DAQ-2024-007745

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DAQC-CI115980001-24
Site ID 11598 (B1)

MEMORANDUM

TO: FILE – QUALITY STEEL CORPORATION – Fuel Storage Tank Manufacturing
Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: April 19, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: April 4, 2024

SOURCE LOCATION: 5520 West Old Bingham Highway
West Jordan, UT 84084
SOURCE CONTACTS: Corey Fowler, EHS Manager
801-834-5750 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Quality Steel produces steel propane tanks. Raw steel plate is
rolled into a cylinder. The flat seams are submerged arc welded
using wire that contains metal fabrication or finishing metal
hazardous air pollutant (MFHAP). Used flux is sent to a shaker
and chunks are sifted out and sent to the manufacturer for
regrinding. Sifted flux fines are reused. A plasma cutter makes
holes for fittings. The weld is inspected for defects that are
repaired by stick rod welding. Round connections are submerged
arc welded using wire that contains MFHAP.

Tac welding, and the attachment of hooks, legs, fittings, etc. are
accomplished by MIG welding with an Argon CO2 shield and
Prostar 045 wire that contains MFHAP. The vessels are pressure
tested with water. If no leaks are detected, the water is drained to
floor storage, and the tanks are placed on moving hangers. The
vessels move through a second shot blaster, a drying oven,
undercoat spray booth, finish spray booth, and a natural gas fired
baking oven. Particulate control: the paint booths uses particulate
filters, and blasting booths uses baghouses. After the vessel is
cool, covers and valves are attached. The vessels are transported
by dirt road to the yard for storage using forklifts.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN115980009-24, dated February
1, 2024
MACT (Part 63) -A : General Provisions,

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MACT (Part 63) -XXXXXX : National Emission Standards for
Hazardous Air Pollutants Area Source Standards for Nine Metal
Fabrication and Finishing Source Categories

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Quality Steel Corporation - Fuel Storage Tank
Manufacturing Plant

P.O. Box 249 2914 U.S. Highway 61 5520 West Old Bingham Highway
Cleveland, MS 38732 West Jordan, UT 84084

SIC Code: 3443: (Fabricated Plate Work (Boiler Shop))

Section I: GENERAL PROVISIONS

I.1 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.2 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.3 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.4 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.5 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.6 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.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Status: In Compliance. No breakdowns have occurred since the previous inspection. Source
submitted their 2023 Emission Inventory by the April 15, 2024, deadline, which is currently
under review. The source submitted their 2022 Emission Inventory on time and can be
found in the attachments section below.

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Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Fuel Storage Tank Manufacturing Plant

II.A.2 One (1) Product Dryer
Fuel Type: Natural Gas
Heating Capacity: <5 MMBtu/hr

II.A.3 Two (2) Paint Booths
Identification: Prime, and Top Coat
Attached Equipment: Paint arrestor filters
64 arrestor filters (Prime), and 64 arrestor filters (Top Coat)

II.A.4 Various Equipment Items
HVLP Spray Guns

II.A.5 One (1) Shot Blaster
Shot blaster with baghouse (GS-20 cartridge filter system)

II.A.6 Plasma Cutter and Welding Operations
One (1) dry plasma cutter
Control device: dust collector
Various welders

Status: In Compliance. No unapproved equipment was observed at the time of inspection.

II.B Requirements and Limitations

II.B.1 The Fuel Storage Tank Manufacturing Plant shall be subject to the following:

II.B.1.a The owner/operator shall control process streams from the Prime and Top Coat paint booths with
paint arrestor filters. All exhaust air from each paint booth shall be routed through a double
filtered paint arrestor filter bank containing the full complement of filter panels before being
vented to the atmosphere. [R307-401-8]

Status: In Compliance. All painting operations onsite are routed through a double filtered
paint arrestor bank before exiting through vents to the atmosphere.

II.B.1.b The paint booth stack heights shall be as follows:

A. Four (4) Prime Stacks - 42 feet above grade each

B. Four (4) Top Coat Stacks - 42 feet above grade each

C. One (1) Dryer Stack - 38 feet above grade

The nine (9) stacks shall be configured as unrestricted, vertically venting. [R307-401-8]

Status: In Compliance. All stacks onsite meet the height requirements listed in the AO and
are configured as unrestricted, vertically vented stacks.

II.B.1.c Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10% opacity. [R307-401-8]

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II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-305-3]

Status: In Compliance. No visible emissions were observed at the time of inspection. See the
attached VEO form for additional information.

II.B.2 VOC Limitations

II.B.2.a The owner/operator shall comply with the applicable requirements of R307-350 during
operations. [R307-350]

Status: In Compliance. All VOC containing paints used onsite meet the requirements
within R307-350. Source utilizes the same paints from the previous inspection and the SDS
were viewed onsite at the time of inspection.

II.B.2.b The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:

49.30 tons per rolling 12-month period for VOCs
0.51 tons per rolling 12-month period for all HAPs combined. [R307-401-8]

II.B.2.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]

HAPs = [% HAPs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]

Status: In Compliance. The rolling 12-month totals for VOC and HAP emissions from
April 2023 to March 2024 are as follows:

23.6 tons of VOCs emitted

0.28 tons for all HAPs combined

Based on the information provided by Quality Steel to NSR during their most recent
permit modification, all HAPs combined that are reviewed for this rolling 12-month total
refers to xylene and methyl methacrylate emissions. NSR reviewed the SDS from Quality
Steel during their permit modification and determined that the products used by Quality
Steel are HAP free, except for xylene and methyl methacrylate. This information about the
HAPs was obtained over the phone with Corey Fowler on April 17, 2024. See the
attachments section for additional information about the VOCs and HAPs emitted.

II.B.2.c 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 HAPs 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 HAPs-emitted from each material

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F. The amount of VOCs reclaimed and/or controlled from each material

G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8]

Status: In Compliance. Records are stored for each month and new totals are calculated
each month by the 20th of each month. SDS are stored onsite and were viewed at the time
of inspection.

II.B.2.d 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. A mass-balance method is used to calculate VOC and HAP
emissions onsite.

II.B.3 Baghouses Limitation

II.B.3.a The owner/operator shall use a baghouse to control particulate emissions from the shot blaster.
[R307-401-8]

Status: In Compliance. A baghouse is used to control emissions from the shot blaster.

II.B.3.b The owner/operator shall not allow visible emissions from the baghouse to exceed 10% opacity.
[R307-401-8]

II.B.3.b.1 The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across the baghouse. [R307-401-8]

II.B.3.b.2 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.3.b.3 The pressure gauge shall measure the static pressure differential in 0.5-inch water column
increments or less. [R307-401-8]

II.B.3.c During operation of the baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between 0.5 and 6.0 inches of water column. [R307-401-8]

II.B.3.c.1 The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

II.B.3.c.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Manufacturer recommended static pressure differential for the unit (if applicable);

C. Weekly static pressure differential readings;

D. Date of reading. [R307-401-8]

Status: In Compliance. No visible emissions were observed at the time of inspection. See the
attached VEO Form for additional information. The baghouse has a magnehelic gauge
installed that is easily visible and reads in 0.5 inch water column increments. Baghouse
gauge readings are recorded daily and at the time of inspection, the baghouse gauge was
read at 2.0. Past records of the baghouse gauge readings indicated that the pressure gauge
did not exceed 6.0 and had a minimum of 0. On days where it was recorded 0, the baghouse
was not in use for the day based on operations for the day, or was in process of a filter
replacement.

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II.B.3.d At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

II.B.3.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

Status: In Compliance. The baghouse gauges are replaced every year in May by Dwyer
Industries. Records are stored digitally, and a sticker is placed on the box of the magnehelic
gauge with the date of the gauge’s replacement. Each gauge replacement comes with a
certification from Dwyer Industries that the new gauge is calibrated correctly for use in the
baghouse. The last replacement was May 16, 2023.

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) -A : General Provisions

Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable federal
subparts. In Compliance for Subpart XXXXXX.

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. The source submitted their annual compliance statement for 2023 in January
2024. See the attachments section for additional information.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with R307-214 is determined by compliance with applicable
federal subparts. Subpart XXXXXX applies to this source. See Section III for additional information
about compliance with Subpart XXXXXX.

Degreasing and Solvent Cleaning Operations [R307-335]

Status: Not Applicable. The source has removed the Tekusolv II brand parts cleaner from their
operations. The source no longer operates any parts washers or cleaners.

Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. All paints used onsite follow VOC content regulations established by
R307-350. The paints used at this source are the same paints used in the previous inspection, and the
SDS for the paints were viewed at the time of inspection.

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EMISSION INVENTORY:

Listed below are the Actual Emissions Inventory provided from Quality Steel Corporation - Fuel Storage
Tank Manufacturing Plant. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN115980009-24, dated February 1, 2024, is provided. The 2022 Emission Inventory is listed
below and can be found in the attachments section. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 2901.00
Carbon Monoxide 0.22 0.76
Nitrogen Oxides 1.01 1.00
Particulate Matter - PM10 4.60 1.34
Particulate Matter - PM2.5 4.60 0.14
Sulfur Dioxide 0.02 0.004
Volatile Organic Compounds 49.30 30.93

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Xylenes (Isomers And Mixture) (CAS #1330207) 996 0

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN115980009-24,
dated February 1, 2024: In compliance with conditions listed in
the AO. The facility is well maintained and records were made
available upon request.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the normal frequency.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: Applicable Supporting Documentation Included
Jordan Garahana <[e-mail]>
Subpart 6XX Annual Compliance
1 message
Eddie Scow <[e-mail]>Thu, Apr 4, 2024 at 11:43 AM
To: "[e-mail]" <[e-mail]>
Cc: Corey Fowler <[e-mail]>
See aached regarding 2023 submissions.
Eddie Scow
HSE Manager
Quality Steel Corp. of MS.
[e-mail]
o- 801-280-7084
c- 801-803-1085

QSC - WJO Signed Air Quality Report 2023.pdf
437K
4/19/24, 11:01 AM State of Utah Mail - Subpart 6XX Annual Compliance
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1795427017137709635&simpl=msg-f:1795427017137709635 1/1
Jordan Garahana <[e-mail]>
Quality Steel of West Jordan
4 messages
Corey Fowler <[e-mail]>Fri, Apr 5, 2024 at 7:15 AM
To: "[e-mail]" <[e-mail]>
Cc: Eddie Scow <[e-mail]>
See Attached, Quality Steel’s 12 Month VOCs

V/R,

Corey Fowler
HSE Manager
Quality Steel Corporation
5520 W. Old Bingham Hwy | West Jordan, UT 84081
C: 801-834-5750

QSC 12 Month VOCs Copy.xlsx
13K
Jordan Garahana <[e-mail]>Fri, Apr 5, 2024 at 9:05 AM
To: Corey Fowler <[e-mail]>
Hey Corey,
Thanks for sending this over. I will let you or Eddie know if there is anything else I need to complete my inspection.
Thanks,
Jordan Garahana
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
4/19/24, 11:00 AM State of Utah Mail - Quality Steel of West Jordan
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1795500715938013173&simpl=msg-f:17955007159380131…1/2
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Jordan Garahana <[e-mail]>Wed, Apr 17, 2024 at 2:43 PM
To: Corey Fowler <[e-mail]>
Hey Corey,
Do you have a rolling total for the same time frame for all HAPs combined?
Thanks,
Jordan
On Fri, Apr 5, 2024 at 7:15 AM Corey Fowler <[e-mail]> wrote:
[Quoted text hidden]
[Quoted text hidden]
Corey Fowler <[e-mail]>Wed, Apr 17, 2024 at 2:59 PM
To: Jordan Garahana <[e-mail]>
Jordan,

From what we submitted it should be 24.76543

V/R,

Corey Fowler
HSE Manager
Quality Steel Corporation
5520 W. Old Bingham Hwy | West Jordan, UT 84081
C: 801-834-5750

[Quoted text hidden]
4/19/24, 11:00 AM State of Utah Mail - Quality Steel of West Jordan
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1795500715938013173&simpl=msg-f:17955007159380131…2/2
2022 Emissions Inventory Report
Quality Steel Corporation- Fuel Storage Tank Manufacturing Plant (11598)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)1.30793 0.03329 1.34123
PM10-FIL PM10 Filterable 1.27207 <.00001 1.27207
PM25-PRI PM2.5 Primary (Filt + Cond)0.11632 0.03229 0.14862
PM25-FIL PM2.5 Filterable 0.08046 <.00001 0.08046
PM-CON PM Condensible 0.03586 <.00001 0.03586
SO2 Sulfur Dioxide 0.00377 0.00075 0.00453
NOX Nitrogen Oxides 0.6291 0.3726 1.0017
VOC Volatile Organic Compounds 30.901 0.02944 30.93044
CO Carbon Monoxide 0.52844 0.2415 0.76994
7439921 Lead <.00001 <.00001 <.00001
NH3 Ammonia 0.02013 <.00001 0.02013

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
CAS #110-43-0 123-86-4 71-36-3 108-65-6 67-63-0 78-93-3 80-62-6 97-85-8 97-88-1 100-41-4 106-65-0 108-10-1 123-54-6 623-91-6 627-93-0 868-77-9 1119-40-0 1330-20-7 34590-94-8
Methyl 2, 4 2-2-VOC 12 Month
N Butyl Butyl PM Isopropyl Butyl DiglycolMethyl Isobutyl Butyl Dimethyl Isobutyl Diethyl Dimethyl HydroxyethylDimethyl Methoxymethylet-Total Total VOC Rolling
Year Month M.A.K.Acetate Alcohol Acetate Alcohol Acetate MethacrylateIsobutyrateMethacrylateEthylbenzeneSuccinate Ketone PentanedioneFumarate Glutarate MethacrylateGlutarate Xylene hoxypropanolPounds Tons Total
2023 January 3420.99 385.73 406.65 70.77 359.32 464.56 1.59 4.28 12.21 10.49 33.57 42.58 75.96 36.91 25.17 2.89 109.09 72.08 10.8 5545.64 2.77282 2.77282
2023 February 2292.91 372.3 321.89 91.53 302.59 140.53 2.59 5.99 10.76 6.54 29.45 12.88 70.76 32.89 22.09 4.2 95.71 38.14 15.33 3869.08 1.93454 1.93454
2023 March 3233.76 376.98 22.48 109.74 0 274.26 0.21 7.2 14.32 11.7 37.14 25.14 85.08 43.32 27.85 3.69 120.7 62.96 13.29 4469.82 2.23491 2.23491
2023 April 3373.13 270.61 44.16 64.66 0 538.69 0.46 3.09 11.11 10.16 28.81 49.38 64.57 33.45 21.61 2.2 93.63 76.14 7.76 4693.62 2.34681 2.34681
2023 May 2334.97 327.94 542.83 88.52 520.07 114.52 1.35 6.66 11.64 8.3 30.19 10.5 70.72 35.41 22.64 3.73 98.1 40.28 13.79 4282.16 2.14108 2.14108
2023 June 1131.3 153.75 569.97 71.82 538.98 208.94 0.4 5.94 3.39 0.06 9.16 19.15 24.53 10.73 6.87 2.53 29.77 20.33 10.81 2818.43 1.409215 1.409215
2023 July 3565.3 283.44 528.52 49.03 470.9 555.08 0.82 1.85 12.45 12.66 32.24 49.03 70.21 37.35 24.18 1.67 104.77 83.24 6.29 5889.03 2.944515 2.944515
2023 August 2905.02 285.52 628.65 80.67 574.91 475.07 1 5.37 9.81 6.7 25.66 43.55 60.57 29.89 19.25 3.32 83.4 62.64 12.64 5313.64 2.65682 2.65682
2023 September 1549.3 164.12 309.49 60.07 279.89 273.17 0.19 4.93 4.93 2.42 12.99 25.04 31.95 15.17 9.74 2.25 42.2 32.36 8.74 2828.95 1.414475 1.414475
2023 October 2400.55 257.68 509.86 77.99 446.14 366.2 1.55 4.35 8.48 4.72 22.24 33.57 54.14 25.94 16.68 3.53 72.28 49.61 12.21 4367.72 2.18386 2.18386
2023 November 1832.39 191.48 316.9 58.56 271.63 301.87 0.86 4.45 6.16 3.45 16.18 27.67 39.49 18.87 12.13 2.55 52.58 38.36 9.52 3205.1 1.60255 1.60255
2023 December 1271.22 152.32 233.23 49.32 204.14 166.77 0.78 2.81 4.86 2.81 12.82 15.29 30.94 14.9 9.61 1.96 41.65 24.8 7.43 2247.66 1.12383 1.12383
2024 January 1847.11 148.56 414.46 39.6 360.53 325.62 0 2.46 5.94 3.92 15.44 29.85 34.24 17.9 11.58 1.08 50.17 44.9 4.39 3357.75 1.678875 1.678875
2024 February 3306.45 378.36 654.62 99.3 584.42 317.7 1.14 5.73 14.39 8.23 37.49 29.12 85.85 43.55 28.12 3.71 121.83 69.84 13.25 5803.1 2.90155 2.90155
2024 March 1402.42 164.58 288.82 60.17 253.52 196.96 0.31 3.77 5.18 3.72 13.66 60.17 32.56 15.88 10.25 1.96 44.4 26.08 7.97 2592.38 1.29619 1.29619
2024 April
2024 May
2024 June
2024 July
2024 August
2024 September
2024 October
2024 November
2024 December