DAQ-2025-002821

sEsI
REVIEWED
lu,t;ulr, CG ,r,r, 7^'J'25
ST. GEORGE
STEEL
January 28,2025
VIA US MAIL CERTIFIED
Utah Division of Air Quality
Minor Source Compliance
PO Box 1,44820
Salt Lake Ciry*, UT 8411.44820
I-,1.# /
Subject:NESHAP - Annual Certification and Compliance Report
Nine Metal Fabrication and Finishing Source Categories
40CFR63Subpart XXXXXX
To whom it may concem,
St. George Steel operates a manufacturing facility located at L30L East 700 North in St. George,
Utah. The facility is subject to the above referenced NESHAP standard. Please accept this letter
as St. George Steel's Annual Certification and Compliance Report.
Section 1 - Facility lnformation
Ftts - t
DIVISION OF A'R OL'ALITY
Perlod Covered by thls Report:January 1,2024 through December 31,2024
"ExiEting'n or "New" Source:Existing
Gompllance Date (initial):July 25,2011
Source Gategory:Fabricated Metal Products
Source NAICS Number:332999
Company Name:St. George Steel LLC
Facllity Name (lf different):St. George Steel
Facility Physical Address:1301 East 700 North, St. George, UT 84770
Owner Gompany Name:St. George Steel LLC
Owner Company Address:1301 East 700 North, St. George, UT 84770
Owner Telephone Number:[phone]
Owner Contact:Cody Jones
Owner e-mail (if avallable):Ciones@stoeorqesteel. com
ls the owner the operator?Yes
lf No, provlde operator lnformation:NA - Same as owner
1301 East 700 North, St. George, UT 84770 [phone]
02c NESHAPS Annual Cert & Comp Report - SGS - 2024.docx
Page 2
Section 2 - ldentification of Affected Operations
Part 1 - The following are the operations at this facility subject* to subpart XXXXXX
Dry Abrasive Blasting Yes No
1. Totally enclosed and unvented blast chambers X
2. Vented enclosures with a filtration control device X
3. Objects over 8 feet in any dimension without a filtration control device
(includes outdoor blasting of objects over 8 ft in any dimension)x
Dry Machining X
Dry Grinding or Dry Polishing with Stationary Machines X
Spray Painting
1. ln a spray booth X
2. Without a spray booth (for Fabricated Structural Metal facilities or any
objects over 15 feet)x
Welding
1. Use less than 2,000 pounds of MFHAP-containing welding rod or wire
annually X
2.Use 2,000 pounds or more of MFHAP-containing welding rod or
welding wire annually X
* lmpoftant Note: The operator understands that the operations listed above are affected sources under subpart XXXXW
onlv if/when they use materials that contain or have the potential to emit metal fabrication or finishing metal HAP (MFHAP).
MFHAP containinglpotential is defined to be when the compounds of cadmium, chromium, lead, manganese, and nickel,
or any of these metals in the elemental form with the exception of lead, are used or have the potential to be emitted in
quantitiesof 0.1 percentormore,orl.0percentormoreforelemental of compoundsof manganese.
Part2 - This table lists each drv abrasive blastinq operation at this facility subject to subpart XXXXXX.
Abrasive Blasting
Process Description / lD No.
HAP
Emitted or Usedb
(Gd. Gr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Gheck allthat apply)
Outdoor Blasting Cr, Mn, Ni Totally enclosed, unvented
Vented, with control device; describe
X Objects over 8 ft (with no control)
X Management practices
Enclosed Blaster Cr,Mn,Ni Totally enclosed, unvented
X Vented, with control device
(Cartridoe filter)
Objects over 8 ft (with no control)
X Management practices
02c NESHAPs Annual Cert & Comp Report - SGS - 2024.docx
Page 3
Part 3 - This table lists each drv machininq, drv qrindinq. or drv polishinq operation at this facility
subject to subpart XXXXXX.
Dry Machining, Dry Grinding,
or Dry Polishing
Process Descriotion / lD No.
HAP
Emitted or Usedb
(Cd. Cr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Check allthat apply)
MetalShearing Cr, Mn, Ni Control device; describe
X Management practices
Grinding with Abrasive Wheel
Pedestal Grinder
Cr, Mn, Ni Control device; describe
X Management practices
Control device; describe
Management practices
Parl4 - This table lists each gp.t3y_Eirtlng operation at this facility subject to subpart XXXXXX.
Spray Painting
Process Description / lD No.
HAP
Emitted or Usedb
(Cd. Cr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Check allthat apply)
Not Applicable All paints were
investigated and it was
confirmed that no paints
contain MFHAPS.
Accordingly, the Facility is
not subject to the
requirements of this
section.
Spray booth, PM filter, HVLP spray
guns
HVLP spray guns, only
Management practices
Spray booth, PM filter, HVLP spray
guns
HVLP spray guns, only
Management practices
Part 5 - This table lists each g!!!49 operation at this facility subject to subpart XXXXXX.
Welding Process Description
/ !D No.
HAP
Emitted or Usedb
(Cd. Cr. Pb. Mn. Ni)
Compliance Method(s) Employed
(Gheck allthat apply)
Production Welding Cr, Mn, Ni x Management practices
Fume capture device; describe
Management practices
Fume capture device; describe
Management practices
Fume capture device; describe
02c NESHAPS Annual Cert & Comp Report - SGS - 2024.docx
Page 4
Part 6 - The following applicable management practices are used at this facility, as practicable (check
allthat apply):
Dry Abrasive Blasting
x Minimize dust generation during emptying of abrasive blasting enclosure to reduce MFHAP
emissions, as practicable.
x Operate all equipment associated with dry abrasive blasting operations according to the
manufacturer's i nstructions.
x Minimize excess dust in the surrounding area to reduce MFHAP emissions, as practicable.
x For Outdoor Blasting - Enclose dusty abrasive storage areas and holding bins, seal chutes and
conveyors that transport abrasive materials.
x
For Outdoor Blasting - Do not re-use dry abrasive blasting media unless contaminants (i.e., any
material other than the base metal, such as paint residue) have been removed by filtration or
screening, and the abrasive material conforms to its original size.
x
For Outdoor Blasting - When practicable, switch from high particulate matter (PM)-emitting blast
media (e.9., sand) to low PM-emitting blast media (e.9., crushed glass, specular hematite, steel
shot, aluminum oxide).
Dry Machining, Dry Grinding, Dry Polishing
x Minimize excess dust in the surrounding area to reduce MFHAP emissions, as practicable.
x Operate equipment according to manufacturer's instructions.
Spray Painting
Proper cleaning and storage of spray guns, if applicable.
Training for employees using HVLP spray equipment, with certification as having completed
classroom or hands-on training in the proper selection, mixing, and application of coatings, with
refresher training repeated at least once every 5 years.
Facility to maintain a list of trained painters.
Welding
x Operate equipment according to manufacturer's instructions.
x Use welding processes with reduced fume generation capabilities, if practicable. (e.9., gas metal
arc welding (GMAWf-also called metal inert gas welding (MlG))
x Use welding process variations (e.9., pulsed current GMAW), which can reduce fume generation
rates, if practicable.
x Use welding filler metals, shielding gases, carrier gases, or other process materials which are
capable of reduced welding fume generation, if practicable.
x Optimize welding process variables (e.9., electrode diameter, voltage, amperage, welding angle,
shield gas flow rate, travel speed) to reduce the amount of welding fume generated, if practicable.
Use a welding fume capture and control system, operated according to the manufacturer's
specifications, if practicable.
02c NESHAPs Annual Cert & Comp Report - SGS - 2024.docx
Page 5
Report of Visible Observations (Dry Blasting or Welding)
lf visible emissions were detected for more than six minutes during any observation period during the year list
all such instances below along with all corrective action taken and the results of subsequent follow-up
inspections for visible emissions.
Blasting or
Welding
Date Description of Corrective
Actions
Date and result of follow-up
observation
None
Certification
x
Yes, the facility referenced below !! operating in compliance with all of the relevant
standards and other requirements of 40 CFR Part 63 subpart XXXXXX, National Emission
Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories.
No, the facility referenced below is NOT operating in compliance with the relevant
standards and/or other requirements of 40 CFR Part 63 subpart XXXXXX, National
Emission Standards lor Hazardous Air Pollutants: Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories.
Reason for noncompliance:
I hereby certify that, to the best of my knowledge, the information presented herein is true,
t/zs/z{
' t,ra*,(Signature)
Codv Jones
(Printed Name)
President
[phone]
(Phone)
Ciones@stqeorqesteel. com
(e-mail)(Tiile)
EPA Region VIII
Air and Toxics Enforcement
1595 Wynkoop Street
Denver, CO 80202-1,1.29
---5U=
NESHAP Visual Determination
Site Map
1301 East 700 North, St. George, Utah
lnstructions:
1. Verify that the welding and cutting (or blasting) operations associated with the emission points
to be observed are operating at normal capacity.
2. Observe each emission point for 15 minutes.
3. Use the stop watch to record the total number of seconds with visible emissions from any
point. Multiple points may be observed simultaneously but all emissions during the 15 minutes
must be totaled.
4. Record observations on the Observations Log Sheet.
@
O = observation Point
---srlJ=
Daily
(Once each work day for ten
days.)
Once ten
Weekly
(Once every fifth work day.)
Monthly
(Once every calendar month.)
Visual Determination Schedule - Blasting
Once three monthlv insoections
Quarterly
(Once every calendar
quarter.)
every calendar
'.)
every calendar
,.)
lf any observation has more than
additional requirements.
heyg_099!_99qrp!g!9q._bggi[he quarterly inspections.
lrr,'rt,r*l lrr,'r"r*) l rr,tr,r*) l.n,*l a t,* l ,r,r"*1I nux ll nmx ll nr.,x ll r',rx ll urx ll urx
I
in the monthl
@ffiEsend
E_]l"v'll"n'l[,*]send
360 seconds with visible emissions, refer to NESHAP XXXXXX for
Send in yearly report Jan
in yearly report Jan
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---5lJ='
Check (or mark date of insoecttion
Daily
(Once each work day for ten
days.)
Once
Quarterly
(Once every calendar
quarter.)
Visual Determination Schedule - Welding
Weekly
(Once every fifth work day.)
Once four weeklv insoections have been
Monthly
(Once every calendar month.)
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I
6t13t2023
MLH
9t12t2023
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with visible emissions, refer to NESHAP XXXXXX for
ru
ry(Once every calendar | | 311412023 |quarter') __l I "' Iry(Once every calendar | | 311212024 |quarter')
---l I "' I
@ng60seconds
(Once every calendar
quarter.)
ouarttfu -(Once every calendar
quarter.)
additional requirements.
Send in yearly report Jan
Send in yearly report Jan
3
nthlom
--fs|lJ=|
NESHAP Visual Determination
Log Sheet - Weldine
. lf any point has more than 360 seconds with visible emissions, refer to NESHAP XXXXXX for additional
requirements.
301 East 700 St utah
Date:March 12. 2024 {Ql)Wind Soeed:10 Mph NE
0bserver:Codv Jones Slry Conditions:Clear Blue
Observation
Point:
Start Time
(Clock time)
End Time
IClock timel
Observation
/Minrrtasl
Seconda with visible
emissionst:
Correc{ive Ac{ions Taken
1.10:15 AM 10:30 AM t5 0 N/A
2.l0:30 AM 10:45 AM 15 0 N/A
3.10:45 AM 11:00 AM 15 0 N/A
4.'t't:00 AM 11:15 AM 15 0 N'A
Date:June 1 3. 2024 lQzl Wind Speed:None
Observer:Codv Jones Sky Conditions:Clear Blue
Observation
Polnt:
S1art Time
{Clock lime}
End Time
IClmk timel
Observation
/Minrripq\
Seconds with visible
emissionst:
Coneclive Actions Taken
1 l0:15 AM 10:30 AM 't5 0 N/A
2.l0:30 AM 10:45 AM 15 0 N/A
3.10:45 AM 11:00 AM 15 0 N/A
4.1l:00 AM 11:15 AM 15 0 N/A
Date:Seotember fi).2024 (O3)Wind Speed:None
Obseryer:Codv Jones Skv Conditions:Clear Blue
Observation
Polnt:
Start Time
IClock iime)
End Time
lClock time)
Observation
/Minutes)
Seconds with visible
emissions*:
Gorrective Actions Taken
10:15 AM 10:30 AM 15 0 N/A
2.10:30 AM 10:45 AM 15 0 N/A
3.10:45 AM ll:00 AM l5 0 N/A
4.'11:00 AM 11:15 AM 15 0 N/A
Date:December 10.2024 (Q4)Wnd Speed:5 Mph NE
Observer:Codv Jones Skv Conditions:Cloudv
Observation
Point:
Start Time
IClnck time-)
End Time
IClock timel
Observation
/Minrrlesl
Seconds wlth visible
emisslonsr:
Coneclive Actions Taken
1.10:15 AM l0:30 AM 15 0 N/A
2.10:30 AM 10:45 AM 15 0 N/A
3.10:45 AM l1:00 AM 15 0 N/A
4.11:00 AM 11:15 AM 15 0 N/A
---lflr=
NESHAP Visual Determination
Log Sheet - Blastine
1301 East 700 North, St. George, Utah
* lf any point has more than 360 seconds with visible emissions, refer to NESHAP XXXXXX for additional
requirements.
Date:March 12, 2024 (Q1)Wind Speed:10 MPH, NNE
Observer:Codv Jones Skv Conditions:Clear Blue
Observation
Point:
Start Time
(Clock time)
End Time
(Clock time)
Observation
(Minutes)
Seconds with
visible emissions*
Corrective Actions Taken:
Blast 1 l1:15 AM 11:30 AM 15 0 N/A
Date:June 13. 2024 @21 Wind Soeed:None
Observer:Codv Jones Skv Conditions:Clear Blue
Observation
Point:
Start Time
(Clock time)
End Time
(Clock time)
Observation
(Minutes)
Seconds with
visible emissions*
Corrective Actions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
Date:Seotember 09.2024 (O3)Wind Soeed:None
Observer:Codv Skv Conditions:Clear Blue
Observation
Point:
Start Time
(Clock time)
End Time
(Clock time)
Observation
(Minutes)
Seconds with
visible emissions*
Corrective Actions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
Date:December'10. 2024 (Q4)Wind Speed:5 Mph NE
Observer:Codv Jones Skv Conditions:Cloudv
Observation
Point:
Start Time
(Clock time)
End Time
(Clock time)
Observation
(Minutes)
Seconds with
visible emissions*
Conective Ac{ions Taken:
Blast 1 11:15 AM 11:30 AM 15 0 N/A
4129125. 12:34 PM State of Utah Mail - NESHAP Annual Certification Report
Chad Gilgen <[e-mail]>
NESHAP Annual Certification Report
Cody Jones <[e-mail]>
To: Chad Gilgen <[e-mail]>
Thanks Chad
Mon, Mar 3,2025 at 8:16AM
Cody Jones
President
T: (435)67s856 ext. 3326
C: [phone]
E: ciones(Ostoeoroesteel.com
W. www.stgeorgesteel.com
1301 East 700 North, St. George. UI 84770
tbsffit $f. GEORGE
From: Chad Gilgen <[e-mail]>
Sent: Friday, February 28, 2025 2:2L PM
To: Cody Jones <[e-mail]>
Subject: Re: NESHAP Annual Certification Report
Hi Cody,
Thanks for submitting the additional information.
Thanks again,
Chad
This looks great and covers everything I need.
Ghad Gllgen I Manager I Mlnor Source Compllance
385-306-6s00 (cell)
https://mail.google.com/maiUu l0l?ik=3614379000*u;"r1v=pt&search=all&permmsgid=msg-f:1825586il3724430861&dsqt=1&simpl=msg-f:18255865437..1t3
https://mail.google.com/maiUu/0/?ik=36f4379Md&view=pt&search=all&permmsgid=msg-f:1825586*3724430861&dsqt=1&simpl=msg-f:18255865437... 213
4129125,12:34 PM State of Utah Mail - NESMP Annual Certification Report
Emails to and ftom this email address rnay De considered public records and thus subiect to Utah GMMA requirements.
On Mon, Feb 17, 2025 al9:28AM Cody Jones <[e-mail]> wrote:
Hi Chad,
Sorry for the delay, I was OOO last week and just now getting back to email.
See attached observation sheets we forgot to include.
Thanks
Cody Jones
Presldent
T (435)6734856 ext, 3328
C:[phone]
E : [e-mail]
ftwww.stgeorgestee Lcom
1301 East 700 North, St. George, UT 84770
Isslw*
From: Chad Gilgen <[e-mail]>
Sent: Friday, February 7,2025 t:53 PM
To: Cody Jones <cjones@stgeorgestee!.com>
Subiect: NESHAP Annual Certification Report
Hello Cody,
4129125,12:3tl PM Strate of Utah Mail - NESHAP Annual Certlflcation Report
I am in receipt of the NESHAP Annual Certification Report for St. George Steel dated January 28,2025. The report is
missing the visibb emission observation sheets. Please pages 6 - 9 of the attached document for what was submifted
with lait years r€port and needs to be submitted for this years report. You can emall these to my attentlon.
Thanks,
Chad
Chad Gllgen I tanager ! Mlnor Source Compllance
385-3064500 (cell)
Emails to and from this email address rnay be considered public records and thus subject to Utah GMMA requirements.
https://mail.google.com/maiUu/O/?ik=3614379b,4d&view=pt&search=all&pennmsgid=msg-f:182558654372t1430861&dsqt=1&slmpl=msg-f:18255865437... 3/3