DAQ-2024-011858

DAQE-AN109540002-24

{{$d1 }}

Sterling Jensen
Richards Sheet Metal
2680 Industrial Drive
Ogden, UT 84401
[e-mail]

Dear Mr. Jensen:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-0251-93 for a 10-Year
Review and Permit Updates
Project Number: N109540002

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. Richards Sheet Metal 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: Weber-Morgan 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 25, 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")}}
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APPROVAL ORDER
DAQE-AN109540002-24
Administrative Amendment to Approval Order DAQE-0251-93
for a 10-Year Review and Permit Updates

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

Issued to
Richards Sheet Metal - Steel Parts Manufacturing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

November 25, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN109540002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Richards Sheet Metal Richards Sheet Metal - Steel Parts Manufacturing Facility

Mailing Address Physical Address
2680 Industrial Drive 2680 Industrial Drive
Ogden, UT 84401 Ogden, UT 84401

Source Contact UTM Coordinates
Name: Sterling Jensen 415,138 m Easting
Phone: [phone],563,315 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3444 (Sheet Metal Work)

SOURCE INFORMATION
General Description
Richards Sheet Metal manufactures sheet metal and steel parts in Ogden, Weber County. The facility
consists of three (3) production buildings and an administration office. The primary emission unit at the
facility is a paint booth. The paint booth is located on the east side of the building and is vented through
an uncontrolled stack.

NSR Classification
10-Year Review

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

Applicable Federal Standards
None
Project Description
This administrative amendment is to AO DAQE-0251-93, dated April 12, 1993. The DAQ is conducting
a 10-year review of the source and is updating the language and format of the 1993 AO. There are no
changes to the operations taking place at the steel parts manufacturing facility.

DAQE-AN109540002-24
Page 4

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
Carbon Monoxide 0.05
Nitrogen Oxides 0.21
Particulate Matter - PM10 1.47
Particulate Matter - PM2.5 1.47
Volatile Organic Compounds 7.54

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Chromium Compounds (CAS #CMJ500) 88
Cobalt Compounds (CAS #CNB850) 1
Lead (CAS #7439921) 7
Methanol (CAS #67561) 2021
Toluene (CAS #108883) 4041
Xylenes (Isomers And Mixture) (CAS #1330207) 1078
Change (TPY) Total (TPY)
Total HAPs 3.62

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]

DAQE-AN109540002-24
Page 5

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 Richards Sheet Metal Steel Parts Manufacturing Facility
II.A.2 Spray Painting Booth One (1) Paint Booth Dimensions: 44' long x 14' wide x 20' high

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall post a copy of this AO on site. The owner/operator shall make the AO available to employees who operate the air emission-producing equipment, and the owner/operator shall provide these employees with instructions as to their responsibilities operating the equipment in compliance with the relevant conditions listed below. [R307-401-8] II.B.1.b The owner/operator shall not consume more than the following: A. 2,000 gallons of paint per rolling 12-month period B. 1,200 gallons of paint thinner per rolling 12-month period. [R307-401-8]
II.B.1.b.1 The owner/operator shall: A. Determine consumption using invoice records of paints and thinners purchased B. Record consumption on a daily basis C. Use consumption records to calculate a rolling 12-month total based on the first day of each month using records from the previous 12 months D. Keep consumption records for all periods when the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall not allow visible emissions from any point or fugitive emission source associated with the installation of control facilities to exceed 10% opacity on site. [R307-401-8]
DAQE-AN109540002-24
Page 6

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirements for observations to be made at 15-second intervals over a six-minute period shall not apply. Any time interval with no visible emissions shall not be included. [R307-401-8] II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall only use natural gas as fuel in the plant heating/cooling system. [R307-401-8] II.B.3 Paint Booth Requirements
II.B.3.a The owner/operator shall equip the paint booth with: A. Twenty-four (24) 20" x 25" x 2" intake filters B. Twenty-four (24) 20" x 25" x 2" exhaust paint arrestor filters C. One (1) exhaust fan rated to 14,000 Actual Cubic Feet Per Minute (ACFM) D. One (1) vent, 30" in diameter, which shall extend no less than 8' above the building roof and shall vent vertically into the atmosphere. [R307-401-8]
II.B.3.b The owner/operator shall equip the spray booth with Research Product Corporation paint arrestor
particulate pads (stock no. 3031), or equivalent, to control particulate emissions. All exhaust air from the spray booth shall be routed through the arrestor particulate pads, or equivalent, before
being vented to the atmosphere. [R307-401-8]

II.B.4 VOC Requirements II.B.4.a The owner/operator shall not emit more than 7.54 tons per rolling 12-month period of VOCs
from evaporative sources (paints and thinners) on site. [R307-401-8]

II.B.4.a.1 The owner/operator shall calculate a new 12-month total by the 1st day of each month using data from the previous 12 months. The owner/operator shall use a mass balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] [R307-401-8]
II.B.4.a.2 The owner/operator shall keep a record each month for all times the plant is in operation containing the following:

A. The name of the VOC-emitting material (paint, thinner, reducers, etc.)

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

C. The density of each material used

D. The volume of each VOC-emitting material used daily

E. The amount of VOCs emitted from each material.

[R307-401-8]

DAQE-AN109540002-24
Page 7

II.B.4.b The owner/operator shall comply with all applicable requirements of UAC R307-350. Miscellaneous Metal Parts and Products Coatings. [R307-350]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-0251-93 dated April 12, 1993

DAQE-AN109540002-24
Page 8

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-

RN109540002 November 18, 2024 Sterling Jensen
Richards Sheet Metal 2680 Industrial Drive Ogden, UT 84401
[e-mail] Dear Sterling Jensen,
Re: Engineer Review - Administrative Amendment to Approval Order DAQE-0251-93 for a 10-Year Review and Permit Updates Project Number: N109540002 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. Richards Sheet Metal should complete this review within 10 business days of receipt. Richards Sheet Metal 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 Richards Sheet Metal does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Richards Sheet Metal 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 N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N109540002 Owner Name Richards Sheet Metal Mailing Address 2680 Industrial Drive
Ogden, UT, 84401 Source Name Richards Sheet Metal- Steel Parts Manufacturing Facility
Source Location 2680 Industrial Drive Ogden, UT 84401
UTM Projection 415,138 m Easting, 4,563,315 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3444 (Sheet Metal Work) Source Contact Sterling Jensen Phone Number [phone] Email [e-mail] Billing Contact Terry Pion Phone Number [phone]
Email [e-mail] Project Engineer Lucia Mason, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 13, 2024 Date of Accepted Application September 5, 2024

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 2024 Page 2
SOURCE DESCRIPTION General Description
Richards Sheet Metal manufactures sheet metal and steel parts in Ogden, Weber County. The facility consists of three production buildings and an administration office. The primary emission unit at the facility is a paint booth. The paint both is located on the east side of the building and is
vented through an uncontrolled stack. NSR Classification: 10 Year Review Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Weber County Airs Source Size: B Applicable Federal Standards
None Project Proposal
Administrative Amendment to Approval Order DAQE-0251-93 for a 10-Year Review and Permit Updates
Project Description This administrative amendment is to Approval Order DAQE-0251-93, dated April 12, 1993. The DAQ is conducting a 10-year review of the source and is updating the language and format of the 1993 AO. There are no changes to the operations taking place at the steel parts manufacturing facility. EMISSION IMPACT ANALYSIS This is a 10-year review. No changes to equipment or emissions are being made at this time. Therefore, modeling is not required.
[Last updated September 24, 2024]

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 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) Carbon Monoxide 0.05 Nitrogen Oxides 0.21
Particulate Matter - PM10 1.47
Particulate Matter - PM2.5 1.47
Volatile Organic Compounds 7.54

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Chromium Compounds (CAS #CMJ500) 88 Cobalt Compounds (CAS #CNB850) 1
Lead (CAS #7439921) 7
Methanol (CAS #67561) 2021
Toluene (CAS #108883) 4041
Xylenes (Isomers And Mixture) (CAS #1330207) 1078
Change (TPY) Total (TPY) Total HAPs 3.62 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 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 changes to equipment or emissions are being made at this time. Therefore, a BACT analysis is not required. [Last updated September 24, 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 N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 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 NEW Richards Sheet Metal Steel Parts Manufacturing Facility
II.A.2 NEW Spray Painting Booth One (1) Paint Booth Dimensions: 44' long x 14' wide x 20' high

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 2024 Page 6
SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 NEW Site-Wide Requirements
II.B.1.a NEW The owner/operator shall post a copy of this AO on site. The owner/operator shall make the AO available to employees who operate the air emission producing equipment and the owner/operator shall provide these employees with instructions as to their responsibilities operating the equipment in compliance with the relevant conditions listed below. [R307-401-8]
II.B.1.b
NEW
The owner/operator shall not consume more than the following:
A. 2,000 gallons of paint per rolling 12-month period B. 1,200 gallons of paint thinner per rolling 12-month period [R307-401-8]
II.B.1.b.1 NEW The owner/operator shall: A. Determine consumption using invoice records of paints and thinners purchased B. Record consumption on a daily basis C. Use consumption records to calculate a rolling 12-month total based on the first day of
each month using records from the previous 12 months D. Keep consumption records for all periods when the plant is in operation [R307-401-8] II.B.1.c NEW The owner/operator shall not allow visible emissions from any point or fugitive emission source associated with the installation of control facilities to exceed 10% opacity on site.
[R307-401-8] II.B.1.c.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirements for observations to be made at 15 second intervals over a six-minute period shall not apply. Any time interval with no visible emissions shall not be included. [R307-401-8]

II.B.2 NEW Fuel Requirements
II.B.2.a NEW The owner/operator shall only use natural gas as fuel in the plant heating/cooling system. [R307-401-8]

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 2024 Page 7
II.B.3 NEW Paint Booth Requirements
II.B.3.a NEW The owner/operator shall equip the paint booth with: A. Twenty-four (24) 20" x 25" x 2" intake filters
B. Twenty-four (24) 20" x 25" x 2" exhaust paint arrestor filters
C. One (1) exhaust fan rated to 14,000 Actual Cubic Feet Per Minute (ACFM)
D. One (1) vent, 30" in diameter, which shall extend no less than 8' above the building
roof and shall vent vertically into the atmosphere
[R307-401-8]

II.B.3.b NEW The owner/operator shall equip the spray booth with Research Product Corporation paint arrestor particulate pads (stock no. 3031), or equivalent, to control particulate emissions. All exhaust air from the spray booth shall be routed through the arrestor particulate pads, or equivalent, before being vented to the atmosphere. [R307-401-8] II.B.4 NEW VOC Requirements
II.B.4.a NEW The owner/operator shall not emit more than 7.54 tons per rolling 12-month period of VOCs from evaporative sources (paints and thinners) on site. [R307-401-8]

II.B.4.a.1 NEW The owner/operator shall calculate a new 12-month total by the 1st day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]

II.B.4.a.2 NEW The owner/operator shall keep record each month for all times the plant is in operation containing the following: A. The name of the VOC-emitting material (paint, thinner, reducers, etc.) B. The percent by weight of VOCs in each material used
C. The density of each material used
D. The volume of each VOC-emitting material used daily
E. The amount of VOCs emitted from each material [R307-401-8]
II.B.4.b NEW The owner/operator shall comply with all applicable requirements of UAC R307-350. Miscellaneous Metal Parts and Products Coatings. [R307-350]

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 2024 Page 8
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-0251-93 dated April 12, 1993
REVIEWER COMMENTS
1. Comment regarding 10-Year Review:
This is a 10-year review. The language and formatting of this AO have been updated to reflect the style of modern permits. PTE values and the approved equipment list have been moved to respective new sections. The source is not modifying and/or installing any equipment. The PTE for PM2.5 was not specified in the previous AO (DAQE-0251-93 dated April 12, 1993). For a conservative estimate, the PTE of PM2.5 was set equal to the PTE of PM10 (1.47 tpy). There are no other changes to the emission estimates at this time.
[Last updated September 25, 2024] 2. Comment regarding Federal Standard Applicability: 40 CFR 60 (NSPS)
There are no applicable NSPS subparts. 40 CFR 61 (NESHAP) There are no applicable NESHAP subparts. 40 CFR 63 (MACT) There are no applicable MACT subparts. [Last updated November 14, 2024]
3. Comment regarding Title V Requirements: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants.
4. Any Title IV affected source.
This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. There are no other reasons why this source would be required to obtain a Part 70 permit as an area source; thus, Title V does not apply as per R307-415-4(2)(c).
[Last updated November 18, 2024]

Engineer Review N109540002: Richards Sheet Metal- Steel Parts Manufacturing Facility November 18, 2024 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 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
Lucia Mason <[e-mail]>
5 New 10-year reviews
1 message
Alan Humpherys <[e-mail]>Thu, Jun 13, 2024 at 8:08 AM
To: Lucia Mason <[e-mail]>
Lucia,
Here are 5 more 10-year reviews. They were initially started by another engineer, so the projects are created with some work done already. Please let me know
what questions you have.
Project #1: 12188-0006
Old AO: DAQE-AN2188004-05
Peer: EQ
Project #2: 12101-0007
Old AO: DAQE-493-01
Peer: Tim
Site #3: 10520-0004
Old AO: DAQE-1041-93
Peer: Dylan
Site #4: 10954-0002
Old AO: DAQE-251-93
Peer: Christine
Site #5: 10017-0004
Old AO: DAQE-AN0100170001-09
Peer: Tim
Thanks,
Alan
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
9/9/24, 12:39 PM State of Utah Mail - 5 New 10-year reviews
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801755276052051181&simpl=msg-f:1801755276052051181 1/2
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
9/9/24, 12:39 PM State of Utah Mail - 5 New 10-year reviews
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801755276052051181&simpl=msg-f:1801755276052051181 2/2
Lucia Mason <[e-mail]>
DAQ Approval Order Review, 10954: Richards Sheet Metal- Richard Sheet Metal
3 messages
Lucia Mason <[e-mail]>Mon, Nov 18, 2024 at 12:27 PM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
The DAQ has completed Richards Sheet Metal's updated Approval Order. Before it's issued you have ten days to review the document. Please get back to me with
any questions or concerns by 11/28. If you approve of the document, please return a signed copy. The updated permit is attached.
Hope you're having a good start to your week,
Lucia
#6 SOURCE RN109540002.rtf
1492K
Sterling Jensen <[e-mail]>Tue, Nov 19, 2024 at 7:16 AM
To: Lucia Mason <[e-mail]>
Lucia,

What is stated on the Approval Order appears to be correct and prudent. Please find aached the signed document.

Kind regards,

Sterling N. Jensen
President
801-436-1419 (direct)
11/19/24, 8:43 AM State of Utah Mail - DAQ Approval Order Review, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-287152893967838773&simpl=msg-a:r3217888825905543636&simpl=msg-f:1816160687596397500&simpl=…1/2
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.
[Quoted text hidden]
[e-mail]_20241118_164326.pdf
473K
Lucia Mason <[e-mail]>Tue, Nov 19, 2024 at 7:29 AM
To: Sterling Jensen <[e-mail]>
Thank you.
[Quoted text hidden]
11/19/24, 8:43 AM State of Utah Mail - DAQ Approval Order Review, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-287152893967838773&simpl=msg-a:r3217888825905543636&simpl=msg-f:1816160687596397500&simpl=…2/2
Lucia Mason <[e-mail]>
Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
7 messages
Lucia Mason <[e-mail]>Thu, Oct 3, 2024 at 10:02 AM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
The most recent compliance report for Richard's Sheet Metal mentions internally vented laser metal cutters and internally vented welding stations. Can you confirm
that you have this equipment on site? If so, would you like it to be added to your permit for informational purposes?
Thanks,
Lucia
Sterling Jensen <[e-mail]>Fri, Oct 4, 2024 at 11:28 AM
To: Lucia Mason <[e-mail]>
Lucia,

We do have laser cung machines and they all discharge through HEPA filtered baghouses which are maintained on a weekly basis. In line with the OSHA
standards for welding emissions, we shied several years ago to advanced process welding machines using solid wire only and specialized spray, pulse and
wave pulse procedures to eliminate welding fume and exhaust that you would normally see with Flux Core of Metal Cored wire. I do not see any reason why
these systems would need to be added to the permit. It had been discussed with prior auditors and they opinion aer looking at the operaon was it was not
needed or required.

Kind regards,

Sterling N. Jensen
President
801-436-1419 (direct)
11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…1/8
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Oct 15, 2024 at 11:06 AM
To: Sterling Jensen <[e-mail]>
Sounds good. The laser cutters and welding stations have been left off the permit.
Earlier you said the facility could be described by a combination of SIC codes 3443 and 3444. Fabricated Plate Work (boiler shops), SIC code 3443, is one of nine
source categories regulated by 40 CFR 63 Subpart XXXXXX which may require a number of notifications (initial and ongoing), recordkeeping, and visible emission
monitoring components.
Richards sheet metal would be subject to Subpart XXXXXX if the facility uses any materials that contain or have the potential to emit metal fabrication or finishing
metal HAP (MFHAP). [40 CFR 63 (MACT) Subpart XXXXXX]
MFHAP are defined as compounds of cadmium, chromium, lead, manganese, and nickel, or any of these metals in the elemental form excluding lead.
Materials that contain MFHAP are defined as "materials that contain cadmium, chromium, lead, or nickel in amounts greater than or equal to 0.1 percent
by weight (of the metal), and materials that contain manganese in amounts greater than or equal to 1.0 percent by weight (of the metal), as shown in
formulation data provided by the manufacturer or supplier, such as the Material Safety Data Sheet for the material." [40 CFR 63 (MACT) Subpart
XXXXXX]
You can view the full subpart text here: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-XXXXXX
Does the Richards Sheet Metal use any materials that would trigger Subpart XXXXXX?
Thanks for all your time,
Lucia
11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…2/8
[Quoted text hidden]
Lucia Mason <[e-mail]>Mon, Nov 4, 2024 at 3:05 PM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
Let me know if you have any updates on the applicability of Subpart XXXXXX at Richards Sheet metal.
Thank,
Lucia
[Quoted text hidden]
Sterling Jensen <[e-mail]>Thu, Nov 7, 2024 at 7:11 AM
To: Lucia Mason <[e-mail]>
Lucia,

Apologies for the delay in response. I have been traveling the past 2 weeks. I will get this checked on and back to you when I return.

Regards,

Sterling N. Jensen
President / CEO
801-436-1419 (office)
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…3/8
-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.

From: Lucia Mason <[e-mail]>
Sent: Monday, November 4, 2024 3:05 PM
To: Sterling Jensen <[e-mail]>
Subject: Re: Equipment Confirmaon, 10954: Richards Sheet Metal- Richard Sheet Metal

Hi Sterling,

Let me know if you have any updates on the applicability of Subpart XXXXXX at Richards Sheet metal.

Thank,

Lucia

On Tue, Oct 15, 2024 at 11:06 AM Lucia Mason <[e-mail]> wrote:
Sounds good. The laser cutters and welding stations have been left off the permit.

Earlier you said the facility could be described by a combination of SIC codes 3443 and 3444. Fabricated Plate Work (boiler shops), SIC code 3443, is one of
nine source categories regulated by 40 CFR 63 Subpart XXXXXX which may require a number of notifications (initial and ongoing), recordkeeping, and visible
11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…4/8
emission monitoring components.

Richards sheet metal would be subject to Subpart XXXXXX if the facility uses any materials that contain or have the potential to emit metal fabrication or
finishing metal HAP (MFHAP). [40 CFR 63 (MACT) Subpart XXXXXX]
· MFHAP are defined as compounds of cadmium, chromium, lead, manganese, and nickel, or any of these metals in the elemental form excluding
lead.
· Materials that contain MFHAP are defined as "materials that contain cadmium, chromium, lead, or nickel in amounts greater than or equal to 0.1
percent by weight (of the metal), and materials that contain manganese in amounts greater than or equal to 1.0 percent by weight (of the metal), as
shown in formulation data provided by the manufacturer or supplier, such as the Material Safety Data Sheet for the material." [40 CFR 63 (MACT)
Subpart XXXXXX]
You can view the full subpart text here: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-XXXXXX

Does the Richards Sheet Metal use any materials that would trigger Subpart XXXXXX?

Thanks for all your time,

Lucia

On Fri, Oct 4, 2024 at 11:29 AM Sterling Jensen <[e-mail]> wrote:
Lucia,

We do have laser cung machines and they all discharge through HEPA filtered baghouses which are maintained on a weekly basis. In line with the
OSHA standards for welding emissions, we shied several years ago to advanced process welding machines using solid wire only and specialized spray,
pulse and wave pulse procedures to eliminate welding fume and exhaust that you would normally see with Flux Core of Metal Cored wire. I do not see
any reason why these systems would need to be added to the permit. It had been discussed with prior auditors and they opinion aer looking at the
operaon was it was not needed or required.

Kind regards,

11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…5/8
Sterling N. Jensen
President
801-436-1419 (direct)
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Nov 7, 2024 at 7:12 AM
To: Sterling Jensen <[e-mail]>
Sounds good. Thanks for the update.
[Quoted text hidden]
Sterling Jensen <[e-mail]>Wed, Nov 13, 2024 at 10:52 AM
To: Lucia Mason <[e-mail]>
Lucia,

Aer reviewing the provided document we note that we do work in stainless steel which has chromium and nickel content greater than 0.1% of the base
material. Generally the grades of stainless steel we work in are type 304 and type 316. Those generally would have Chromium ranging from 16-20%, Nickel at
8 to 14% and Manganese at 2%. This represents approximately 10% of our annual output based on volume of material processed. Our primary material
processed is carbon steel components.

All of these materials are processed in our facility by shearing, punching (no fumes produced, or by laser cung. All laser equipment is installed with industry
approved HEPA filter systems with system controlled limits.
11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…6/8

All welding acvies at our facility are performed by using welding processes with reduced fume generaon capabilies, advanced process welding
procedure, solid wire filler metals, and opmized welding procedure specificaons and procedures to minimize any welding fume or visible emissions. On the
rare occasion when a customer specificaon is not able to be adjusted to accommodate these processes and procedures, we have mobile HEPA fume source
capture equipment and our welding personnel are provided with PAPR welding systems to provide safe breathable air on these occasions.

With regards to the document it would appear that only we only would be applicable to 63.11514, a, 2 and 8, and the products noted above that are
contained in the stainless steel we use.

As a note, the equipment manufactures of our laser systems we use for cung are Trumpf and Bystronic. Their engineering and manufacturing programs are
designed and operated to assure customers such as Richards that the equipment purchased and installed by them meet the criteria imposed by the countries
within which the equipment is operated.

Hopefully this is a sasfactory response to this inquiry.

In reviewing our past records it appears that we went through a similar acvity in 2016 without any problems. Our intenon is to always comply with any
regulaons regardless of what they may be and to provide our employees and the community we operate in a safe environment.

Kind regards,

Sterling N. Jensen
President
801-436-1419 (direct)
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…7/8
www.richards-fab.com

-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.

From: Lucia Mason [mailto:[e-mail]]
Sent: Monday, November 4, 2024 3:05 PM
[Quoted text hidden]
[Quoted text hidden]
11/14/24, 11:17 AM State of Utah Mail - Equipment Confirmation, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r7222470699482901632&simpl=msg-a:r-5816867969188781129&simpl=msg-f:1812005328968471886&simpl…8/8
Lucia Mason <[e-mail]>
Periodic Permit Review, 10954: Richards Sheet Metal- Richard Sheet Metal (Utah Division of Air Quality)
3 messages
Lucia Mason <[e-mail]>Wed, Jul 31, 2024 at 10:33 AM
To: [e-mail]
Hi Sterling,
Your Approval Order (AO) is due for its customary 10-year review. This review typically involves updating your old permit (DAQE-0251-93) to align with the
language and formatting of current AOs. As I began the review process, I noticed that you would likely qualify for a Small Source Exemption (SSE), as your annual
emissions appear to be below the thresholds that necessitate an AO.
Before proceeding with updates to your AO, I wanted to offer you the option to switch to an SSE. If you choose this route, you would no longer need to pay the
annual NSR fee or undergo regular compliance inspections.
To make this switch please submit an SSE application here:
https://utahgov.co1.qualtrics.com/jfe/form/SV_3t4JtgzRudum7l3
For more information about SSEs, you can visit the Department of Environmental Quality's website here:
https://deq.utah.gov/air-quality/new-source-review-exemptions-from-permitting-air-quality
Alternatively, you're welcome to maintain your current AO. If you choose to keep your existing permit, I will contact you to confirm your contact information and
discuss any relevant permit updates.
Please let me know how you would like to proceed. Feel free to reach out with any questions.
Best,
Lucia
Sterling Jensen <[e-mail]>Wed, Jul 31, 2024 at 4:13 PM
To: Lucia Mason <[e-mail]>
Thank you. I will get our July data entered and get the applicaon completed and returned.

Kind regards,
9/9/24, 12:39 PM State of Utah Mail - Periodic Permit Review, 10954: Richards Sheet Metal- Richard Sheet Metal (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-3611533936708313628&simpl=msg-a:r-4642683919185742902&simpl=msg-f:1806134446320158558&simpl…1/3

Sterling N. Jensen
President
801-436-1419 (direct)
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.
[Quoted text hidden]
Lucia Mason <[e-mail]>Wed, Jul 31, 2024 at 4:26 PM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
Sounds good. To add some clarification, from your most recent compliance report it's clear that you're under the SSE criteria pollutant limit of 5 tons/year (your VOC
emissions total to ~1.591 tons/year). That being said, I couldn't tell what your HAP breakdown looked like. Just be aware that you'll only qualify for a SSE if you
emit less than:
500lbs/year of each HAP individually and
2,000lbs/year of all HAPs combined
I suggested you look into a SSE because at the end of your most recent compliance report the inspector left a comment saying that "a small source exemption was
suggested to Mr. Jensen as most of their emissions come from painting operations which are now mostly outsourced."
Keep me posted on your progress.
9/9/24, 12:39 PM State of Utah Mail - Periodic Permit Review, 10954: Richards Sheet Metal- Richard Sheet Metal (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-3611533936708313628&simpl=msg-a:r-4642683919185742902&simpl=msg-f:1806134446320158558&simpl…2/3
Lucia
[Quoted text hidden]
9/9/24, 12:39 PM State of Utah Mail - Periodic Permit Review, 10954: Richards Sheet Metal- Richard Sheet Metal (Utah Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-3611533936708313628&simpl=msg-a:r-4642683919185742902&simpl=msg-f:1806134446320158558&simpl…3/3
Lucia Mason <[e-mail]>
SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
12 messages
Lucia Mason <[e-mail]>Thu, Aug 8, 2024 at 12:18 PM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
Thanks for your Small Source Exemption (SSE) application! I'm going to need some additional information before determining if you qualify for an SSE.
To be eligible for an SSE you must adhere three requirements which are described below (and can be referenced here: https://deq.utah.gov/air-quality/new-source-
review-exemptions-from-permitting-air-quality).
The first requirement is that a source must emit less than 5 tons/year of any criteria pollutant. You likely qualify here given that, according to your initial
submission, you primarily emit VOCs and are under 5 tons of annual emissions.
The second requirement is that a source must emit less than 500 pounds per year of any individual Hazardous Air Pollutant (HAP) and less than 2,000
pounds per year of all HAPs combined. Your initial submission didn't include any HAP emission records. Please add this to your application using any HAPs
listed on your paint SDSs. A complete list of HAPs can be found here: https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications.
The last requirement has the same limitations as the second, only it apples to toxic emissions that aren't listed as HAPs. This final requirement isn't applicable to
most sources but your original AO lists a series of toxic chemicals used at the facility that could result in unusual emissions. We need to confirm nothing toxic is
being emitted in large amounts so please add include any toxic emissions in your application even if the pollutant isn't listed as a HAP.
For all your calculations, please submit any spreadsheets, SDSs, consumption records, or other supporting documents you reference in your
calculations. We need these documents to confirm your annual emissions and process your application.
Please reach out with any questions. You can reach me at this email or by phone at [phone].
Thanks again,
Lucia
Sterling Jensen <[e-mail]>Thu, Aug 8, 2024 at 12:39 PM
To: Lucia Mason <[e-mail]>
Lucia,

9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…1/7
Thanks for the addional informaon. The above aached files are maintained on a monthly basis and indicate the amounts of coang products we bring in.
I will have my assistant go through the SDS for the items we list and check for HAP’s that may be components of the coang systems we use.

Kind regards,

Sterling N. Jensen
President
801-436-1419 (direct)
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.
[Quoted text hidden]
2 attachments
2024 Paint.xlsx
51K
2023 Paint.xlsx
55K
Lucia Mason <[e-mail]>Thu, Aug 8, 2024 at 1:05 PM
9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…2/7
To: Sterling Jensen <[e-mail]>
Sounds good. Thank you.
Do you have records from 2022? We'll need two years worth of data for the months between now and the end of the year.
[Quoted text hidden]
Sterling Jensen <[e-mail]>Thu, Aug 8, 2024 at 1:07 PM
To: Lucia Mason <[e-mail]>
Here is 2022. The 2024 is up to date through the end of July if I understand correctly or will be shortly.

Sterling
[Quoted text hidden]
2022 Paint.xlsx
56K
Lucia Mason <[e-mail]>Thu, Aug 8, 2024 at 1:09 PM
To: Sterling Jensen <[e-mail]>
Thanks!
[Quoted text hidden]
Sterling Jensen <[e-mail]>Mon, Aug 19, 2024 at 12:05 PM
To: Lucia Mason <[e-mail]>
Lucia,

I have had the data pulled from the SDS sheets and aer a rough analysis it would seem that we should remain under the current level of registraon.

Kind regards,

9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…3/7
Sterling N. Jensen
President
801-436-1419 (direct)
801-436-1420 (fax)
801-452-5630 (cell)
[e-mail]
www.richards-fab.com

-An ISO 9001:2015 Registered Company

The informaon contained in this message from Richards Sheet Metal Works, Inc. including any aachments, is confidenal and intended only for the named recipient(s). If you have received this message in error, you
are prohibited from copying, distribung or using the informaon. Please contact the sender immediately by return email and delete the original message.

From: Lucia Mason [mailto:[e-mail]]
Sent: Thursday, August 8, 2024 12:18 PM
To: Sterling Jensen <[e-mail]>
Subject: SSE Addional Informaon, 10954: Richards Sheet Metal- Richard Sheet Metal

Hi Sterling,
[Quoted text hidden]
Lucia Mason <[e-mail]>Mon, Aug 19, 2024 at 4:02 PM
To: Sterling Jensen <[e-mail]>
9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…4/7
Ok great! I'll need to confirm your calculations before moving forward. Could you send me your spreadsheets and any SDSs or supporting documents you used in
your calculations?
Thanks,
Lucia
[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Aug 29, 2024 at 2:50 PM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
I'm just checking in on your SSE application. Let me know if you have any questions.
Thanks,
Lucia
[Quoted text hidden]
Sterling Jensen <[e-mail]>Tue, Sep 3, 2024 at 11:10 AM
To: Lucia Mason <[e-mail]>
Lucia,

I have aached the brief spreadsheet for the largest connuous buy we make, which is a lacquer thinner that we buy in 55 gallon drums. Ashley, who
maintains the coangs database we have looked at the HAP amounts for just the methanol and toluene and put together the excel data aached as well as
pulling the SDS for the thinner. It would seem from these figures that we exceed the quota for the SSE exempon just by our thinner usage.

Please let us know if we are reading this incorrectly. It would seem based on this data that we should remain as is.

Sterling
[Quoted text hidden]
2 attachments
9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…5/7
SDS-DT10 FAST DRY ACRYLIC LACQUER THINNER.PDF
2528K
DT10 Methanol and Toluene 23-24.xlsx
11K
Lucia Mason <[e-mail]>Thu, Sep 5, 2024 at 7:35 AM
To: Sterling Jensen <[e-mail]>
Hi Sterling,
I've checked your calculations and they look good. You're right that the paint thinners alone exceed the SSE threshold. Sorry for recommending a permitting
direction that doesn't apply to you and thank you for all the time you put in to investigate the possibility. I'm going to continue with your periodic permit updates
instead.
To move forward with the permit updates I need to confirm your contact information. Could you provide your company mailing address, the name of the person you
would like your Approval Order addressed to, and the physical and mailing addresses, phone number and email of a billing contact (if it's someone other than you).
Apologies again for recommending a SSE. Thank you for all the time and effort you've put in.
Hope you're having a good week,
Lucia
[Quoted text hidden]
Sterling Jensen <[e-mail]>Thu, Sep 5, 2024 at 8:03 AM
To: Lucia Mason <[e-mail]>
Richards Sheet Metal
2680 Industrial Drive
Ogden, UT 84401

Approval Order contact: Sterling N. Jensen [e-mail] 801-436-1419 (direct)
Billing Contact: Terry Pion [e-mail] 801-409-0402
[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Sep 5, 2024 at 8:22 AM
To: Sterling Jensen <[e-mail]>
9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…6/7
Thank you!
[Quoted text hidden]
9/9/24, 12:40 PM State of Utah Mail - SSE Additional Information, 10954: Richards Sheet Metal- Richard Sheet Metal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r719123765138093580&simpl=msg-a:r-300458826232612205&simpl=msg-f:1806845748759493319&simpl=m…7/7