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HomeMy WebLinkAboutDAQ-2024-0077291 DAQC-CI157060001-24 Site ID 15706 (B1) MEMORANDUM TO: FILE – DUNCAN AVIATION, INC – Aircraft Maintenance, Repair, and Overhaul (MRO) Complex THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jordan Garahana, Environmental Scientist DATE: April 5, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: March 14, 2024 SOURCE LOCATION: 262 South 3800 West Provo, UT 84601 SOURCE CONTACTS: Bruce Jensen, Environmental Supervisor bruce.jensen@duncanaviation.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Duncan Aviation, Inc. is an aircraft maintenance, repair, and overhaul site. The site operations include airframe maintenance, aircraft on ground (AOG) emergency, avionics installation, interior and paint refurbishment, and other engineering services. Emissions on site are generated through stripping, sanding, painting, and detail work on the interior and exterior of aircraft. The on-site fuel storage tanks and natural gas-fired boilers also contribute to source emissions. Small booths, located in various buildings across the facility, are used for painting, finishes, cabinetry, upholstery, completions, and structural processes. Filters, air re-circulation, and High- Volume, Low-Pressure (HVLP) spray guns control emissions in the booths. Duncan Aviation, Inc. operates two (2) paint hangar bays and fifteen small operation booths consisting of painting, sanding, and gluing. Aircraft are parked in the hangar where a stripping solution de-paints the aircraft. Once the aircraft is de-painted, it is primed, painted, and allowed to air-dry in the hangar. The hangars are equipped with crossdraft and downdraft systems that control particulate emissions using three-stage particulate filters and VOCs through the use of a concentrator regenerative thermal oxidizer (RTO). 2 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN157060003-20, dated November 12, 2020 MACT (Part 63) -A : General Provisions, MACT (Part 63) -CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities, MACT (Part 63) -HHHHHH: National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources SOURCE EVALUATION: Name of Permittee: Permitted Location: Duncan Aviation, Inc. – Aircraft Maintenance, Repair, and Overhaul (MRO) Complex 262 South 3800 West 262 South 3800 West Provo, UT 84601 Provo, UT 84601 SIC Code: 4581: (Airports, Flying Fields, & Airport Terminal Services) 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] 3 I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Multiple breakdowns have occurred with the RTO since the previous inspection in 2023 and 2024. The source has followed the rules listed for breakdowns for reporting and remediation requirements within the rule. Source submitted their 2022 Emission Inventory within the appropriate timeframe and was reminded of the submission date for the 2023 Emission Inventory. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Duncan Aviation Aircraft Maintenance, Repair, and Overhaul Complex II.A.2 Two (2) Paint Bays Downdraft Paint Bay: PPH1 Control: RTO, 3-stage particulate filters, downdraft ventilation Total Volume: 250,000 CFM Crossdraft Paint Bays: PPH2 Control: RTO, 3-stage filters, crossdraft ventilation Total Volume: 150,000 CFM MACT Applicability: Subpart HHHHHH II.A.3 Small Booths: Six (6) Paint Booths Booths: (1) PPTPB1 (2) PACPB1 (3) PFNPB1 (4) PUPPB1 (5) PITPB1 (6) PVSPB1 Controls: 3- stage particulate filters (control efficiency: 99%) Full roof and 4 walls or within an enclosed room HVLP or electrostatic spray gun paint application MACT Applicability: Subpart HHHHHH II.A.4 Small Booths: Two (2) Paint Booths (1) PFNPB3 (2) PFNPB2 Controls: Single stage particulate filters (control efficiency: 99%) Full roof and 4 walls or within an enclosed room HVLP or electrostatic spray gun paint application MACT Applicability: None 4 II.A.5 Sanding Operations Tables (All tables and controls vent internally): (1) Finish Shop (2) Structures Shop (3) Interior Completions (4) Building 2 (5) Upholstery Additional controls: Downdraft table with filters and dust collectors MACT Applicability: Subpart HHHHHH II.A.6 Small Booths: Three (3) Glue Booths Booths: (1) PCBGB1 (2) PUPGB1 (3) PITGB1 Controls: Negative pressure air system Two stage particulate filter MACT Applicability: Subpart HHHHHH II.A.7 Concentrator Regenerative Thermal Oxidizer (RTO) Fuel: Natural Gas Includes: Emergency Bypass Maximum Rating: 10.5 MMBtu/hr II.A.8 Spray Guns Style: HVLP or electrostatic II.A.9 Three (3) Storage Tanks Fuel: Jet Fuel Maximum Capacity: 30,000 gallons each MACT and NSPS Applicability: None II.A.10 Storage Tanks Fuel: Diesel and Unleaded Gas Maximum Capacity: Equal to or less than 600 gallons each MACT Applicability: Subpart CCCCCC II.A.11 Miscellaneous Equipment Four (4) Boilers Fuel: Natural Gas Maximum Rating: 5 MMBtu/hr each MACT and NSPS Applicability: None One (1) Wastewater Evaporator Fuel: Natural Gas Maximum Rating: 5 MMBtu/hr MACT and NSPS Applicability: None Status: In Compliance. No unapproved equipment was observed at the time of inspection. Additional information gathered at the time of inspection: II.A.4 Small Paint Booth PFNPB3 is still not installed at this time. They are still planning on building the paint booth. 5 II.B Requirements and Limitations II.B.1 Site wide Limits and Requirements II.B.1.a Unless otherwise specified in this AO, visible emissions from on-site equipment shall not exceed 20% opacity. [R307-201] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-201] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached VEO form for additional information. II.B.1.b The owner/operator shall not allow plant wide emissions of VOCs and HAPs from the paint hangers; and paint, sanding, finishing, and glue booths to exceed: 32.02 tons per rolling 12-month period for VOCs 0.83 tons per rolling 12-month period for Hexane 1.37 tons per rolling 12-month period for Toluene 1.26 tons per rolling 12-month period for Xylene 0.70 tons per rolling 12-month period for Methyl Isobutyl Ketone 0.52 tons per rolling 12-month period for Glycol ether 0.09 tons per rolling 12-month period for Chromium 1720 pounds per rolling 12-month period for All other cumulative HAPs. [R307-401-8] II.B.1.b.1 Compliance with the VOC and HAP limitations shall be determined on a rolling 12-month total. Based on the last day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Monthly calculations shall be made no later than 20 days after the end of each calendar month. 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 HAPs 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/2000 lb x EF HAP = (% HAP by Weight)/100 x [Density (lb/gal)] x Gal Consumed x 1 ton/2000 lb x EF 6 F. EF is the applicable emission factor provided on the manufacture SDS sheet. G. The amount of VOC or HAP emitted monthly from all materials used. H. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC or HAP emissions. When the RTO is used for emission reductions, the owner/operator may use the following equations to determine emission totals after control. VOCs = [VOCs determined by mass-balance method] x [1 - 85%] HAP = [HAP determined by mass-balance method] x [1 - 85%]. [R307-401-8] Status: In Compliance. The rolling 12-month total from March 2023 to February 2024 for VOC and HAP emissions are as follows: 6.32 tons of VOCs emitted 0.26 tons of Hexane emitted 0.40 tons of Toluene emitted 0.06 tons of Xylene emitted 0.00 tons of Methyl Isobutyl Ketone emitted, 0.012 tons reclaimed 0.12 tons of Glycol ether emitted 0.00 tons of Chromium emitted 627 lbs. of other cumulative HAPs emitted. Calculations are made using the procedure listed in the AO. See the attachments section for additional information. II.B.1.c Except when in use, the owner/operator shall store VOC/HAPs-containing materials and VOC/HAPs-laden rags in covered containers. [R307-355-7, R307-401-8] Status: In Compliance. All VOC/HAP containing materials and laden rags were stored in covered containers when not in use at the time of inspection. II.B.2 Paint Requirements II.B.2.a The owner/operator shall route all primers and topcoats, defined below, through the RTO once use meets or exceeds 200 gallons per rolling 12-month period: A. Primers in excess of 4.5 pounds per gallon of VOCs B. Topcoats in excess of 3.5 pounds per gallon of VOCs Applications exempt from the 200-gallon limitation are defined in R307-355-3. [R307-355-3, R307-355-5, R307-355-9] II.B.2.a.1 Records for materials that do not pass through the RTO shall be maintained in a log indicating the volume and date of products used. [R307-355-6, R307-401-8] 7 II.B.2.a.2 Compliance shall be determined on a rolling 12-month total. Based on the last day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Monthly product inventories shall be made no later than 20 days after the end of each calendar month. [R307-401-8] Status: In Compliance. The rolling 12-month total from March 2023 to February 2024 for topcoats and primers are as follows: 170.4 gallons of topcoat and primers used Records of materials that do not pass through the RTO are maintained onsite and were viewed at the time of inspection. See the attachments section for additional information on primers and topcoats used. II.B.2.b The owner/operator shall ensure all applications of primer and topcoats are applied via a HVLP or Electrostatic Spray. Exceptions to this condition for hand applications are as follows: HVLP or Electrostatic may be substituted with hand application in instances where a spray gun is unable to properly reach limited access space; fillers within the coating adversely impacting the HVLP or Electrostatic applicator; stenciling, lettering, or identification markers applied; a hand-held spray applied; for touch-ups and repairs; or the application of specialty coatings. [R307-355-6] Status: In Compliance. Topcoats and primers are applied using the methods referenced within this AO condition and are following associated regulations accordingly. II.B.3 RTO Requirements II.B.3.a The owner/operator shall ensure the RTO system operates at all times, when the Downdraft Paint Bay and Crossdraft Paint Bays are in use for priming, top coat, and stripping applications except when the cumulative airflow is below 25,000 CFM. [R307-401-8] Status: In Compliance. The RTO system parameters are tracked and monitored from the RTO control room and the main office. The requirements of this condition are met continuously and monitored as required. II.B.3.b The owner/operator shall operate the RTO for no less than three hours during curing applications. These hours shall begin at the start of the curing operation. [R307-401-8] Status: In Compliance. The RTO is programmed to meet this requirement. II.B.3.c The owner/operator shall operate the RTO at a temperature above 1,350 degrees Fahrenheit while the concentrator wheels are in operation. [R307-401-8] II.B.3.c.1 The owner/operator shall maintain a log of RTO inspections indicating, at minimum, the date and temperature of the RTO during operations. [R307-401-8] II.B.3.c.2 The owner/operator shall maintain records of the RTO operating parameters, verified by the manufacturer, indicating the following programed operations: A. Curing application times: The RTO shall be programmed to run for no less than three hours for curing applications. 8 B. Bypass temperature: The bypass shall only open when temperature reaches 1600 degrees Fahrenheit or higher. [R307-401-8] Status: In Compliance. The RTO is programmed to not operate below 1,350 degrees Fahrenheit. At the time of inspection, the operating temperature of the RTO was 1,426 degrees Fahrenheit. Logs are maintained for each RTO inspection. II.B.3.d The owner/operator shall verify the capture and control efficiency of the RTO using methods of verification compliant with R307-355-9 within no less than 3 months from the issuance of this AO. [R307-355-9] Status: In Compliance. This was verified as part of the 2021 inspection conducted. See DAQC-1258-21 for additional information. II.B.3.e The owner/operator shall maintain and operate the RTO according to manufacturer's specifications for the life of the RTO. Records of inspection schedules, monitoring, recordkeeping, and key parameters, as identified by the manufacturer, shall be kept for a minimum of two years. [R307-355-9] Status: In Compliance. Records of maintenance of the RTO are stored onsite and have been stored for at least 2 years. II.B.3.f The owner/operator shall not allow visible emissions from the RTO to exceed 10% opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached VEO form for additional information. II.B.4 Spray Gun Requirements II.B.4.a The owner/operator shall ensure all operators of spray guns are certified for the proper spray application of surface coatings and the proper setup and maintenance of spray equipment. [40 CFR 63 Subpart HHHHHH, R307-401-8] Status: In Compliance. All requirements for spray gun operators according to Subpart HHHHHH are being followed. See the attachments section for additional information. II.B.4.b The owner/operator shall ensure spray gun cleaning is done in a manner that prevents atomized mists or spraying of cleaning solvents beyond the cleaning solvent container. [40 CFR 63 Subpart HHHHHH, R307-401-8] Status: In Compliance. Spray gun cleaning is done according to the rules set in Subpart HHHHHH. II.B.5 Small Booths Requirements II.B.5.a The owner/operator shall ensure each small booth is equipped with a set of paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting small booths shall pass through this control system before being vented to the atmosphere (outside building/operation). [R307-401-8] Status: In Compliance. The small paint booth is equipped with particle arrestors and are filtered before entering the atmosphere. 9 II.B.5.b The owner/operator shall not allow visible emissions from small booth operations to exceed 10% opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attachments section for additional information. II.B.6 Tank Requirements II.B.6.a The owner/operator shall operate and maintain all tanks in accordance with the manufacturer's instructions. [R307-401-8] Status: In Compliance. All fuel storage tanks are maintained according to the manufacturer's specifications. 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 with subparts CCCCCC and HHHHHH. MACT (Part 63) -CCCCCC : National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Status: In Compliance. The source dispensed less than 10,000 gallons of gasoline at this facility within the last 12-month period. The source is operating under the best practices outlined in 61.1116. MACT (Part 63) -HHHHHH : National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources Status: In Compliance. Compliance is satisfied by compliance with AO Condition II.B.4, as well as submitting their initial notification as mentioned in the 2020 inspection. Source also submitted additional information confirming staff onsite are certified under subpart HHHHHH. 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. Federal subpart CCCCCC applies to this rule. See Section III for additional information. 10 Solvent Cleaning [R307-304] Status: Not Applicable. Currently exempt. Solvent cleaning at this site is governed under R307-355-8. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached VEO form for additional information. PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306] Status: In Compliance. All abrasive blasting occurs in a closed space that vents internally to a baghouse. Compliance with this rule is also satisfied by compliance with II.B.1.a of the AO. Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: In Compliance. Compliance with this rule is satisfied by properly managing VOC-containing products to minimize evaporation. Degreasing and Solvent Cleaning Operations [R307-335] Status: In Compliance. The source still maintains a Safety-Kleen brand parts washer. At the time of inspection, the parts washer was observed to be closed when not in use. Miscellaneous Metal Parts and Products Coatings [R307-350] Status: Not Applicable. Currently exempt. All coatings activities that occur at the site are governed by R307-355. Control of Emissions from Aerospace Manufacture and Rework Facilities [R307-355] Status: In Compliance. All applicable conditions of R307-355 are referenced throughout this AO. See all R307-355 referenced conditions in this AO for additional information about compliance with this state rule. EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided from Duncan Aviation, Inc. – Aircraft Maintenance, Repair, and Overhaul (MRO) Complex. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN157060003-20, dated November 12, 2020, is provided. The 2022 Emission Inventory is listed below and can be found in the attachments section. PTE are supplied for supplemental purposes only. 11 Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 7126.90 Carbon Monoxide 4.73 2.79 Nitrogen Oxides 4.38 3.33 Particulate Matter - PM10 0.66 0.25 Particulate Matter - PM2.5 0.66 0.25 Sulfur Dioxide 0.09 0.019 Volatile Organic Compounds 32.02 6.04 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Ethyl Benzene (CAS #100414) 520 38 Ethylene Glycol (CAS #107211) 900 76 Generic HAPs (CAS #GHAPS) 480 Glycol Ethers (CAS #EDF109) 1040 48 Hexane (CAS #110543) 1660 606 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 1400 46 Toluene (CAS #108883) 2740 760 Xylenes (Isomers and Mixture) (CAS #1330207) 2520 190 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN157060003-20, dated November 12, 2020: In Compliance with the conditions listed within the AO. Records were made available upon request. Facility appears to be well maintained. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Check on the installation status of the paint booth PFNPB3. It has not yet been installed. NSR RECOMMENDATIONS: Add the parts washer and the abrasive blasting units to the AO during the next modification. AO needs to move section II.B.5 and II.B.6 to their proper location in the AO. They are currently out of order. ATTACHMENTS: Applicable Supporting Documentation Included 2022 Emissions Inventory Report Duncan Aviation, Inc. Aircraft Maintenance, Repair, and Overhaul (MRO) Complex (15706) 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)0.2531 <.00001 0.2531 PM10-FIL PM10 Filterable 0.03164 <.00001 0.03164 PM25-PRI PM2.5 Primary (Filt + Cond)0.2531 <.00001 0.2531 PM25-FIL PM2.5 Filterable 0.03164 <.00001 0.03164 SO2 Sulfur Dioxide 0.01998 <.00001 0.01998 NOX Nitrogen Oxides 3.3302 <.00001 3.3302 VOC Volatile Organic Compounds 6.0041 <.00001 6.0041 CO Carbon Monoxide 2.79737 <.00001 2.79737 NH3 Ammonia 0.10657 <.00001 0.10657 HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions (tons)* 71432 Benzene (HAP)VOC 0.001 98828 Cumene (HAP)VOC 0.001 111422 Diethanolamine (HAP)VOC 0.007 100414 Ethyl Benzene (HAP)VOC 0.019 107211 Ethylene Glycol (HAP)VOC 0.038 171 Glycol Ethers (HAP)VOC 0.024 110543 Hexane (HAP)VOC 0.303 67561 Methanol (HAP)VOC 0.021 108101 Methyl Isobutyl Ketone (HAP)VOC 0.023 80626 Methyl Methacrylate (HAP)VOC 0.005 100425 Styrene (HAP)VOC 0.104 108883 Toluene (HAP)VOC 0.38 1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.095 *Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated. 1/2 2/2 4/5/24, 10:59 AM State of Utah Mail - Documents from Inspection on 3/14 https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r2896094765976459221&simpl=msg-a:r186824974993239…1/2 Jordan Garahana <jordangarahana@utah.gov> Documents from Inspection on 3/14 3 messages Jordan Garahana <jordangarahana@utah.gov>Fri, Mar 15, 2024 at 9:56 AM To: Bruce.jensen@duncanaviation.com Hello Bruce, Thank you once again for your time and help yesterday during my inspection. As a reminder here are the documents I am looking for to help complete my inspection: II.B.1.b- VOC and HAP emissions from March 2023 to February 2024 II.B.2.a- primer and topcoat usage over 200 gallons that are in excess of 4.5 pounds per gallon VOC for primers and 3.5 pounds per gallon VOCs for topcoats from March 2023 to February 2024. MACT Part 63 HHHHHH- painters certifications for all painters onsite II.A.4- Status of small paint booth labeled PFNPB3 if it has been installed and is in operation since it was not in operation/installed during the previous inspection Please let me know if you have any questions about the records or information I am requesting. Please have this to me by March 21. Thanks, Jordan Garahana -- Jordan Garahana Environmental Scientist | Minor Source Compliance M: (385) 271-2871 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Bruce Jensen <bruce.jensen@duncanaviation.com>Mon, Mar 18, 2024 at 8:55 AM To: Jordan Garahana <jordangarahana@utah.gov> Cc: Nate Hansen <nathan.hansen@duncanaviation.com> Good morning, Jordan. I hope this email finds you doing well and having a good Monday. Here's the requested documentaon pertaining to the March 14th, 2024 inspecon. 4/5/24, 10:59 AM State of Utah Mail - Documents from Inspection on 3/14 https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r2896094765976459221&simpl=msg-a:r186824974993239…2/2 II.A.4- I found out that the small paint booth PFNPB3 doesn't exist yet. It is a downdra paint booth that we plan to build in the future in our Cabinet/Finish Shop as we get busier. Please let me know if there's anything else we can do for you. Have a great week. Thank you, Bruce Bruce Jensen  Environmental Supervisor DIRECT: +1 801-342-5595 | CELL: +1 435-994-1167 www.DuncanAviation.aero From: Jordan Garahana <jordangarahana@utah.gov> Sent: Friday, March 15, 2024 9:56 AM To: Bruce Jensen <bruce.jensen@duncanaviation.com> Subject: Documents from Inspecon on 3/14 [Quoted text hidden] 3 attachments PRT519_000580.pdf 2476K PRT519_000578.pdf 334K PRT519_000577.pdf 127K Jordan Garahana <jordangarahana@utah.gov>Tue, Mar 19, 2024 at 11:15 AM To: Bruce Jensen <bruce.jensen@duncanaviation.com> Hey Bruce, Thank you for sending me the documents I requested. I will let you know if there is anything else I need for my inspection. Thanks, Jordan Garahana [Quoted text hidden]