the concentration of sulfuric acid in the sulfuric acid descaling tanks using
a
method which has been approved by the Director B. Record the concentration at least two times per week C. Keep a log of the concentration [R307-401-8]

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 10
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN108330005-12 dated November 28, 2012
REVIEWER COMMENTS
1. Comment regarding 10-Year Review:
The requirements have been updated to reflect the wording and format of modern permits. The PTE limits have been moved to a separate section labeled "Summary of Emissions." All contact information and locations have been confirmed and updated.
On August 23, 2024, the source confirmed the 9MMBtu/hr molten zinc kettle is no longer in use or
on site and requested the kettle be moved from the permit. It has been removed from the Approved Equipment List accordingly. Emissions from the 9MMBtu/hr kettle were not subtracted from the PTE values in AO DAQE-AN108330005-12 because the requirements include a natural gas consumption limit.
On August 23, 2024, the source also provided a heat rating for the natural gas-fired boilers of 2.6 MMBtu/hr each and a heat rating for the natural gas-fired Metallic Zinc Recovery (MZR) unit recovery unit of 0.4 MMBtu/hr. The boiler's heat rating is included in Equipment II.A.1. The MZR
unit's heat rating was added in II.A.9. Both the boiler's and the MZR unit's heat ratings are under 5 MMBtu/hr. Thus, the equipment is exempt under R301-401-10 and listed "for informational purposes only."
On October 10, 2024, the source confirmed that the chromate quench tank listed in DAQE-AN108330005-12 condition II.A.13 has been removed from the facility and should not be referenced in the AO. The chromate quench tank has been removed from the permit. The tank was included in the 2012 AO for informational purposes only, thus its removal did not impact the source's PTE
values.
CO2e was calculated based on the natural gas consumption limit and added to the Summary of Emissions. These calculations used greenhouse gas emission factors from AP-42 5th Edition Table 1.4-2 and 40 CFR 98 Table A-1 to Subpart A. [Last updated October 9, 2024]
2. Comment regarding Federal Standard Applicability: NSPS, 40 CFR 60 Subpart Dc establishes national emission standards for small industrial-commercial-institutional
steam generating units (between 100 MMBtu and 10MMBtu/hr). The facility operated two 80bph boilers (2.7 MMBtu/hr). The boilers are below the lower heat rating for the Subpart. Therefore, Subpart Dc is not applicable.
MACT, 40 CFR 63
Subpart CCC establishes national emission standards for hazardous air pollutants for steel pickling with HCL processes. The facility has a descaling tank, but the process uses sulfuric acid and not hydrogen chloride. Therefore, Subpart CCC does not apply.

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 11
Subpart JJJJJJ establishes national emission standards for hazardous air pollutants for industrial commercial and institutional boilers area sources. The facility operates two natural gas fired boilers. Gas-fired boilers are not subject to Subpart JJJJJJ. Therefore, Subpart JJJJJJ is not applicable. [Last updated October 9, 2024] 3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This source is not a major source, or a Title IV affected source. The facility is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP) or 40 CFR 63 (MACT) regulations. 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 facility.
[Last updated September 23, 2024]

Engineer Review N108330007: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility October 9, 2024 Page 12
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
Heating Value of Natural Gas 1020 BTU/scf or MMBtu/MMscf
Equipment Details
Rating 229,000.0 MMBtu/year Any Size Table 1.4-2 lb/10^6 scf lb/MMBtuCO2120,000 117.6471Green House Gas Pollutant Global Emission Emission Reference Lead 0.0005 0.0000
CO2 (mass basis)1 120,000 13,471 N2O Uncontrolled 2.2 0.0022
Methane (mass basis)25 2.3 0.26 Controlled - Low Nox burners 0.64 0.0006N2O (mass basis)298 2.2 0.25 Methane 2.3 0.0023
CO2e 13551
NG limit 229000 decatherms/year229000MMBtu/year https://www.convertunits.com/from/dekatherm/to/btu
Calculations Based on NG Limit
AP-42 Table 1.4-2&Table A-1 toSubpart A of Part 98
Page 1 of Version 1.0 November 29, 2018
Equipment Details
Rating 26 MMBtu/hour 229,000.0 NOx
Operational Hours 8,760 hours/year
Firing Normal
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 100 2.56 11.23
CO 84 2.15 9.43
PM10 7.6 0.19 0.85PM2.5 7.6 0.19 0.85SO20.6 0.02 0.07
VOC 5.5 0.14 0.62Lead0.0005 0.00 0.00 COHAP0.05 0.21 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)ReferenceCO2 (mass basis)1 120,000 3,075 13,471
Methane (mass basis)25 2.3 0.06 0.26N2O (mass basis)298 2.2 0.06 0.25CO2e13,551
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference2-Methylnaphthalene 2.40E-05 6.15E-07 2.69E-063-Methylchloranthrene 1.80E-06 4.61E-08 2.02E-077,12-Dimethylbenz(a)anthracene 1.60E-05 4.10E-07 1.80E-06 CO2
Acenaphthene 1.80E-06 4.61E-08 2.02E-07 Lead
Acenaphthylene 1.80E-06 4.61E-08 2.02E-07 N2O
Anthracene 2.40E-06 6.15E-08 2.69E-07
Benz(a)anthracene 1.80E-06 4.61E-08 2.02E-07 PM (total)
Benzene 2.10E-03 5.38E-05 2.36E-04 PM (cond)Benzo(a)pyrene 1.20E-06 3.08E-08 1.35E-07 PM (filter)Benzo(b)fluoranthene 1.80E-06 4.61E-08 2.02E-07 SO2Benzo(g,h,i)perylene 1.20E-06 3.08E-08 1.35E-07 TOC

Natural Gas-Fired Boilers & Heaters
Manufacturer Data
or AP-42 Table 1.4-1
AP-42 Table 1.4-2
AP-42 Table 1.4-2
&
Table A-1 to
Subpart A of Part 98
Emission Factor
(lb/10^6 scf)
Benzo(k)fluoranthene 1.80E-06 4.61E-08 2.02E-07 MethaneChrysene1.80E-06 4.61E-08 2.02E-07 VOCDibenzo(a,h)anthracene 1.20E-06 3.08E-08 1.35E-07Dichlorobenzene1.20E-03 3.08E-05 1.35E-04
Fluoranthene 3.00E-06 7.69E-08 3.37E-07 CO2
Fluorene 2.80E-06 7.18E-08 3.14E-07 Methane
Formaldehyde 7.50E-02 1.92E-03 8.42E-03 N2O
Hexane 1.80E+00 4.61E-02 2.02E-01 CO2e
Indeno(1,2,3-cd)pyrene 1.80E-06 4.61E-08 2.02E-07Naphthalene6.10E-04 1.56E-05 6.85E-05 HAP - OrgaPhenanathrene1.70E-05 4.36E-07 1.91E-06Pyrene5.00E-06 1.28E-07 5.61E-07Toluene3.40E-03 8.71E-05 3.82E-04
Arsenic 2.00E-04 5.13E-06 2.25E-05
Beryllium 1.20E-05 3.08E-07 1.35E-06
Cadmium 1.10E-03 2.82E-05 1.23E-04
Chromium 1.40E-03 3.59E-05 1.57E-04Cobalt8.40E-05 2.15E-06 9.43E-06Manganese3.80E-04 9.74E-06 4.27E-05Mercury2.60E-04 6.66E-06 2.92E-05Nickel2.10E-03 5.38E-05 2.36E-04
Selenium 2.40E-05 6.15E-07 2.69E-06
HAP - Meta
AP-42 Table 1.4-3
AP-42 Table 1.4-4
Total HAP
ppm to lb/M
Source: AQ
NoxCO
Heating Value of Natural Gas 1020 BTU/scf or MMBtu/MMscf
Size Table 1.4-1 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check
>100 MMBtu/hr Uncontrolled - Pre NSPS (Subparts D & Db)280 0.2745 7.18 31.43
>100 MMBtu/hr Uncontrolled - Post NSPS (Subparts D & Db)190 0.1863 4.87 21.33
>100 MMBtu/hr Controlled - Low Nox burners 140 0.1373 3.59 15.72
>100 MMBtu/hr Controlled - Flue gas recirculation (FGR)100 0.0980 2.56 11.23 Match
<100 MMBtu/hr Uncontrolled 100 0.0980 2.56 11.23 Match
<100 MMBtu/hr Controlled - Low Nox burners 50 0.0490 1.28 5.61
<100 MMBtu/hr Controlled - Low Nox burners/FGR 32 0.0314 0.82 3.59
Tangential-Fired Uncontrolled 170 0.1667 4.36 19.08Tangential-Fired Controlled - FGR 76 0.0745 1.95 8.53
Size Table 1.4-1 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check>100 MMBtu/hr Uncontrolled - Pre NSPS (Subparts D & Db)84 0.0824 2.15 9.43 Match>100 MMBtu/hr Uncontrolled - Post NSPS (Subparts D & Db)84 0.0824 2.15 9.43 Match
>100 MMBtu/hr Controlled - Low Nox burners 84 0.0824 2.15 9.43 Match>100 MMBtu/hr Controlled - Flue gas recirculation (FGR)84 0.0824 2.15 9.43 Match
<100 MMBtu/hr Uncontrolled 84 0.0824 2.15 9.43 Match<100 MMBtu/hr Controlled - Low Nox burners 84 0.0824 2.15 9.43 Match<100 MMBtu/hr Controlled - Low Nox burners/FGR 84 0.0824 2.15 9.43 Match
Tangential-Fired Uncontrolled 24 0.0235 0.62 2.69
Tangential-Fired Controlled - FGR 98 0.0961 2.51 11.00
Any Size Table 1.4-2 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check120,000 117.6471 3,075 13,471 Match
0.0005 0.0000 0.00 0.00 Match
Uncontrolled 2.2 0.0022 0.06 0.25 Match
Controlled - Low Nox burners 0.64 0.0006 0.02 0.07
7.6 0.0075 0.19 0.85 Match
5.7 0.0056 0.15 0.641.9 0.0019 0.05 0.210.6 0.0006 0.02 0.07 Match110.0108 0.28 1.23
2.3 0.0023 0.06 0.26 Match5.5 0.0054 0.14 0.62 Match
Global Warming Potential lb/hr Ton/year13,075 13,471
25 1 6
298 17 74
Total CO2e 3,094 13,551 Match
anic Table 1.4-3 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check2-Methylnaphthalene 2.40E-05 2.35E-08 6.15E-07 2.69E-06 Match3-Methylchloranthrene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 Match7,12-Dimethylbenz(a)anthracene 1.60E-05 1.57E-08 4.10E-07 1.80E-06 Match
Acenaphthene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 Match
Acenaphthylene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 Match
Anthracene 2.40E-06 2.35E-09 6.15E-08 2.69E-07 Match
Benz(a)anthracene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 MatchBenzene2.10E-03 2.06E-06 5.38E-05 2.36E-04 MatchBenzo(a)pyrene 1.20E-06 1.18E-09 3.08E-08 1.35E-07 MatchBenzo(b)fluoranthene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 MatchBenzo(g,h,i)perylene 1.20E-06 1.18E-09 3.08E-08 1.35E-07 Match
Benzo(k)fluoranthene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 Match
Chrysene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 Match
Dibenzo(a,h)anthracene 1.20E-06 1.18E-09 3.08E-08 1.35E-07 Match
Dichlorobenzene 1.20E-03 1.18E-06 3.08E-05 1.35E-04 Match
Fluoranthene 3.00E-06 2.94E-09 7.69E-08 3.37E-07 MatchFluorene2.80E-06 2.75E-09 7.18E-08 3.14E-07 MatchFormaldehyde7.50E-02 7.35E-05 1.92E-03 8.42E-03 MatchHexane1.80E+00 1.76E-03 4.61E-02 2.02E-01 Match
Indeno(1,2,3-cd)pyrene 1.80E-06 1.76E-09 4.61E-08 2.02E-07 Match
Naphthalene 6.10E-04 5.98E-07 1.56E-05 6.85E-05 Match
Phenanathrene 1.70E-05 1.67E-08 4.36E-07 1.91E-06 Match
Pyrene 5.00E-06 4.90E-09 1.28E-07 5.61E-07 Match
Toluene 3.40E-03 3.33E-06 8.71E-05 3.82E-04 Match
al Table 1.4-4 lb/10^6 scf lb/MMBtu lb/hr Ton/year CheckArsenic2.00E-04 1.96E-07 5.13E-06 2.25E-05 MatchBeryllium1.20E-05 1.18E-08 3.08E-07 1.35E-06 MatchCadmium1.10E-03 1.08E-06 2.82E-05 1.23E-04 MatchChromium1.40E-03 1.37E-06 3.59E-05 1.57E-04 Match
Cobalt 8.40E-05 8.24E-08 2.15E-06 9.43E-06 Match
Manganese 3.80E-04 3.73E-07 9.74E-06 4.27E-05 Match
Mercury 2.60E-04 2.55E-07 6.66E-06 2.92E-05 MatchNickel2.10E-03 2.06E-06 5.38E-05 2.36E-04 MatchSelenium2.40E-05 2.35E-08 6.15E-07 2.69E-06 Match
Total HAP lb/hr Ton/year Check
0.05 0.21 Match
MMBtu Conversion.
QMD Permit Sample Evaluation Natural Gas Fired Boiler 5-20 MMBTU/HR, 2007
Nox Molecular Weight 46.1 lb/lb-mole
CO Molecular Weight 28.01 lb/lb-mole
Concentration lb/MMBtu lb/hr Ton/year Check000.00 0.00000.00 0.00
Lucia Mason <[e-mail]>
Intermontain galvanizing air operating permit renewal
8 messages
Buck, Sally <[e-mail]>Mon, Jul 29, 2024 at 12:19 PM
To: "[e-mail]" <[e-mail]>
Please call Sally Buck 4029160047
Sent from my iPhone
The information contained in this E-mail message and the documents accompanying this message are privileged and confidential, and may be protected from
disclosure. Please be aware that any use, printing, copying, disclosure or dissemination of this communication may be subject to legal restriction or sanction. If
you think that you have received this E-mail message in error, please reply to the sender.
Lucia Mason <[e-mail]>Wed, Jul 31, 2024 at 12:34 PM
To: "Buck, Sally" <[e-mail]>
Hi Sally,
I just gave you a call but I figured I'd email you as well. The Utah Division of Air Quality is conducting a 10- Year Review of Valmont Coatings Inc. Intermountain
Galvanising Facility and the Approval Order (AO) associated with it (DAQE-AN108330005-12).
Our 10- Year Review process will primarily update the formatting and language of the AO to make it similar to modern permits. The permit requirements will stay the
same unless federal laws have changed since the AO was issued. If this is the case, requirements in your AO may be subject to change. Your company will NOT be
charged for this project.
To update your permit we need the most recent contact information for Valmont Galvanizing. Please confirm, update or add as much of the following information as
possible:
Site Name: Valmont Coatings, Inc. - Intermountain Galvanizing- Galvanizing Facility
Source Address/Contact:
Physical Address: 1085 West 400 North, Lindon UT 84042
Billing Address: 1085 West 400 North, Lindon UT 84042
Work Fax Number: [phone]
Work Phone Number: [phone]
Email: provide if available
10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…1/7
Company Address/Contact:
Physical Address: 1085 West 400 North, Lindon UT 84042
Mailing Address: 1085 West 400 North, Lindon UT 84042
Work Fax Number: [phone]
Work Phone Number: [phone]
Email: provide if available
Relevant Individuals:
Primary Approval Order Contact:
Name: Ellen Dasher
Physical Address: 1085 West 400 North, Lindon UT 84042
Work Fax Number: provide if available
Work Phone Number: (402) 963 - 1129
Email: [e-mail]
Billing Contact:
Name: Ellen Dasher
Physical Address: 1085 West 400 North, Lindon UT 84042
Work Fax Number: provide if available
Work Phone Number: (402) 963 - 1129
Email: [e-mail]
Additionally, our latest compliance report says that you removed one of your sulfuric acid tanks and your 9 MBtu/hr molten zinc kettle has been taken offline with no
plans for further use. Is that accurate? If so, would you like your permit updated to reflect those changes?
Please let me know if you have any questions. Thanks for your time.
Best regards,
Lucia
[Quoted text hidden]
Buck, Sally <[e-mail]>Fri, Aug 2, 2024 at 6:11 AM
To: Lucia Mason <[e-mail]>
Site contact is the general manager Eva Snow, Eva.Snow@Valmont .com. Site phone number and address. Secondary contact is [e-mail]
(also at site address and phone no). Billing contact is also Eva Snow.
The site has all previously permitted process equipment still in operation. The old kettle which was not operating, has been removed, but the primary kettle listed in
the current operating permit is currently operating. We also still operate the dust collector and associated blast booth on the powder paint line.
We only have and only need one kettle with a NG furnace, one boiler 4 acid tanks, one caustic tank , one preflux tank, and 2 rinse tanks.
10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…2/7
Please let me know a good time to call and discuss. I will want to review the draft permit language prior to issuance of possible I am in the office all next week on
pacific time.
Sent from my iPhone
On Jul 31, 2024, at 11:34 AM, Lucia Mason <[e-mail]> wrote:
[Quoted text hidden]
Lucia Mason <[e-mail]>Mon, Aug 5, 2024 at 12:41 PM
To: "Buck, Sally" <[e-mail]>
Hi Sally,
I'm around anytime before 4 Pacific time today and before 11 am tomorrow. If that doesn't work for you I can provide more availability.
I'll make sure the Approval Order is sent to you for review before being issued.
A phone call will be really useful as far as understanding your process and equipment. However, I'm going to need written confirmation to update your
equipment list regardless.
After talking on the phone could you reply to this email with edits to the equipment I've listed below? I also want to confirm that I'm correctly understanding what
tanks some of the requirements in the old permit apply to. My current understanding is that the three tanks I've marked with an asterisk below are subject to
temperature and concentration requirements. Let me know if that is correct when you reply to this email.
Two (2) natural gas-fired boilers (do you only use one now?)
Manufacturer: Sellers
Model: #LN490
Power Rating: 80 bhp

One (1) shot blaster with attached dust collector
Airless centrifugal steel shot blaster
Equipped with a dust collector discharged inside the building
Manufacturer: Wheelabrator

One (1) coating booth with attached dust collector
Electrostatic powder coating booth
Equipped with a cartridge dust collector discharged into the building
Designer: Valmont Industries

10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…3/7
One (1) curing oven
Manufacturer: Milbank Systems
Fuel type: Natural gas-fired
Power rating: 1 MMBtu/hr

Two (2) molten zinc kettles
Tanks #1 (has this been taken offline)
Power rating: 9 MMBtu/hr

Tank #2
Power rating: 6 MMBtu/hr

Four (4) Sulfuric acid pickling tanks* (are only three used now?)

Two (2) caustic soda tanks*
Tanks #1 and #2
One (1) zinc/ammonium chloride pre-flux tank*

One (1) metallic zinc recovery (MZR) unit
Zinc recovery unit to retrieve metallic zinc from the kettle-skims
Model: 750
Fuel type: natural gas
Rated capacity 1,329 lbs/batch

Assorted Tanks
One (1) caustic rinse tank
Two (2) sulfuric acid rinse tanks
One (1) water quench tank
One (1) chromate quench tank
For informational purposes only
[Quoted text hidden]
Buck, Sally <[e-mail]>Fri, Aug 23, 2024 at 1:34 PM
To: Lucia Mason <[e-mail]>
Cc: "Snow, Eva M." <[e-mail]>, "Nicholes, Phil" <[e-mail]>, "Rhodes, Carl P." <[e-mail]>
Lucia
Sorry this has taken me so long. I am in all day today and Monday morning if you have further questions.
10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…4/7

Email for Eva Snow is [e-mail], but an email for the permit contact should be [e-mail]. That email will
always go to the active site manager and the active regional manager for the site. Much better for long term continuity.

The combustion units are the Horizontal Hot water immersion Boiler, (Metallics Zinc Recovery unit (400,000 BTU) and the kettle furnace.
1. 2 Boilers in tandem- natural gas fired 2.6 MMBTu each
2. Kettle Furnace with CIC furnace using 4 Hauck burners SVG135 (the Steel vessel was replaced in 2023 same size and specifications)
Heating system unchanged at 6 MMBTu total (4 burners @ 1.5 MMBTU)
3. Metallics Zinc Recovery unit (400,000 BTU)
Process tanks on site:
2 Caustic (8-16% NaOH)
3 Rinse Tanks
3-4 Acid Tanks (6-12% H2SO4)
1 PreFlux (ZnNH4Cl) 1
1-2 Post HDG Water Quench

I think this is all you needed. Please let me know when the draft permit language will be available.
Sally

Sally Buck, Valmont Coatings Environmental Manager North America
402-916-0047
[e-mail]
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o Name: Ellen Dasher
10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…5/7
o Physical Address: 1085 West 400 North, Lindon UT 84042
o Work Fax Number: provide if available
o Work Phone Number: (402) 963 - 1129
o Email: [e-mail]

· Billing Contact:
o Name: Ellen Dasher
o Physical Address: 1085 West 400 North, Lindon UT 84042
o Work Fax Number: provide if available
o Work Phone Number: (402) 963 - 1129
o Email: [e-mail]

Additionally, our latest compliance report says that you removed one of your sulfuric acid tanks and your 9 MBtu/hr molten zinc kettle has been
taken offline with no plans for further use. Is that accurate? If so, would you like your permit updated to reflect those changes?

Please let me know if you have any questions. Thanks for your time.

Best regards,

Lucia
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Lucia Mason <[e-mail]>Mon, Aug 26, 2024 at 7:17 AM
To: "Buck, Sally" <[e-mail]>
Hi Sally,
Unless something comes up in internal reviews this should be all the information I need. The way our permitting system pulls emails from our database is a little
funny. To get the "info" email on the permit I'm going to list it under Philip's contact. It will also be listed as the site and company email address.
10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…6/7
I'll make sure to send the draft over to you once it's gone through internal reviews. Let me know if you have any questions and thanks for all your help!
Lucia
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Buck, Sally <[e-mail]>Tue, Sep 24, 2024 at 10:31 AM
To: Lucia Mason <[e-mail]>
I do have some comments and I am reviewing that with Eva. I should have the new language back to you by end of week.
Sally

From: Lucia Mason <[e-mail]>
Sent: Monday, August 26, 2024 6:18 AM
To: Buck, Sally <[e-mail]>
Subject: Re: Intermontain galvanizing air operang permit renewal

Hi Sally, Unless something comes up in internal reviews this should be all the information I need. The way our permitting system pulls emails from our database is a little funny. To get the "info" email on the permit I'm going
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Lucia Mason <[e-mail]>Tue, Sep 24, 2024 at 11:57 AM
To: "Buck, Sally" <[e-mail]>
Sounds good. There are some elements of the permit I won't be able to change but I'm happy to make any adjustments within my control. Let me know when you
have a completed draft.
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10/30/24, 2:34 PM State of Utah Mail - Intermontain galvanizing air operating permit renewal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805938504981870303&simpl=msg-f:1805938504981870303&simpl=msg-a:r7097495845916093130&simpl=…7/7
Lucia Mason <[e-mail]>
Six 10-Year Review Projects
2 messages
Alan Humpherys <[e-mail]>Wed, Jun 12, 2024 at 9:49 AM
To: Lucia Mason <[e-mail]>
Lucia,
Please work on the following 10-year review projects.
Site #1: 12132
Peer: Christine
Old AO: DAQE-AN121320016-22, Feb 23, 2022
Notes: II.B.3.b should state "baghouses" instead of just "baghouse." I'll add it to the list to review.
Site #2: 14016
Peer: Tim
Old AO: DAQE-AN0140160001-07, May 17, 2007
Site #3: 12736
Peer: EQ
Old AO: DAQE-AN2736002-06, Jan 13, 2006
Site #4: 10270
Peer: Dungan
Old AO: DAQE-412-00, July 6, 2000
Notes: Needs name change (was Metalcraft) (same or different?)
Site #5: 12202
Peer: Dungan
Old AO: DAQE-817-01, Oct 4, 2001
Notes: Needs name change (was Metalcraft) (same or different?)
Site #6: 10833
Peer: Dylan
Old AO: DAQE-AN108330005-12, Nov 28, 2012
Thanks,
Alan
8/20/24, 11:43 AM State of Utah Mail - Six 10-Year Review Projects
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801671042937908281&simpl=msg-f:1801671042937908281&simpl=msg-a:r3589728101253066642 1/2
--
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.
Lucia Mason <[e-mail]>Wed, Jun 12, 2024 at 12:12 PM
To: Alan Humpherys <[e-mail]>
Ok great! I just met with Teri to set up macros and get an overview of TEMO. I'll start working through one of the ten year reviews before meeting with you later
today.
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8/20/24, 11:43 AM State of Utah Mail - Six 10-Year Review Projects
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801671042937908281&simpl=msg-f:1801671042937908281&simpl=msg-a:r3589728101253066642 2/2