DAQ-2024-007980

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DAQC-CI124690001-24
Site ID 12469 (B1)

MEMORANDUM

TO: FILE – WESTERN EMULSIONS, INC. – Woods Cross Hot Asphalt Storage
Terminal (Peak Asphalt)

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: May 7, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County

INSPECTION DATE: April 17, 2024

SOURCE LOCATION: 991 West 1500 South
Woods Cross, UT 84087

DIRECTIONS: Take the road that parallels the west side of the train tracks.
Look for the Peak Asphalt sign.

SOURCE CONTACTS: Mike Thorpe, Plant Manager
385-566-7751, [e-mail]

Matthew Church, Records Contact
208-821-7039, [e-mail]

OPERATING STATUS: Operating normally.

PROCESS DESCRIPTION: Asphalt blending and storage facility. Raw asphalt materials are
shipped to the site by railcar. As the asphalt is needed, the
railcars are heated and the material is piped to the storage tanks.
Hot oil heaters are used to keep the asphalt material warm
enough to flow to and from the storage tanks. Boilers are used to
provide steam for heating the asphalt in the railcars. Materials
are piped to different tanks for blending and adding additives
such as rubber, polymers, and chemicals. The blended material
is then piped to a truck terminal (rack) where it can be loaded
into haul trucks for distribution. Natural gas is used as a fuel in
the boilers and oil heaters. Tanks are all sealed fixed-roof tanks.
Fugitive dust is controlled by the use of magnesium chloride
(MgCl2).

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN124690012-14, dated
August 4, 2014
NSPS (Part 60) Dc: Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units.

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Western Emulsions, Inc. – Woods Cross Hot
Asphalt Storage Terminal

PO Box 50538 991 West 1500 South
Idaho Falls, ID 83405 Woods Cross, UT 84087

SIC Code: 2951: (Asphalt Paving Mixtures & Blocks)

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

Status: In Compliance. No limits appear to have been exceeded. No modifications have been
made to equipment or processes. The source appeared to be adequately maintained. No
breakdowns have occurred. A 2022 emission inventory was submitted to DAQ.

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Section II: SPECIAL PROVISIONS

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

II.A.1 Asphalt and Emulsion Plant
Ergon Asphalt and Emulsions, Incorporated

II.A.2 Medium Cure Asphalt Tanks
Six (6) Tanks
Item numbers 1 through 6
Capacity: 12'x30' each
Service: medium cure asphalt

II.A.3 Asphalt Emulsion Tanks
Nine (9) Tanks in total
Item numbers 7 through 13, 15, and 16

Three (3) tanks
Capacity: 11'x28' each

One (1) tank
Capacity: 11'x30'

One(1) tank
Capacity: 12'x28'

One (1) tank
Capacity: 12'x30'

One (1) tank
Capacity: 11'x16'

Two (2) tanks
Capacity: 12'x30'

Service: asphalt emulsion

II.A.4 Asphalt Cement Tanks
Sixteen Tanks in total
Item numbers 103 through 109, and 201, 202, 206 through 210, 211, and 212

Two (2) tanks
Capacity: 67'x40' each

Two (2) tanks
Capacity: 16.5'x30' each

Two (2) tanks
Capacity: 50.7'x28' each

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One (1) tank
Capacity: 25.6'x30'

One (1) tank
Capacity: 22'x16'

One (1) tank
Capacity: 16.5'x28'

Two (2) tanks
Capacity: 36.6'x40' each

Three (3) tanks
Capacity: 25.7'x30' each

Two (2) tanks
Capacity: 10'x10'

Service: asphalt cement

II.A.5 Distillate Tanks
Three (3) Tanks in total
Item numbers 14, H2, and H3

One (1) tank
Capacity: 12'x30'

Two (2) tanks
Capacity: 7.8'x27.4' each

Service: distillate

II.A.6 Extender Tanks
Three (3) Tanks in total
Item numbers H4, H5, and H8

Two (2) tanks
Capacity: 12'x36' each

One (1) tank
Capacity: 8'x10'

Service: extenders

II.A.7 Miscellaneous Tanks
Six (6) Tanks in total
Item numbers C1, C2, 204, 204, H6, and HCL

One (1) tank
Capacity: 9'x15'
Service: chemical
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One (1) tank
Capacity: 6'x19'
Service: chemical

One (1) tank
Capacity: 7'x21'
Service: anti-strip agent

One (1) tank
Capacity: 10'x14'
Service: sulfur

One (1) tank
Capacity: 11'x28'
Service: water

One (1) tank
Capacity: 6'x19'
Service: HCl

II.A.8 Asphalt Tanks
Two (2) Asphalt Tanks
Item number 301, 302
Capacity: 40'x95' each
Service: asphalt

II.A.9 Heaters
Two (2) heaters
Ratings: One (1) 14.5 MMBtu/hr
One (1) 10 MMBtu/hr

II.A.10 Boilers
Two (2) Boilers
Ratings: One (1) 16.5 MMBtu/hr
One (1) 5.2 MMBtu/hr

II.A.11 Truck Loading Racks

II.A.12 Railcar Heating

II.A.13 Overhead Loading Rack

II.A.14 Furnace
One (1) controlled pyrolysis cleaning furnace
Rating: 0.325 MMBtu/hr

II.A.15 Miscellaneous Equipment
Small storage tanks
Small generators
Asphalt reclamation tanks
Propane heating torches
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Miscellaneous maintenance equipment
Odor control devices (do not control emissions)
Laboratory equipment
Emulsion mills
Polymer grinders
Parts washers
Maintenance equipment

Status: In Compliance. The following were observed:

II.A.2 - medium cure asphalt tanks are only used 1-2 times/year.

II.A.3 - emulsion tanks are no longer used. The emulsion is made at the 1100 North
95 West plant.

II.A.4 - asphalt cement tanks:
2 tanks 67'x40' each - 103 and 104
2 tanks 16.5'x30' each - 105 and 106
2 tanks 50.7'x28' each - 107 and 109
1 tank 25.6'x30' - not in use - no outer shell
1 tank 22'x16' - 201
1 tank 16.5'x28' - 202
2 tanks 36.6'x40' each - 206 and 207
3 tanks 25.7'x30' each - 208, 209, and 210
2 tanks 10'x10' - 211 and 212 - no longer on site

II.A.5 - distillate tanks - horizontal - no longer used, but still on site.

II.A.6 - extender tanks (extenders "soften" the asphalt so road retains shape after
buckling):
2 tanks 12'x36' - H4 and H5
1 tank 8'x10' - H8 - not in use

II.A.7 - miscellaneous tanks:
2 tanks 6'x19' - chemical - C1 and C2 – no longer used.
1 tank 7'x21' - 204 - empty, no longer used.
1 tank 10'x14' - sulfur - no longer used as they now use a dry bagged product.
1 tank 11'x'28' - water - no longer used
1 tank - 6'x9' - HCl - never used

II.A.8 - asphalt tanks - 301 and 302 - not yet built, no current plans - 50,000 bbl each

II.A.9 - heaters - smaller unit is no longer functional.

II.A.10 - boilers - smaller unit no longer used, but the larger boiler is functional

II.A.11 - truck loading racks - 4 (1 not used)

II.A.12 - railcar heating - pipelines from the boiler

II.A.13 - overhead loading rack.
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II.A.14 - furnace - 350,000 Btu/hr oven - in building now used as storage

II.A.15 - miscellaneous equipment: no generators on site; lid was closed on the parts
washer. Also on site was a lime silo with baghouse that is no longer used.

II.B Requirements and Limitations

II.B.1 The Woods Cross asphalt terminal shall comply with the following conditions:

II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with
the source or with the control facilities shall not exceed 10% opacity for the heaters,
furnaces, and boilers, and 20% opacity for all other emission points except for periods of
start-up, shut-down, or malfunction. 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. No visible emissions were observed during the inspection.

II.B.1.b The following throughput limit shall not be exceeded:

260,000,000 gallons of crude oil per rolling 12-month period

A new 12-month total shall be calculated on a monthly basis by summing the monthly
totals for the previous consecutive 12-months. Monthly calculations shall be made no
later than 20 days after the end of each month. Records of throughput shall be kept for
all periods when the plant is in operation. Throughput shall be determined by
examination of company and/or customer billing records. The records of crude oil
throughput shall be kept on a daily basis. [R307-401-8]

Status: Not Applicable. This facility is used as an asphalt storage yard now, no mixing is currently
being done onsite. Zero gallons of crude oil throughput for the current 12-month period. For
informational purposes, the source supplied the total asphalt throughput as 43,883.84 tons for the
12-month period. See attached.

II.B.1.c Visible fugitive dust emissions from haul-road traffic and mobile equipment in
operational areas shall not exceed 20% opacity at any point. Visible emission
determinations 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 fugitive dust emissions were observed. Only one haul truck
came through during the inspection.

II.B.1.d All unpaved operational areas that are used by mobile equipment shall be water sprayed,
and/or chemically treated to control fugitive dust. An application of water, or chemical
treatment shall be used. Treatment shall be of sufficient frequency, intensity, and
duration to maintain the surface material in a damp/moist condition unless it is below
freezing. If chemical treatment is to be used, the plan must be approved by the Director.
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Records of water, and/or chemical treatment shall be kept for all periods when the plant is
in operation. The records shall include the following items:

1. Date
Number of treatments made, dilution ratio, and quantity
Rainfall received, if any, and approximate amount
Time of day treatments were made
Records of temperature if the temperature is below freezing. [R307-401-8]

Status: In Compliance. The operation yard is almost entirely covered with crushed asphalt. Haul
traffic is low. The source only has need to bring in a water truck once or twice a year. Records of
watering are kept in a log in the office.

II.B.1.e The paved in-plant haul road shall not exceed 0.40 miles in combined length, and the
vehicle speed along the haul road shall not exceed 10 miles per hour. [R307-401-8]

Status: In Compliance. The haul road appears to be within the set parameter.

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.

NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units

Status: In Compliance. Notification of the date of construction and startup along with heat input
capacity were submitted in the NOI and archived in the file of the previous owner. Only natural gas is
used as fuel in the boiler.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This condition is met by compliance with NSPS (Part 60) Dc.

Solvent Cleaning [R307-304]

Status: In Compliance. The source uses Safety Kleen Premium Solvent which has a vapor pressure
of 0.2 mm Hg @ 20 C. Waste rags are kept in covered containers.

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Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No visible emissions were observed during the inspection. The operations
yard is almost completely covered with crushed asphalt.

Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. No spills, discarded, or open containers of asphalt or other VOC containing
materials were observed during the inspection.

Degreasing [R307-335]

Status: In Compliance. The source has one parts washer, which is lidded with operation instructions
posted on the inside of the lid. The lid was closed at the time of inspection.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Western Emulsions, Inc.- Woods Cross
Hot Asphalt Storage Terminal. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN124690012-14, dated August 4, 2014 is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1.00
Carbon Monoxide 17.46 1.685
Nitrogen Oxides 19.98 2.006
Particulate Matter - PM10 4.75 0.194
Particulate Matter - PM2.5 4.75 0.157
Sulfur Oxides 0.13 0.012
Volatile Organic Compounds 45.93 0.739

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 208
Generic HAPs (CAS #GHAPS) 342
Hexane (CAS #110543) 790
Xylenes (Isomers And Mixture) (CAS #1330207) 146

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN124690012-14,
dated August 4, 2014: the source should be considered in
compliance. The facility appeared to be adequately maintained
and operated properly. Records were made available for review
during the inspection and after by email.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal. Steel toes, hard hat, safety glasses, and long
sleeves are required to walk the facility.

NSR RECOMMENDATIONS: Update process and equipment list if any modifications are
made.

ATTACHMENTS: VEO Form, Email, Throughput Record.
Shipping Report
Material shiped between April 01, 2023 and March 31, 2024
WXN1 - Woods Cross North Asphalt & FG Tons Shipped
AC - Asphalt Cement
PG58-28 36,687.92
PG64-22 5,227.73
Total AC Shipped 41,915.65
Blended AC - Blended Asphalts Finished
Goods
15-Pen 554.90
56 PEN 1,413.29
Total Blended AC Shipped 1,968.19
Intermediate - Inventoried Intermediates
30 Pen 908.66
Total Intermediate
Shipped
908.66
WXN1 Product Summary
41,915.65AC
1,968.19Blended AC
908.66Intermediate
44,792.50
43,883.84
Total Shipped:
Total Asphalt Throughput
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Business Date:4/25/2024
9:40:39 AM4/25/2024Run Date: