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Home My WebLink AboutDAQ-2025-0026071 DAQC-CI132620001-24 Site ID 13262 (B1) MEMORANDUM TO: FILE – ST. GEORGE STEEL, LLC – St. George Steel Fabrication Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: May 9, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County INSPECTION DATE: July 11, 2024 SOURCE LOCATION: 1301 East 700 North St. George, UT 84770 DIRECTIONS: The main office is located near the southwest corner of the building at this address. SOURCE CONTACTS: Mike Housley, Manager 435-673-4856; mhousley@stgeorgesteel.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: St. George Steel, LLC engages in fabricating structural steel members for buildings, duct work, conveyors, and hoppers for mining and industrial markets. The process includes customized services including plasma cutting, punching, bending, forming, welding, machining, abrasive blasting, coating, and product assembly. Raw materials are delivered to the site by truck and stored in a warehouse/storage facility. The steel is transported to the production building where laser or a plasma torch is used to cut, bend, and weld into shape using Metal Inert Gas (MIG). The product is then sent to the confirmed abrasive blasting booth which is equipped with a large baghouse to collect particulate matter emissions. Painting of the product occurs in the final assembly building using High Volume Low Pressure (HVLP) spray guns. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN132620008-23, dated November 2, 2023 MACT (Part 63) -XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories, * ) ) * - $ % * 2 . & $ 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: St. George Steel, LLC- St. George Steel Fabrication Facility 1301 East 700 North 1301 East 700 North St. George, UT 84770 St. George, UT 84770 SIC Code: 3441: (Fabricated Structural Metal) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: Out of Compliance. The source modified the permitted equipment prior to submitting a Notice of Intent and receiving an updated Approval Order. Refer to Section II.A for more details. The remaining conditions from Section I were reviewed with the source and appeared to be in compliance. The source is not currently required to submit an Emission Inventory. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 St. George Steel II.A.2 Abrasive Blasting Operation Baghouse manufactured by Hoffman, rated at 50 hp 3 II.A.3 High Volume Low Pressure (HVLP) Spray Guns II.A.4 Natural Gas-fired Comfort Heaters II.A.5 Metal Inert Gas (MIG) Welding and Cutting II.A.6 Automated Laser Cutter Cartridge filter unit II.A.7 Laser Cutter Table Baghouse manufactured by Donaldson, rated at 15 hp Status: Out of Compliance. Item II.A.6 has been permanently removed from the site and replaced with two wet plasma cutters. A Compliance Advisory (DAQC-1066-24) and Warning Letter (DAQC-321-25) were submitted to address this issue. The source received an updated Approval Order (DAQE-AN132620009-25) April 9, 2025. II.B Requirements and Limitations II.B.1 The St. George Steel Facility shall be subject to the following II.B.1.a The owner/operator shall not consume more than the following: A. 700 tons of abrasive blasting media per rolling 12-month period B. 12,700 gallons of paint applied by spraying per rolling 12-month period C. 3,600 decatherms of natural gas per rolling 12-month period. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Determine consumption by keeping logs of fuel use, paint use, and abrasive blasting media purchased B. Record consumption on a daily basis C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep consumption records for all periods that the facility is in operation. [R307-401-8] Status: In Compliance. Calculations were made according to this condition. Refer to the attachments for more information. The rolling 12-month totals from July 2023 - June 2024, are as follows: 6.4 tons of abrasive blasting media 2,886 gallons of paint applied 2,309 decatherms of natural gas consumed II.B.1.b The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: A. 35.0 tons per rolling 12-month period of VOCs B. 3.5 tons per rolling 12-month period of Xylene C. 0.8 tons per rolling 12-month period of Ethylbenzene D. 9.0 tons per rolling 12-month period of Toluene 4 E. 1.9 tons per rolling 12-month period of Methanol F. 0.6 tons per rolling 12-month period of all Other HAPs G. 15.8 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.1.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.1.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] Status: In Compliance. Calculations were made according to this condition. Refer to the attachments for more information. The rolling 12-month totals from July 2023 - June 2024, are as follows: 7.47 tons of VOCs 3.37 tons of combined HAPs 1.15 tons of Xylene 2.09 tons of Toluene 0.08 tons of Methanol 0.24 tons of Ethyl Benzene 0.16 tons of all other HAPs II.B.1.b.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] Status: In Compliance. Records are kept according to this condition. Each SDS is kept as a physical and digital copy. II.B.1.c The owner/operator shall use natural gas as a primary fuel for all comfort heaters. [R307-401-8] Status: In Compliance. Only natural gas is used as fuel in the comfort heaters. 5 II.B.1.d The owner/operator shall store all VOC-containing materials and VOC-laden rags in covered containers, except when in use. [R307-401-8] Status: In Compliance. All VOC-containing materials and VOC-laden rags are kept in specifically designed and labeled containers. II.B.2 Haul Roads and Fugitive Dust Sources shall be subject to the following II.B.2.a Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. [R307-401-8] II.B.2.a.1 Visible emissions determinations for traffic sources shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8] Status: In Compliance. No visible emissions were observed from the haul road. The referenced haul road is a small laydown yard and the potential for fugitive dust is low. Refer to the VEO form in the attachments. II.B.2.b The owner/operator shall comply with the fugitive dust control plan received on January 6, 2010, for control of all dust sources associated with the source. [R307-401-8] Status: In Compliance. The source is aware and follows the submitted Fugitive Dust Control Plan. No visible emissions were observed during the inspection. Refer to the VEO form in the attachments. II.B.3 Welding, Painting, Blasting, and Cutting operations shall be subject to the following II.B.3.a Visible emissions from the painting, welding, and laser cutter operations shall not exceed 10% opacity. [R307-401-8] Status: In Compliance. No visible emissions from the painting, welding, and cutting operations were observed. II.B.3.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. Opacity observations were made according to EPA Method 9. Refer to the VEO form in the attachments. II.B.3.b The owner/operator shall comply with R307-206. Emission Standards: Abrasive Blasting. [R307-401-8] Status: Compliance not determined. Abrasive blasting did not occur at the time inspection. However, abrasive blasting is conducted within a structure which exhausts through a baghouse. II.B.3.c The owner/operator shall vent exhaust from the laser cutting table through the baghouse manufactured by Donaldson. The baghouse shall be in operation at all times when the cutter is being operated. [R307-401-8] Status: Not Applicable. The laser cutters and associated baghouse have been removed from operation. 6 II.B.3.c.1 The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the laser cutting baghouse. Static pressure differential across the fabric filter shall be between 2 to 4 inches of water column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The reading shall be accurate to within plus or minus 1.0 inches of water column. The instrument shall be calibrated according to the manufacturer's instructions. [R307-401-8] Status: Not Applicable. The baghouse associated with the laser cutters has been removed. II.B.3.d The owner operator shall vent the exhaust from abrasive blasting operation through the baghouse manufactured by Hoffman. The baghouse shall be in operation at all times when the abrasive blasting operations are being performed. [R307-401-8] Status: In Compliance. Exhaust air from the abrasive blasting operation is routed to the Hoffman baghouse. The source was not abrasive blasting at the time of the inspection. II.B.3.d.1 The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the abrasive blasting operation equipment baghouse. Static pressure differential across the fabric filter shall be between 2 to 4 inches of water column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The reading shall be accurate to within plus or minus 1.0 inch of water column. The instrument shall be calibrated according to the manufacturer's instructions. [R307-401-8] Status: In Compliance. A magnehelic pressure gauge is installed. No abrasive blasting was conducted during the inspection and the baghouse did not operate. The source is aware of the pressure gauge requirements and actively monitors the equipment during operation. The magnehelic pressure gauge was replaced July 15, 2024, with a newly calibrated gauge. II.B.3.e The owner/operator shall maintain the self-cleaning cartridge filter dust filtration system as specified by the manufacturer for proper function. Dust that is removed from the air stream that collects in the system's container shall be periodically emptied. The air filter shall be replaced frequently enough to prevent the automatic flow alarm from sounding and the unit from shutting down. The flow setting for the filtration system set by the manufacturer shall not be altered to prevent the alarm from sounding or the unit shutting down. [R307-401-8] Status: In Compliance. The source stated that the cartridge dust filtration system is maintained as specified by the manufacturer's recommendations. The source stated that the alarm sounds and shuts down the unit when flow is blocked as intended. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. MACT (Part 63) -XXXXXX: National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories Status: In Compliance. Dry abrasive blasting is conducted in a confined enclosure to minimize dust. Small particles are vacuumed into the baghouse. The source regularly blasts objects greater than 8 feet in size. The source stated that they have standards to remove contamination prior to blasting, and they regularly perform VEO checks to prevent fugitive emissions. This subpart is also applicable to the welding operations. The source strives to minimize dust caused by the fabrication process by emptying enclosures and regularly maintaining equipment according to manufacturer specifications. The 2023 annual report and quarterly observations were submitted January 10, 2024. 7 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205] Status: In Compliance. This area source rule is addressed in Condition II.B.2.a and II.B.2.b. Emission Standards: Abrasive Blasting [R307-206] Status: In Compliance. This area source rule is addressed in Condition II.B.3.b. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from St. George Steel, LLC - St. George Steel Fabrication Facility on the Approval Order (AO) DAQE-AN132620008-23, dated November 2, 2023. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 180.00 Carbon Monoxide 0.01 Nitrogen Oxides 0.02 Particulate Matter - PM10 0.51 Particulate Matter - PM2.5 0.51 Sulfur Dioxide 0.00 Volatile Organic Compounds 35.00 Hazardous Air Pollutant PTE lbs/yr Ethyl Benzene (CAS #100414) 1600 Generic HAPs (CAS #GHAPS) 1200 Methanol (CAS #67561) 3800 Toluene (CAS #108883) 18000 Xylenes (Isomers And Mixture) (CAS #1330207) 7000 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN132620008-23, dated November 2, 2023, the overall status is: Out of Compliance. Compliance Advisory (DAQC-1066-24) and Warning Letter (DAQC-321-25) were submitted to address the replacement of permitted equipment prior to submitting a Notice of Intent. The source received an updated Approval Order (DAQE-AN132620009-25) April 9, 2025, to address this issue. No additional action recommended. HPV STATUS: Not Applicable. 8 RECOMMENDATION FOR NEXT INSPECTION: Inspect at the regular interval. Steel toe boots, hearing, and eye protection are required to tour the site. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form, Production Records, Emission Estimates, 2023 Subpart XXXXXX Annual Report STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY Page _of_ EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM Source Name: J .\--, Geogu S\-U-\ Street Address: \Xi\ f:;7Q? }I City/County: S\: r Oeo<:5e.-J ~tts'-1,"'JbA Phone: l\ )S -015-4~ Site ID: \ ~k::~1, Facility: <l\<l-\ ~\,rlq\-'lc:Y' , Equipment/Process: ~l~stl~ , t,J{~'~j I CvWl'g Control Equipment: (Jpq\fcvw Emission Point: Sky Conditions: Clear [ ] Partly Cloudy [ ] Overcast [ ] Precipitation: No [ ] Yes [ ] Wind: Direction: ___ Speed: __ _ mph Ambient Temp: °F RH: ___ % Height Relative to Observer: ---- Distance From Observer: ---- Condensed Water Vapor Present: No [ ] Yes [ ] Attached [ ] Detached [ ] Length of Condensed Water Vapor Plume: _____ _ Background: ______________ _ Sketch process unit: indicate observer position relative to source; indicate potential emission points and/or actual emission points. 0 l)rJw nur1 h .11 HI\\ • observer Sun ♦ Wind ► Emission Point with Plume (~)'-_, Observer Position X r . ,. Observer's Signature: Oistrib: white-file; canary-inspecto • pink-owner/operator OBSERVATION DATE: -1 / l ,/ ~ Start time: ____ Stop time: ___ _ ~ c mrn 0 15 30 45 1 -----2 / ~~ 3 I/ /~ 4 ~ l/ 5 / '-..../ 6 7 8 9 10 11 12 ~\\1~ \i,,-{VlOI\Wl PtNodi l3ul~Zo23-Ju4,Zo2).,() COMMENTS: v-"'" 1 C\t ~.&.\Jo', To05 o.f: A½rgs'N?:: fin<xi'-{&cit~, 6',llo~ 0 £-\?c"/».. 5zc")«A I D~s o?-hfa,.Jvf:) I /oas Pl£@~, e,,(Y)a\ \ ('lCorct.S -lo C-k L_)OWib1 &.,u~~ ·9 Cl/ ~rj 7 I JI ) :2--Z.. 1 Z o::z.,y ,. I have received a copy of these observations: SIGNATURE: Title: St. George Steel LLC /Monthly/NG/Paint and Blast Media Summary Actual July 2023 thru June 2024 NG Dekatherms Blast Media Tons Total Paint (less waste) J 2023 1.1 0.8 290 A2023 1.5 0.9 313 S 2023 0.8 0.5 157.1 O 2023 2.6 0.5 182 N 2023 145.3 0.3 165 D 2023 423.8 0.7 310 J 2024 595.4 0.6 245 F 2024 526.2 0.4 211.8 M 2024 434.9 0.4 259 A 2024 160.1 0.45 299.5 M 2024 17.6 0.35 253 J 2024 0.2 0.5 201.5 12 mo rolling total 2309.5 6.4 2886.9 Permit Limits 3,600.00 700.00 12,700.00 The following consumption limits shall not be exceeded. A. 700 tons of abrasive blasting media used per rolling l2-month period B. 12,700 gallons of paint applied by spraying per rolling l2-month period C. 3,600 dekatherms of natural gas per rolling l2-month period See PDF reports Actual July 2023 thru June 2024 Total VOC- Permitted to 35 tons Total VOC/Tons 7.47 Comb HAP- Permitted to 15.8 tons Comb HAP/tons 3.37 Xylene- 3.5 tons Xylene 1.15 Toluene- 9 tons Toluene 2.09 Methanol- 1.9 tons Methanol 0.08 Ethyl Benzene- 0.8 tons Ethyl Benzene 0.24 All other HAPS- 0.6 tons All Other HAP 0.168505 MIBK 0.16 DIISOCYANATE 0.00052 DIBUTYL PHTHALATE 0 NAPHTHALENE 0.00454 CUMENE 0.003445 a MONTH YEAR MONTH COMBINED HAP IN LBS 12 Month Rolling Combined HAP/Emission Estimates St George Steel, LLC MONTH COMBINED HAP IN TONS FACILITY NAME: June 2024 777.53 0.3887659314 May 2024 1,010.44 0.50522050593 April 2024 1,097.77 0.54888290065 March 2024 638.30 0.3191494662125 February 2024 287.41 0.1437070046125 January 2024 537.14 0.26857123685 December 2023 275.85 0.13792310035 November 2023 606.23 0.3031157447675 October 2023 299.69 0.1498438613875 September 2023 260.84 0.130418832425 August 2023 714.33 0.3571642438 July 2023 951.97 0.475984717425 7,457.5012 Month Rolling Combined HAP in LBS:3.73Tons: Friday, July 12, 2024 Page 1 of 1 Prepared by Using MONTH YEAR MONTH TOTAL VOC IN LBS 12 Month Rolling Total VOC/Emission Estimates St George Steel, LLC MONTH TOTAL VOC IN TONS FACILITY NAME: June 2024 1,222.43 0.611216561375 May 2024 1,647.70 0.82384787898 April 2024 1,636.93 0.81846702385 March 2024 1,301.84 0.65092048595 February 2024 830.32 0.41516182715 January 2024 1,182.23 0.5911157924 December 2023 1,152.80 0.5764007641 November 2023 1,070.97 0.53548639473 October 2023 1,057.58 0.5287898994 September 2023 909.18 0.454588987475 August 2023 1,473.10 0.7365517614 July 2023 1,445.45 0.7227251276 14,930.5512 Month Rolling Total VOC in LBS:7.47Tons: Friday, July 12, 2024 Page 1 of 1 Prepared by Using CHEMICAL NAME MONTH/YEAR MONTHLY INDIVIDUAL HAP IN LBS 12 Month Rolling Individual HAP/Emission Estimates/July 2023 thru June 2024St George Steel, LLC CAS # MONTHLY INDIVIDUAL HAP IN TONS FACILITY NAME: ETHYL BENZENE100-41-4 12 Month Aggregate Total of Individual HAP in LBS 483.41 12 Month Aggregate Total of Individual HAP in Tons 0.24 Methyl Isobutyl Ketone108-10-1 12 Month Aggregate Total of Individual HAP in LBS 320.52 12 Month Aggregate Total of Individual HAP in Tons 0.16 M-XYLENE {BENZENE, M-DIMETHYL-}108-38-3 12 Month Aggregate Total of Individual HAP in LBS 8.00 12 Month Aggregate Total of Individual HAP in Tons 0.00 TOLUENE108-88-3 12 Month Aggregate Total of Individual HAP in LBS 4,186.10 12 Month Aggregate Total of Individual HAP in Tons 2.09 XYLENE (MIXED ISOMERS)1330-20-7 12 Month Aggregate Total of Individual HAP in LBS 2,308.66 12 Month Aggregate Total of Individual HAP in Tons 1.15 Methanol67-56-1 12 Month Aggregate Total of Individual HAP in LBS 162.41 12 Month Aggregate Total of Individual HAP in Tons 0.08 LEAD7439-92-1 12 Month Aggregate Total of Individual HAP in LBS 0.00 12 Month Aggregate Total of Individual HAP in Tons 0.00 Zinc Phosphate7779-90-0 12 Month Aggregate Total of Individual HAP in LBS 4.00 12 Month Aggregate Total of Individual HAP in Tons 0.00 HEXMAMETHYLENE-1,6-DIISOCYANATE822-06-0 12 Month Aggregate Total of Individual HAP in LBS 1.04 12 Month Aggregate Total of Individual HAP in Tons 0.00 Friday, July 12, 2024 Page 1 of 2 Prepared by Using CHEMICAL NAME MONTH/YEAR MONTHLY INDIVIDUAL HAP IN LBS 12 Month Rolling Individual HAP/Emission Estimates/July 2023 thru June 2024St George Steel, LLC CAS # MONTHLY INDIVIDUAL HAP IN TONS FACILITY NAME: NAPHTHALENE91-20-3 12 Month Aggregate Total of Individual HAP in LBS 9.08 12 Month Aggregate Total of Individual HAP in Tons 0.00 CUMENE98-82-8 12 Month Aggregate Total of Individual HAP in LBS 6.89 12 Month Aggregate Total of Individual HAP in Tons 0.00 Friday, July 12, 2024 Page 2 of 2 Prepared by Using