DAQ-2024-007756

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DAQC-410-24
Site ID 10833 (B1)
MEMORANDUM

TO: FILE – VALMONT COATINGS INTERMOUNTAIN GALVANIZING

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: March 19, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: February 28, 2024

SOURCE LOCATION: 1085 West 400 North Lindon, UT 84042

I-15 south to Exit 273. Right onto Geneva Road, left onto 500
North, over the railroad tracks, left onto 1030 West which turns
into 400 North. The main office is located inside the chain link
fence from the east gate, head south towards the building on the
right. Second office to the south labeled “Main Office.”

SOURCE CONTACTS: Eva Snow: General Manager
801-785-7200, [e-mail]

Phil Nicholes, Operations Manager:
801-785-7200, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN108330005-12, dated
November 28, 2012

PROCESS DESCRIPTION

Hot-dip galvanizing of steel in a 46'x6'x6' kettle. Steel is shipped in by truck and unloaded in
the receiving yard with a front-end loader, then taken into the building to the steel racking area.
Each piece is chained to an overhead crane (racked) and dipped into a series of tanks. The plant
water is heated by means of two natural gas-fired boilers. Finished pieces of steel are hauled into
the shipping yard with the FEL and loaded onto trucks for shipment. The process is as follows:

Caustic Soda Tanks (2): Both tanks contain a heated solution (160-180°F) of sodium hydroxide
(8-10%), zinc (0.3%), and water. The steel is dipped into these tanks using the overhead crane to
remove oil, grease, and reduce the amount of iron lost from the steel.

Caustic Rinse Tank: The cleaned steel is dipped into the rinse tank to remove some of the caustic
solution from the steel. This tank is filled with room temperature rinse water, and is used as
make-up water for the caustic soda tanks, allowing for reclamation of the chemicals.

/ :
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Pickling Tanks (3): Each contains a heated solution (140°-150°F) of sulfuric acid (10-15%), iron
(6-8%), and water. The solution reacts with the remaining caustic soda solution on the steel
generating heat. This heat speeds up the reaction of the acid solution with the mill scale and rust
on the metal. As the metal itself is attacked by the acid, hydrogen gas is produced, which also
helps pop off scale. The vapors and steam emitted from the pickling tanks are drawn up through
two overhead exhaust fans and vented out through the roof of the building.

Acid Rinse Tanks (2): The steel is double-dipped in the acid rinse tanks to remove any sulfates
left on the steel after pickling.

Preflux Tank: This tank contains a heated solution (150 - 160°F) of ammonium chloride, zinc
Chloride, and a Merpol wetting agent. Baume (Be) is the weight of the flux solution and is
maintained between 12 and 14. ACN is the ratio of ammonium chloride to zinc chloride and is
maintained between 1.3 and 1.6. The pH of the solution is kept between 4.0 and 4.5. The steel is
dipped into this tank to deoxidize it and give it a rust preventative coating.

Zinc Kettles (2): The kettles contain molten zinc at 840°F to coat the steel with a thin layer of
zinc (-3.7 millimeters thick). The kettle has a burner capacity of 9 MMBTU/hr and is fired by
natural gas. Emissions from the kettles are drawn up by overhead fans and vented through the
roof of the building.

Quench Tanks (2): From the zinc kettle, the steel is dipped into a water quench tank (~200°F).
Some items, such as guard rails, are then dipped in a chromate quench tank to prevent white rust
from developing. The chromate quench tank is kept between room temperature and 100°F and
contains between 0.05-0.10% chromic acid and water.

Powder Coat Line: An enclosed Wheelabrator shot blaster is controlled by filters that discharge
inside the building. Metal parts are hooked onto a moving conveyor that goes through an
enclosed powder coat chamber. The parts are powder-coated and conveyed to the bake oven
where it is heated to 350°F. The over spray from the coating booth is captured in a filter and
recycled.

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
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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 R307-150 Series. Inventories, Testing and
Monitoring. [R307-150]

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

Status: In Compliance. There were no limits exceeded in this AO. Valmont Coatings
maintains records for at least two years, and maintains records of maintenance
activities performed on approved equipment. According to Valmont Coatings, there
were no breakdowns resulting in emissions events. At this time, Valmont Coatings
is not required to submit an Emissions Inventory Report.

Section II: SPECIAL PROVISIONS

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

II.A.1 Protection Coatings
Galvanizing Facility

II.A.2 Two natural gas-fired boilers
Manufactured by Sellers, model #LN490, rated at 80 bhp

II.A.3 Shot blaster attached to dust collector #1
Airless centrifugal steel shot blaster, manufactured by Wheelabrator, equipped with a
dust collector discharged inside the building

II.A.4 One dust collector attached to coating booth Electrostatic powder coating booth, designed
by Valmont Industries, equipped with a cartridge dust collector, discharged into the
building

II.A.5 Curing oven #1
Powder curing oven, manufactured by Milbank Systems, natural gas-fired, rated at 1
MMBtu/hr

II.A.6 Sulfuric acid tanks 1 thru 4
Sulfuric acid tanks, total of four

II.A.7 Molten zinc kettles #1 and #2
Molten zinc kettles one rated at 9 MMBtu/hr and the second one rated at 6 MMBtu/hr
(new)
II.A.8 Caustic soda tanks #1 and #2
Two caustic soda tanks (no emissions)
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II.A.9 Caustic rinse tank #1
One caustic rinse tank (no emissions)

II.A.10 Sulfuric acid rinse tanks # 1 and #2
Two sulfuric acid rinse tanks

II.A.11 Zinc/Ammonium chloride preflux tank #1
One Zinc/Ammonium chloride preflux tank (no emissions)

II.A.12 Water quench tank #1
One water quench tank (no emissions)

II.A.13 Chromate quench tank #1
One chromate quench tank (no emissions)

II.A.14 Metallic zinc recovery (MZR) unit, model 750
Zinc recovery unit to recover metallic zinc from the kettle-skims. The rated
capacity of the unit is 1,329 pounds per batch, heated by natural gas combustion.

Status: In Compliance. There were no new or unapproved equipment observed
operating at the time of inspection. Additional equipment information confirmed at
the time of inspection, and noted in DAQC-344-21.

● II.A.1, and II.A.3 through II.A.5 are housed together in a separate building east of the
main office and are referred to as the “Powder Coat Building Line”

● II.A.2 and II.A.6 through II.A.14 are located in the same building as the main office and
referred to as the “Galv Building Line”

● II.A.3 - Shot blaster attached to dust collector uses #1 steel shot

● II.A.6 - Only three tanks are used. Each tank has been replaced with a polypropylene
material that is the same size and capacity.

● II.A.7 - One kettle is currently in operation rated at 6MMBtu/hr. The other kettle has
been taken offline with no plans for future use.

● II.A.10 - Rinse tank #2 was demolished and is being rebuilt on-site at the time of
inspection.

During this inspection, it was confirmed that Rinse Tank #2 was a metal tank with
plastic liners. The new tank is all plastic.

● II.A.14 - Metallic zinc recovery (MZR) was not operating.

During this inspection, the Metallic Zinc Recovery was in operation.

● One small sand blaster (uses crushed garnet) was located in the southeast corner of the
Powder Coat building but it vents inside the building and is not considered an emitting
source.

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II.B Requirements and Limitations

II.B.1 Requirements and Limitations

II.B.1.a The owner/operator shall notify the Director in writing when the burners have been
replaced in the galvanizing kettles and the kettle has become operational. To ensure

proper credit when notifying the Director, send your correspondence to the Director,
Attn: Compliance Section.

If the owner/operator has not notified the Director in writing within 18 months from the
date of this AO on the status of the construction and/or installation, the Director shall
require documentation of the continuous construction and/or installation of the operation.
If a continuous program of construction and/or installation is not proceeding, the Director
may revoke the AO. [R307-401-18]

Status: In Compliance. On January 30, 2013, the DAQ received a notification, dated
January 25, 2013. See the DAQ files for additional information.

II.B.1.b Visible emissions from the following emission points shall not exceed the following
values:

1) Shot blasting operation - 20% opacity
2) All other points - 10% opacity [R307-306, R307-401-8]

II.B.1.b.1 Opacity observations of emissions from the 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 requirement 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. [R307-201]

Status: In Compliance. There were no visible emissions from the shot blasting
operation and all other points during this inspection. The opacity observations were
conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment for
additional information.

II.B.1.c The following limits shall not be exceeded:

1) 4,980 tons of zinc usage for coatings per rolling 12-month period
2) 229,000 decatherms of natural gas consumed per rolling 12-month period
3) 1,700 tons of kettle-skims processed in MZR unit per rolling 12-month period
[R307-401-8]

II.B.1.c.1 Compliance with the annual limitations shall be determined by a rolling 12-month total.
No later than 20 days after the end of each month the owner/operator shall calculate a
new 12-month total using data from the previous 12 months. Records of zinc usage,
consumption of natural gas and the amount of kettle-skims processed shall be kept when
the plant is in operation. These records, including 12-month total, shall be made
available to the Director or the Director's representative upon request. The usage of zinc
shall be determined by examination of an inventory log which keeps track of zinc
delivery and drawdown. The zinc inventory log shall be kept at the plant at all times and
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shall be updated as the inventory changes. Consumption of natural gas shall be
determined by examination of natural gas fuel bills. Each batch of the amount of kettle-
skims processed in the MZR unit shall be recorded in a log. The kettle-skims processed
shall be determined by examination of the log. [R307-401-8]

Status: In Compliance. Valmont Coatings determined the zinc usage from an
inventory log; the consumption of natural gas, from the gas bills; and the amount of
kettle-skims processed, from recorded logs. The consumption in a rolling 12-month
period, from February 2023 to January 2024, indicated the following amounts:

1) 670.99 tons of zinc usage for coatings
2) 44.88 million standard cubic feet or 44,876 Dekatherms.
3) 39.09 tons of kettle-skims processed in MZR unit.

See the attachment for additional information.

II.B.1.d The temperature of the NaOH caustic tank shall not exceed 180 degrees Fahrenheit. The
concentration of NaOH shall be checked using a method which has been approved by the
Director. The tank shall be equipped with a thermometer to measure NaOH temperature.
The thermometer shall be located where an operator/inspector can safely read the
temperature at any time. Continuous recording is not required. The temperature and the
concentration of the NaOH shall be read and recorded in a log at least once every week.
[R307-401-8]

Status: In Compliance. Temperature readings recorded during this inspection were
less than 180 degrees Fahrenheit indicating compliance with this AO Condition. See
the temperature readings of Caustic Tanks #1 and #2 in the attachment.

II.B.1.e Valmont Coatings Intermountain Galvanizing shall maintain the following operating
parameters in the preflux tank:

1) Degrees Baume (Be) between 10-18.

2) Temperature no greater than 160 degrees Fahrenheit.

The tank shall be equipped with a thermometer to measure the water temperature. The
thermometer shall be located where an operator/inspector can safely read the temperature
at any time. Continuous recording is not required. Both the Baume and the temperature
shall be measured at least once every seven days. Both parameters shall be recorded in a
log. [R307-401-8]

Status: In Compliance. Valmont Coatings maintained the following parameters
during this inspection:

1) Degrees Baume (Be) between 12-16.

2) Temperature indicated 124 degrees Fahrenheit.

See additional information in the attachment.

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II.B.1.f Valmont Coatings Intermountain Galvanizing shall use only natural gas as fuel in the
plant. [R307-401-8]

Status: In Compliance. Valmont Coatings confirmed that natural gas is the only fuel
used in the plant.

II.B.1.g The concentration of sulfuric acid in the acid pickling tank shall not exceed 15% by
weight. The temperature of the acid pickling tank shall not exceed 160 degrees
Fahrenheit. The concentration of sulfuric acid shall be checked two times per week. The
tank shall be equipped with a thermometer to measure the water temperature. The
thermometer shall be located where an operator/inspector can safely read the temperature
at any time. Continuous recording is not required. The temperature reading shall be
taken once a week. Both the temperature and the concentration shall be recorded in a log.
[R307-401-8]

Status: In Compliance. Records reviewed during this inspection indicated a
temperature range from 138-140 degrees Fahrenheit. The concentration of sulfuric
acid in the pickling tank ranged from 7.9-8.2%. See the attachment for additional
information.

II.B.1.h The Approval Order is for a batch-type galvanizing operation only. Continuous
galvanizing operations for such things as chain link fence or other continuous operations
shall require an Approval Order modification. [R307-401-8]

Status: In Compliance. Valmont Coatings confirmed that hot dip galvanizing
operations were of the batch-type and with no continuous galvanizing operations.
The clean steel is immersed into molten zinc where a reaction between the iron and
zinc occurs to provide a coating as part of the steel.

II.B.1.i The galvanizing kettle operation shall be the dry-type. The flux shall be skimmed off as
necessary to meet the opacity limit. [R307-201]

Status: In Compliance. Valmont Coatings confirmed that the kettle operation is the
dry-type which includes pre-fluxing in a zinc ammonium chloride solution, with the
flux skimmed off as necessary to meet the opacity limit.

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.

There are no Federal rules applicable to the processes of this facility.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards

Status: In Compliance. There were no visible emissions from the blasting shot operation and all
other points during this inspection. The opacity observations were conducted according to
40 CFR 60, Appendix A, Method 9. See the attachment for additional information.

R307-306. PM10 Nonattainment and Maintenance Areas: Abrasive Blasting

Status: In Compliance. Valmont Coatings operates an airless centrifugal steel shot blaster equipped
with a dust collector that discharges inside the building. Blasting is confined and the blast media is
S280. There were no visible emissions observed from the blaster during this inspection. See the
SDS of the blast media in the attachment.

R307-309. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive
Dust.
Status: In Compliance. There were no visible emissions observed from unpaved haul roads during
this inspection.
R307-325 Ozone Nonattainment and Maintenance Areas: General Requirements.

Status: In Compliance. There were no spills or open containers containing VOCs observed onsite.
Valmont Operation uses powder coating which is applied electrostatically and cured in an oven.
The coating booth is equipped with fabric filters which are periodically blown down and the
powder collected into a drum.

R307-335: Degreasing

Status: Non-Compliance. The degreaser was not observed during this inspection. A picture of the
degreaser was however, requested. A picture of an opened degreaser was received. Compliance
Assistance was immediately provided to Valmont to keep the degreaser closed when not in use.
Valmont immediately took corrective action to include a signage for the team to keep the degreaser
closed when not in use. No further action required. The spent degreaser is transferred for offsite
disposal by Safety Kleen. See the attachment for additional information.

EMISSION INVENTORY: Valmont Coatings is not required to submit an Emission
Inventory Report.

Listed below are the total potential emissions from Valmont
Coatings Intermountain Galvanizing – Galvanizing Facility on
the Approval Order (AO) DAQE-AN108330005-12, dated
November 28, 2012. The following information was supplied
for supplemental purposes only.

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

COMPLIANCE STATUS &
RECOMMENDATIONS: Valmont Coatings is not in compliance with R307-335:
Degreasing for sending a picture of an open degreaser.
Compliance Assistance provided, and Valmont Coatings takes
immediate corrective action and sends another picture of the
degreaser with signage to keep degreaser closed at all times
when not in use. No further action required at this time. Valmont
Coatings indicated compliance with the conditions of
AO DAQE-AN108330005-12 dated November 28, 2012, at the
time of inspection. Valmont Coatings maintained good
housekeeping practices.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes hard hat, steel-toe
boots, reflective vest, and safety glasses. Evaluate the degreaser.

RECOMMENDATION FOR
NSR: None at this time.

ATTACHMENTS: Rolling 12-month for Zinc Use, Natural Gas Use, Skims
processed, Galvanized steel, Test Results Entry Form, Monthly
Emissions Summary, Parts Washer, Email Communication, SDS
Pollutant Tons/yr
Carbon Monoxide 2.84
Lead Compounds 0.01
Nitrogen Oxides 9.29
Particulate Matter - PM10 11.04
Particulate Matter - PM2.5 5.52
Sulfur Dioxide 0.07
Volatile Organic Compounds 0.66