DAQ-2024-004563

1
DAQC-CI130680001-23
Site ID 13068 (B1)

MEMORANDUM

TO: FILE – BULLFROG INTERNATIONAL L.C. – Bluffdale Spa Manufacturing

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: November 16, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: October 26, 2023

SOURCE LOCATION: 668 West 14600 South
Bluffdale, UT 84065
SOURCE CONTACTS: Derek Steiner, Health, Safety, & Environment Manager
[e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Bullfrog Spas operates a manufacturing facility that fabricates
acrylic spas. The process consists of thermal forming of acrylic
sheets to form the spa. Using robotic spray units, diisocyanate
based foam (using structural foam instead of styrene) is then
sprayed on to the exterior of the shell to provide strength. PVC
piping is added to supply air jets. Methyl methacrylate is used to
attach the polyvinylchloride fixtures. Finally, an additional layer
of foam is applied to provide a layer of insulation. A11 activities
are performed indoors.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN130680003-17 dated April 13,
2017

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Bullfrog International L.C.
Bluffdale Spa Manufacturing

668 West 14600 South 668 West 14600 South
Bluffdale, UT 84065 Bluffdale, UT 84065

SIC Code: 3089: (Plastics Products, NEC)

2
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: In Compliance. No breakdowns have occurred since the previous inspection. The
most recent Emission Inventory submitted was for 2020. Source was reminded of their next
submission date on April 15, 2024, for the year 2023.

Section II: SPECIAL PROVISIONS

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

II.A.1 Bullfrog International - Spa Manufacturing

II.A.2 Spa Manufacturing Process
Spa Manufacturing including:
Heating device
Vacuum fitting

II.A.3 Polymeric Diphenylmethane Diisocyanate Process
Foam application of the chemical to the underside of the spa

II.A.4 PVC Process
Pipe fitting with junctions installed in the spa using methyl methacrylates

II.A.5 Diphenylmethane Diisocyanate (MDI) Foam Process
Foam application of the chemical to the underside of the spa

II.A.6 Maintenance Operations
Welding
Grinding
3
II.A.7 Boilers and Heaters
Several boilers and heaters rated less than 5 MMBtu/hr each
Fuel: natural gas

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

II.B Requirements and Limitations

II.B.1 VOC and HAP Limitations

II.B.1.a The plant-wide emissions of VOCs, and HAP from the two spray booths, and associated
operations shall not exceed:

19.39 tons per rolling 12-month period for VOCs
0.20 tons per rolling 12-month period for methyl methacrylate
0.04 tons per rolling 12-month period for 1,1,2 trichloroethane. [R307-401-8]

II.B.1.a.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
twentieth day of each month, a new 12-month total shall be calculated using data from the
previous 12 months. The VOC, and HAP emissions shall be determined by maintaining a record
of VOC, and HAP emitting materials used each month. The record shall include the following
data for each material used:

A. Name of the VOC, and HAP emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, toxics, isocyanates, etc.

B. Density of each material used (pounds per gallon)

C. Percent by weight of all VOC, and HAP in each material used

D. Gallons of each VOC, and HAP emitting material used

E. The amount of VOC, and HAP emitted monthly by each material used shall be
calculated by the following procedure:

VOC = [% VOC by Weight/100] x [Density (lb/gal)] x [Gal Consumed] x (1 ton/2,000 lb)

HAPs = [% HAP by weight/100] x [Density (lb/gal)] x [Gal Consumed] x (1 ton/2000 lb) x
(emission factor).

Bullfrog has used 2% HAP for the emission factor in its methyl methacrylate calculations
and 0.27% HAP for the emission factor in its 1,1,2 trichloroethane calculations.

F. The amount of VOC, or HAP emitted monthly from all materials used.

G. The amount of VOCs, or HAP reclaimed or otherwise not emitted for the month shall be
similarly quantified and subtracted from the quantities calculated above to provide the
monthly total VOC, or HAP emissions. [R307-401-8]

Status: In Compliance. The rolling 12-month total from November 2022 to October for
VOC, methyl methacrylate, and 1,1,2 trichloroethane emissions are as follows:

13 tons of VOCs emitted
0.12 tons of methyl methacrylate emitted
0 tons of 1,1,2 trichloroethane emitted

4
Records indicate the calculations used, amount emitted, emission factor used, and the name
and SDS of the VOC. The source indicated that the product that contains methyl
methacrylate utilized onsite removed the 1,1,2 trichloroethane component in its ingredient
list years ago. See the attachments section for additional information.

II.B.1.b The owner/operator shall comply with the applicable requirements in R307-342. [R307-342]

Status: In Compliance. The source utilizes adhesives and sealants that fall under the
permitted limits for this area source rule. Information about the VOC content per liter is
maintained for each product that falls under this rule and the source utilizes the hand
application method for applying the adhesives and sealants. All required records are stored
onsite. See the attachments section and the Area Source Rules section for additional
information.

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.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Solvent Cleaning [R307-304]

Status: Not Applicable. The only solvent utilized onsite is Fantastic All-Purpose Cleaner, which has a
VOC content of 0.5 percent by weight.

Davis and Salt Lake Counties and Ozone Nonattainment Areas: Ozone Provisions [R307-325]

Status: In Compliance. No VOC laden rags and containers were observed to be out of compliance.
No spills appeared to be observed as well. Any containers of VOC were closed when not in use.

Adhesives and Sealants [R307-342]

Status: In Compliance. The source applies all adhesives and sealants by the hand application
method. The adhesives and sealants that are utilized at this site are as follows with their
corresponding VOC content:

Weld-On P68 Primer- 550 g/l VOC

Weld-On 717 PVC Cement- 425 g/l VOC

Weld-On 4707 ABS Cement- 410 g/l VOC

Boss 801 Pool & Spa Silicone- 26 g/l VOC

ITW Devcon MA 300 Black and White Part A- <10 g/l VOC

ITW Devcon MA 330 Black and White Part B- <10 g/l VOC

All of the VOC contents listed for the adhesives and sealants used onsite fall under the limits set
within R307-342. See the attachments section for additional information.
5
EMISSION INVENTORY:

Listed below are the Actual Emissions Inventory provided by Bullfrog International L.C. – Bluffdale Spa
Manufacturing. A comparison of the estimated total potential emissions (PTE) on Approval Order
DAQE-AN130680003-17, dated April 13, 2017, is provided. The 2020 Emissions Inventory is listed
below. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 251.00
Carbon Monoxide 0.20 1.45
Nitrogen Oxides 0.24 1.76
Particulate Matter - PM10 0.02 0.13
Particulate Matter - PM2.5 0.02 0.13
Sulfur Dioxide 0.00 0.01
Volatile Organic Compounds 19.39 5.22

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
1,1,2-Trichloroethane (CAS #79005) 80
Methyl Methacrylate (CAS #80626) 400

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN130680003-17,
dated April 13, 2017: In compliance with the conditions listed
within the AO. Records were made available, and the facility
appears to be well maintained.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the usual interval.

ATTACHMENTS: Applicable Supporting Documentation Included
2020 Emissions Inventory Report
Emissions Summary for Bullfrog International L.C.- Bluffdale Spa Manufacturing (13068)
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)0.13479 <.00001 0.13479
PM10-FIL PM10 Filterable 0.0337 <.00001 0.0337
PM25-PRI PM2.5 Primary (Filt + Cond)0.13479 <.00001 0.13479
PM25-FIL PM2.5 Filterable 0.0337 <.00001 0.0337
PM-CON PM Condensible 0.10109 <.00001 0.10109
SO2 Sulfur Dioxide 0.01064 <.00001 0.01064
NOX Nitrogen Oxides 1.76819 <.00001 1.76819
VOC Volatile Organic Compounds 5.22754 <.00001 5.22754
CO Carbon Monoxide 1.4508 <.00001 1.4508
7439921 Lead 0.00001 <.00001 0.00001
NH3 Ammonia 0.05392 <.00001 0.05392

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
11/16/23, 3:20 PM State of Utah Mail - Bullfrog Records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1782736747881047214&simpl=msg-f:17827367478810472…1/2
Jordan Garahana <[e-mail]>
Bullfrog Records from inspection on 10/26
3 messages
Bart Adams <[e-mail]>Thu, Nov 16, 2023 at 8:57 AM
To: "[e-mail]" <[e-mail]>
Cc: Derek Steiner <[e-mail]>
Jordan,
I work with Derek Steiner at Bullfrog.
Huge apology for the delay in responding to your requests for the record keeping requirements for Bullfrog
Spa DAQE-AN130680003-17.
I have aached the requested data II-.B.1.a.
If you have any quesons or need anything else, please let us know.
Kind Regards,
Bart Adams
801-599-2748
[e-mail]
www.summit-enviro.com
Bull Bluff 12 Month Rolling VOC-HAPs Oct 2023 FNL RTF.xlsx
43K
Bart Adams <[e-mail]>Thu, Nov 16, 2023 at 9:02 AM
To: "[e-mail]" <[e-mail]>
Cc: Derek Steiner <[e-mail]>
Jordan,
Forgot to menon that the manufacturer of the MMA containing product dropped the 1,1,2 trichloroethane
out of the product several years ago.
Kind Regards,
Bart Adams
801-599-2748
From: Bart Adams
Sent: Thursday, November 16, 2023 8:57 AM
To: [e-mail] <[e-mail]>
Cc: Derek Steiner <[e-mail]>
Subject: Bullfrog Records from inspecon on 10/26
11/16/23, 3:20 PM State of Utah Mail - Bullfrog Records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1782736747881047214&simpl=msg-f:17827367478810472…2/2

[Quoted text hidden]
Jordan Garahana <[e-mail]>Thu, Nov 16, 2023 at 11:20 AM
To: Bart Adams <[e-mail]>
Cc: Derek Steiner <[e-mail]>
Hey Bart,
Thank you for sending the information I requested over to me. I appreciate yours and Derek's help with getting the
records to me. If I have any questions or information to help complete my inspection I will let you know.
Thanks,
Jordan Garahana
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
11/16/23, 3:19 PM State of Utah Mail - Records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-6051522118381321602&simpl=msg-a:r112424063610911…1/3
Jordan Garahana <[e-mail]>
Records from inspection on 10/26
5 messages
Jordan Garahana <[e-mail]>Tue, Nov 7, 2023 at 10:10 AM
To: [e-mail]
Hey Derek,
Do you have any update on the records that I requested from my inspection on 10/26 of the Bluffdale Bullfrog Spa Plant?
As a reminder, I am looking for these records to help complete my inspection:
II.B.1.a- rolling 12-month total (November 2022 - October 2023) of VOCs, methyl methacrylate and 1,1,2 trichloroethane
emissions plant wide and the associated calculations that you use to get that number.
State Rule R307-342: VOC contents for adhesives, sealants, ad primers, sealant primers and adhesives applied to
particular substrates. I need the VOC content for any of these that are used in the plant. The previous inspector noted that
you used Devcon Plastic Welder, ABS glue (pipe cement), PVC glue (pipe cement), Boss 801 silicone sealant and PVC
and ABS primer that fit into this rule. Please let me know if you have added anything else to that list or if you no longer
use any of those listed above.
Please let me know if you have any questions about what I am requesting. Please have this to me by the end of the week.
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Derek Steiner <[e-mail]>Tue, Nov 7, 2023 at 11:23 AM
To: Jordan Garahana <[e-mail]>
Hi Jordan,

I never received a request for documentation. But I will compile the documents that you need.

There have been a couple of additions for VOC emitters, but they are mostly chemicals that are replacing a similar
product.
11/16/23, 3:19 PM State of Utah Mail - Records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-6051522118381321602&simpl=msg-a:r112424063610911…2/3

Thanks,

The above email contains informaon that may be confidenal and/or privileged. Except for personal use by the intended
recipient, or as expressly authorized by the sender, any person who receives this informaon is prohibited from disclosing, copying,
distribung and/or using it. If you have received this message in error, please delete it and all copies immediately and promptly
nofy the sender. Nothing in this communicaon is intended to operate as an electronic signature under applicable law.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Mon, Nov 13, 2023 at 11:07 AM
To: Derek Steiner <[e-mail]>
Hey Derek,
Any update on the records I requested?
Thanks,
Jordan
[Quoted text hidden]
Derek Steiner <[e-mail]>Mon, Nov 13, 2023 at 3:10 PM
To: Jordan Garahana <[e-mail]>
11/16/23, 3:19 PM State of Utah Mail - Records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-6051522118381321602&simpl=msg-a:r112424063610911…3/3
Hi Jordan,

Sorry for the delay. I’ve been working with our purchasing team to make sure my list was accurate and complete. I
thought we had added some items that were VOC emitters, but it turns out they are not.

I should have this ready today or tomorrow at the latest.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Wed, Nov 15, 2023 at 3:10 PM
To: Derek Steiner <[e-mail]>
Hey Derek,
Any update on those records? If I don't have them by tomorrow end of the day, I will have to issue a Compliance Advisory
for not producing the records in a timely manner. Please let me know of an update as soon as possible.
Thanks,
Jordan
[Quoted text hidden]
11/16/23, 3:20 PM State of Utah Mail - Status of records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8335454562315874529&simpl=msg-a:r-92096185661938…1/2
Jordan Garahana <[e-mail]>
Status of records from inspection on 10/26
2 messages
Jordan Garahana <[e-mail]>Mon, Nov 6, 2023 at 12:25 PM
To: [e-mail]
Hello Dan,
This is Jordan Garahana from the Division of Air Quality. I was just checking in to see if there was an update on the status
of the records I requested from my inspection on 10/26? It has been 10 days since my inspection and I haven't
received any of the records. Is there an update you can provide me?
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Daniel Kissell <[e-mail]>Mon, Nov 6, 2023 at 12:50 PM
To: Jordan Garahana <[e-mail]>, Derek Steiner <[e-mail]>
Jordan,
I've sent this email and added Derek Steiner to this email. Derek is the health and safety coordinator at Bullfrog Spas.
He can help you with getting the documents that you need.
Regards,
Dan Kissell
11/16/23, 3:20 PM State of Utah Mail - Status of records from inspection on 10/26
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8335454562315874529&simpl=msg-a:r-92096185661938…2/2
The above email contains informaon that may be confidenal and/or privileged. Except for personal use by the intended
recipient, or as expressly authorized by the sender, any person who receives this informaon is prohibited from disclosing, copying,
distribung and/or using it. If you have received this message in error, please delete it and all copies immediately and promptly
nofy the sender. Nothing in this communicaon is intended to operate as an electronic signature under applicable law.
From: Jordan Garahana <[e-mail]>
Sent: Monday, November 6, 2023 12:25:41 PM
To: Daniel Kissell <[e-mail]>
Subject: Status of records from inspecon on 10/26

[Quoted text hidden]
Bluffdale, UT Facility
12 Month Rolling Total Emissions
Instructions: Enter "Spas Manufactured" the previous month by the 20th of each month.
VOC (includes MMA)MMA (80-62-6)1,1,2 Trichlor (Obsolete)
Emission Emitted Emission Emitted Emitted
Spas
Manufactured
Factor
(lbs/spa)
Emitted
(lbs)
During Past
12 Months
(tons)
Factor
(lbs/spa)
Emitted
(lbs)
During Past
12 Months
(tons)
During Past
12 Months (tons)
Permit Limit:19.39 Permit Limit:0.2 0.04
November 2021 62 2.6667 165 0.02587 2 0.00
December 2021 29 2.6667 77 0.02587 1 0.00
January 2022 55 2.6667 147 0.02587 1 0.00
February 2022 62 2.6667 165 0.02587 2 0.00
March 2022 58 2.6667 155 0.02587 2 0.00
April 2022 57 2.6667 152 0.02587 1 0.00
May 2022 66 2.6667 176 0.02587 2 0.00
June 2022 110 2.6667 293 0.02587 3 0.00
July 2022 79 2.6667 211 0.02587 2 0.00
August 2022 88 2.6667 235 0.02587 2 0.00
September 2022 87 2.6667 232 0.02587 2 0.00
October 2022 97 2.6667 259 0.02587 3 0.00
November 2022 56 2.6667 149 1.13 0.02587 1 0.01 0.00
December 2022 26 2.6667 69 1.12 0.02587 1 0.01 0.00
January 2023 50 2.6667 133 1.11 0.02587 1 0.01 0.00
February 2023 56 2.6667 149 1.11 0.02587 1 0.01 0.00
March 2023 53 2.6667 141 1.10 0.02587 1 0.01 0.00
April 2023 52 2.6667 139 1.09 0.02587 1 0.01 0.00
May 2023 60 2.6667 160 1.09 0.02587 2 0.01 0.00
June 2023 100 2.6667 267 1.07 0.02587 3 0.01 0.00
July 2023 72 2.6667 192 1.06 0.02587 2 0.01 0.00
August 2023 80 2.6667 213 1.05 0.02587 2 0.01 0.00
September 2023 79 2.6667 211 1.04 0.02587 2 0.01 0.00
October 2023 88 2.6667 235 1.03 0.02587 2 0.01 0.00
November 2023
December 2023
January 2024
February 2024
March 2024
April 2024
May 2024
June 2024
July 2024
August 2024
September 2024
October 2024
November 2024
December 2024
January 2025
February 2025
Bluffdale, UT Facility
Emission Factor Calculations
Enter data into blue cells only.
Period Covered: Nov 1, 2022 through Oct 31, 2023
Spas Produced: 772
Plant-wide Emissions
Usage VOC MMA
Dur ing
Period (lbs) (lbs)
Weld-On P-68 Primer 262 0.946 248 550 136,369 0.002205 100 301
(Quart Cans) l/qt used (l) VOC (g/l) VOC (g) lbs/g % Emitted
Weld-On 717 PVC 1,764 0.946 1,669 425 709,481 0.002205 100 1,564
(Quart Cans) l/qt used (l) VOC (g/l) VOC (g) lbs/g % Emitted
Weld-On 4707 ABS
Cement 44 3.785 167 410 68,289 0.002205 100 151
(Gallon Can) l/gal used (l) VOC (g/l) VOC (g) lbs/g % Emitted
Boss 801 Pool & Spa
Silicone 1,381 13,810 0.0295735 408 26 10,619 0.002205 100 23
(10 fl oz used (fl oz) l/fl oz used (liters) VOC (g/l) VOC (g) lbs/g % Emitted
ITW Devcon MA 300
Black and White Part A 1,752 350 1,000 350,400 773 55 2 8 8
(200 ml cart) used (l) density (g/l) used (g) used (lb) % MMA % Emitted
ITW Devcon MA 330
Black and White Part B 1,752 350 990 346,896 765 75 2 11 11
(200 ml cart) used (l) density (g/l) used (g) used (lb) % MMA % Emitted
TOTAL Emitted During Period: 2,059 20
Spas Produced During Period: 772 772
Emissions per Spa (lbs): 2.66673 0.02587
Notes:
1. This worksheet calculates VOC and HAP emission factors by comparing the VOC and MMA emissions for the given period to spas produced
during that period. Unless there are product changes, emission factors are calculated for each calendar year and then these emission factors
are used to determine emissions during each of the next 12 months.
2. This worksheet does not calculate emissions from any polyurethane diisocyanate foam products as the emissions are negligabl e.