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Home My WebLink AboutDAQ-2024-0108721 DAQC-997-24 Site ID 13315 (B2) MEMORANDUM TO: FILE – WHITEWATER WHIRLPOOL BATHS & SYSTEMS THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Joe Rockwell, Environmental Scientist DATE: October 1, 2024 SUBJECT: Title V Annual Compliance Certification Receipt/Review, FRS ID # UT0000004904900257 REPORT RECEIVED/ DUE DATE: July 12, 2024/July 12, 2024 TITLE V PERMIT #: 4900257001 DATE OF LAST PERMIT REVISION: July 12, 2017 CERTIFICATION PERIOD: July 1, 2023 – June 30, 2024 FACILITY REPORTED COMPLIANCE STATUS: Continuous REPORT EVALUATION: • Was report submitted on time? Yes • Did report identify status of compliance for each condition? Yes • Was compliance status marked as continuous/intermittent for each condition? Yes • Did report identify method used to determine compliance with each condition? Yes • Was report signed and properly certified by responsible official? Yes • Were exceedances/excursions reported? No • Were deviations reported? No CURRENT RECOMMENDATION: The report appears to meet the requirements of Title V operating permit condition I.L. Whitewater is still operating under the Title V operating permit dated July 12, 2017. A Shield Letter has been issued. ATTACHMENTS: Annual Compliance Certification Report. WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.B Permitted Activities TVOP included all permit requirements. Continuous 1.C.1 The permittee must comply with all conditions of the operating permit. Reviewed permit conditions for compliance. Continuous REVIEWEDInitials: Date: Oct 1, 2024Compliance Status: OKFile #: 13315 (B2)Comment: Hard Copy of report received on July 12, 2024. WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. Operations were able to proceed normally throughout the certification period. Continuous 1.C.3 Did the permittee furnish information requested by the Executive Secretary? Provided documents upon request by UDAQ Compliance inspector Continuous 1.D Permit Expiration and Renewal A complete Title V Renewal Application was submitted to UDAQ on January 11, 2022 prior to the January 12, 2022 deadline. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.E Application Shield Application Shield letter was received from UDAQ on February 11, 2022 Continuous 1.G.1 Did the permittee pay the annual emission fee? Payment was made upon receipt from UDAQ, October 3, 2023. Continuous 1.G.2 Was fee paid on time? Payment was paid promptly Continuous 1.J Inspection and Entry UDAQ compliance inspection was performed on March 8, 2024 Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.K Were all application forms, reports and certifications submitted pursuant to the permit properly certified by a responsible official? A responsible official signed and certified all necessary forms, reports and certifications as required. Continuous 1.L.1 Did the permittee submit this compliance certification complete & on time? Compliance Certification was received by UDAQ July 7, 2023. Continuous 1.L.2 Did the permittee also send all compliance certifications to EPA? Compliance Certifications were submitted to EPA via mail. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.M Permit Shield All applicable requirements are included in the WWBS TVOP Continuous 1.N Emergency Provisions No “emergency” situations were encountered during the annual compliance certification reporting period Continuous 1.S.1.a Did the permittee properly retain all records required by the permit? Records have been retained since the onset of permit and will continue to be held for a period of at least 5 years. Continuous 1.S.1.b Did the permittee include all applicable information in records of monitoring required by the permit? All required information annotated on logs. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.S.2.a Did the permittee submit monitoring reports every six months, or more frequently if specified in Section II, and were all instances of deviation from permit requirements clearly identified in the monitoring reports? Semi-Annual Compliance Certification submitted as required by 40 CFR 63 Subpart WWWW. TVOP semi-annual monitoring report was submitted on time. Continuous 1.S.2.b All reports submitted pursuant to Provision 1.S.2.a shall be certified by a responsible official in accordance with Provision 1.K of this permit. All reports were certified by a responsible official. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations 1.S.2.c Did the permittee promptly notify the Executive Secretary of all deviations from permit requirements? No deviations from permit conditions occurred throughout the certification period. Continuous 1.U An emission inventory shall be submitted in accordance the procedures of R307-150, Emission Inventories. 2023 Air emission inventory was submitted to UDAQ through the SLEIS system on April 13, 2024 Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.A Emission Unit(s) Permitted to Discharge Air Contaminants. (R307-415-4(3)(a) and R307- 415-4(4)) Review of permit conditions and existing air sources indicate that they are identified appropriately in the TVOP Continuous II.B.1.a.1 Emission of Styrene calculated on a rolling 12-month total shall not exceed 29.52 tpy VOC emissions are calculated by the 20th of each month using throughput information provided each month. Styrene emissions are calculated with the most recent 12 months of data Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.1.a.2 Records showing name of Styrene emitting material, density, percent by weight of Styrene in each material. Safety Data sheets provided by manufacturer document this criteria Continuous II.B.1.b.1 Emission of Methyl Methacrylate (MMA) calculated on a rolling 12- month total shall not exceed 0.48 tpy VOC emissions are calculated by the 20th of each month using throughput information provided each month. MMA emissions are calculated with the most recent 12 months of data Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.1.b.2 Records showing name of Styrene emitting material, density, percent by weight of Styrene in each material. Safety Data sheets provided by manufacturer document this criteria Continuous II.B.1.c Permittee shall operate and maintain permitted plant equipment, at all times, in a manner consistent with good air pollution control practices to minimize air emissions. A site specific work practice program specifying management practices, requirements and housekeeping procedures to minimize air emissions is followed by all personnel engaged in activities with a potential to impact air pollution controls or emissions. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.1.d Shall comply with the applicable requirements for recycling and emission reduction for class I and class II refrigerants pursuant to 40 CFR 82 Subpart F All refrigerant containing equipment is maintained and serviced by qualified contractors. Continuous II.B.1.e The permittee shall comply with all applicable requirements in 40 CFR 63, Subpart WWWW Facility has an established Work Practice Program (WPP) in accordance with 40 CFR 63 Subpart WWWW, that establishes applicable requirements to be followed at all times while operating. Permittee is in compliance with this WPP at all times. Records are maintained demonstrating compliance with this WPP Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.1.f Comply with all applicable regulations under 40 CFR 63 subpart WWWW. A site specific work practice program specifying management practices, requirements and housekeeping procedures to minimize air emissions is followed by all personnel engaged in activities with a potential to impact air pollution controls or emissions. Continuous II.B.1.f.2 Comply with all applicable regulations under 40 CFR 63 subpart WWWW. Safety Data sheets provided by manufacturer document material content and critical data for calculating emissions Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.1.g All Volatile Organic Compounds (VOC)and Hazardous Air Pollutants (HAP) containing materials are stored in covered containers and VOC/HAP laden rags are stored in covered containers when not in use. A site specific work practice program specifying management practices, requirements and housekeeping procedures to minimize air emissions is followed by all personnel engaged in activities with a potential to impact air pollution controls or emissions. The work practices include requirements to keep containers and VOC/HAP containing materials covered at all times when not in use. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.1.h Submit notification to the director when installation of new equipment in plant #2 has been completed and operational. If equipment is not installed by September 23, 2018 A notification was submitted to UDAQ notifying them of the installation of a small mixer. Addressed during compliance inspection on March 8, 2024. This condition will be removed from permit when TVOP renewal is completed. Continuous II.B.2.a Visible emissions shall be no greater than 10% for Spray Booth B-1 and B-2. In lieu of monitoring opacity, weekly filter inspections shall be conducted and recorded demonstrating filters do not have holes and are installed properly in the support rack. A log with annotated inspections, date, and personnel performing inspections are conducted and recorded on log. Continuous WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 FTerm Description of Permit Provision Method Used to Determine Compliance Status Was Compliance During the Permit Period Continuous, Intermittent, Undetermined Other Facts Relevant to Compliance Status Including Any and All Deviations II.B.2.b Spray booths shall be equipped with a set of paint arrestor filters to control particulate emissions. All air exiting booth will pass through this control before venting to atmosphere. Personnel regularly inspect and maintain filter system to insure proper operation and maintenance of the filters. Records of inspections are documented and retained. Continuous II.B.3.a Boilers are limited to a 10 % opacity. In lieu of emission observations, records of fuel usage shall be maintained to demonstrate that only natural gas is being burned. WWBS no longer has boilers installed in their facility. These will be removed in the TVOP renewal. Continuous Certification In accordance with Operating Permit provision I.K and UAC R307-415-5d, and based on information and belief formed after reasonable inquiry, I certify that the statements and information in this document are true, accurate, and complete. WHITEWATER WHIRLPOOL BATHS AND SYSTEMS ANNUAL TVOP COMPLIANCE CERTIFICATION TVOP # 4900257001 In accordance with Operating Permit provision I.L and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitted for the dates of: July 1, 2023 – June 30, 2024 To: Executive Secretary, Utah Air Quality Board Date: July 11, 2024 ________________________________________________________7/11/2024________________ Signature of a Responsible Official for the Source Date Brian Urry VP Finance_____________________________________________________________ Print or type the name and title of Responsible Official REVIEWEDInitials: Date: Oct 1, 2024Compliance Status: OKFile #: 13315 (B2)Comment: Hard Copy of report received on July 12, 2024.