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HomeMy WebLinkAboutDAQ-2024-0109861 DAQC-CI124030001-24 Site ID 12403 (B1) MEMORANDUM TO: FILE – VR CPC HOLDING, INC. – dba Park City Mountain Resort THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Daniel Riddle, Environmental Scientist DATE: September 23, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Summit County INSPECTION DATE: May 9, 2024, and June 26, 2024 SOURCE LOCATION: 1310 Lowell Avenue Park City, UT 84060 DIRECTIONS: Go to this address instead of the address on the AO. Canyons Team Building 3843 Lower Village Road Park City, UT 84098 SOURCE CONTACTS: Jessica Gibbons, Regional Compliance Specialist 906-235-3152, Jessica.Gibbons@vailresorts.com OPERATING STATUS: Minimal operations on May 9, 2024, summer operations on June 26, 2024. PROCESS DESCRIPTION: VR CPC Holding, Inc. (Vail Resorts) operates the Park City Mountain Resort in Park City. The source has two sections: Park City and Canyons. Permitted sources of air pollution include: Boilers/ heaters for winter heat and snow melting, diesel and gasoline powered emergency lift engines, degreasing operations, glove box abrasive blasting units, and two fuel dispensing stations. One to two diesel or gasoline reciprocating internal combustion engines (RICE) are installed at each ski lift for emergency use when supplied electrical power is interrupted or electric lift motors fail. The RICE connection to the lift drive train can be direct shaft drive, belt drive, or hydraulic. Shops are used for snow cat and lift maintenance. The King Shop on the Park City side has an abrasive blasting glove box, small solvent degreasing station, 100,000 Btu INOV8 Multi-Oil-Fired Heating Appliance, and a fuel (gasoline and diesel) dispensing operation. The Canyons shop has an abrasive blasting glove box, steam degreasing stations, and a fuel dispensing operation. 2 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN124030012-23, dated January 18, 2023 NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: VR CPC Holding, Inc. dba Park City Mountain Resort 4000 Canyons Resort Drive 1310 Lowell Avenue Park City, UT 84098 Park City, UT 84060 SIC Code: 7999: (Amusement & Recreation Services, NEC) 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: Out of Compliance. Equipment modifications have been made without approval from the DAQ. See Section II for more details. The equipment appeared to be properly operated and maintained according to manufacturer recommendations. Records are kept as required and were made available after the inspection. No breakdowns have been reported since the previous inspection. This source is not required to submit an emissions report at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 VR CPC Holding – dba Park City Mountain Resort Ski Resort II.A.2 Main Emergency Generator Engines* Quantity: Twenty-three (23) Fuel: Diesel Cumulative site-wide rating: 11,992 hp Maximum rating: 1,046 hp Minimum rating: 150 hp *Source refers to these as Auxiliary Engines II.A.3 Secondary Emergency Generator Engines** Quantity: Twenty-seven (27) Fuel: Twenty-two (22) Diesel Fuel: Five (5) Gasoline (all manufactured prior to 2009) Cumulative site-wide rating: 5,032 hp Maximum rating: 335 hp Minimum rating: 28 hp **Source refers to these as Evacuation & Tertiary Engines II.A.4 Various Boilers & Heaters Fuel: Natural Gas or Propane Size: Less than 5 MMBtu/hr (each) II.A.5 One (1) Used Oil Burner Fuel: Used Oil Size: 0.24 MMBtu/hr II.A.6 Fuel Dispensing Stations Locations: Two (2) Various diesel and gasoline tanks at each location II.A.7 Abrasive Blasting Operations Two (2) confined spaces equipped with filters 4 II.A.8 Degreasing Operations Location: King Shop Status: Out of Compliance. During review of records received from the source, it was observed that there are 54 generators on site – 4 more than the amount permitted in Conditions II.A.2 and II.A.3. A Compliance Advisory (DAQC-820-24) was issued on August 15, 2024, for the unpermitted generators. A Warning (DAQC-944-24) was issued on September 23, 2024. No further action is recommended at this time. For Condition II.A.4 - the source has 3 boilers rated at 3 MMBtu/hr. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. All natural gas-fired equipment - 10% opacity B. All other points - 20% opacity [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. See attached VEO Form for additional information. II.B.2 Generator Engine Requirements II.B.2.a Emergency generator engines shall be used for electricity-producing operation only during the periods when electric power from the public utilities is interrupted or during electric motor failures or failures of equipment attached to the motor output shafts for drive connections. The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage 5 [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. None of the generators were used for more than 100 hours for non-emergency purposes in the rolling 12-month period from April 2023 – March 2024. See the attached table for hours of usage from all 54 generators. The Flat Iron EPU generator logged 123.6 hours in December 2023 due to the switch being mistakenly left in the on position. See the attached explanation from the source. II.B.2.b The owner/operator shall comply with all applicable provisions of 40 CFR 60, NSPS Subpart A (General Provisions), Section 60.1 to Section 60.18, and Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines), Section 60.4200 to Section 60.4219 for stationary diesel fueled engines on site. To be in compliance, the owner/operator shall operate the engines in accordance with the most current version of 40 CFR 60 applicable to this source. [40 CFR 60 Subpart A, 40 CFR 60 Subpart IIII] Status: In Compliance. See Section III below for more information. II.B.2.c The owner/operator shall comply with all applicable provisions of 40 CFR 63, MACT Standards Subpart A (General Provisions), Section 63.1 to Section 63.16, and Subpart ZZZZ (NESHAPs for Stationary Reciprocating Internal Combustion Engines), Section 63.6580 to Section 63.6675, for stationary diesel engines on site. To be in compliance, the owner/operator shall operate the engines in accordance with the most current version of 40 CFR 63 applicable to this source. [40 CFR 63 Subpart A, 40 CFR 63 Subpart ZZZZ] Status: In Compliance. See Section III below for more information. II.B.2.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the diesel-fired emergency generator engines. [R307-401-8] Status: In Compliance. Only ULSD is utilized at this source. II.B.2.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.2.e.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. Only ULSD is utilized at this source. See the attached invoice from Rebel Oil Co., Inc. II.B.3 Boiler Requirements 6 II.B.3.a The owner/operator shall use natural gas or propane as a fuel source in all boilers and hot water heaters on site. [R307-401-8] Status: In Compliance. Only natural gas or propane are used as fuel sources at this site. II.B.4 Fuel Dispensing and Storage Requirements II.B.4.a The owner/operator shall cover all open diesel and gasoline containers and fill pipes with gasketed seals when not in use. [40 CFR 63 Subpart CCCCCC, R307-401-8] Status: In Compliance. All open diesel and gasoline containers and fill pipes with gasket seals are covered when not in use. II.B.5 Degreasing Operations Requirements II.B.5.a The VOC- and HAPs-containing materials shall be stored in covered containers (except when in use). VOC- and/or HAPs-laden rags shall also be stored in covered containers. [R307-401-8] Status: In Compliance. No VOC containing materials were observed spilled, discarded, stored in open containers, or handled in any other way that would result in greater evaporation. II.B.6 Used Oil Fuel Requirements II.B.6.a The owner/operator shall not burn any used oil unless the used oil is on-specification used oil as defined in UAC R315-15. [R307-401-8] Status: In Compliance. See the attached used oil sampling from February 11, 2023. 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) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. Compliance with this subpart is satisfied by installing a certified engine, maintaining and operating the engines in accordance with the manufacturer's instructions, installation of a non-resettable hour meter, the use of ultra-low sulfur diesel, and maintaining records of use. All information provided at the time of inspection indicate all engines subject to IIII are being properly maintained and operated in accordance with this subpart. 7 MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. This subpart applies to all emergency generators. Each generator is used annually for less than 100 hours for maintenance and other non-emergency purposes. Maintenance occurs per manufacturer recommendations, and the non-resettable hour meter is checked weekly. Only low-sulfur diesel is used in all of the generators. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Only ULSD is utilized at this source. See the established invoice from Rebel Oil Co., Inc. Stationary Sources [R307-210] Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal Requirements NSPS (Part 60) Subparts Dc, IIII, and JJJJ. See Section III above for more information. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal Requirement MACT (Part 63) Subpart ZZZZ. See Section III above for more information. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. See attached VEO Form for additional information. PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306] Status: Not Observed. No abrasive blasting was observed at the time of inspection. The source says that the blasting cabinet is rarely used. No visible emissions have been observed when blasting has taken place. Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: In Compliance. No VOC containing materials were observed spilled, discarded, stored in open containers, or handled in any other way that would result in greater evaporation. 8 Degreasing and Solvent Cleaning Operations [R307-335] Status: In Compliance. The source operates one parts washer in the King Shop. The lid was closed at the time of inspection. Excess solvent and waste drains into a covered container. The waste tank and containers had no visible leaks and appeared to be in good operating condition. The product in use is Water Works Storm Ultra Degreaser from Keteca USA, Inc. See attached for SDS. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from VR CPC Holding, Inc. – dba Park City Mountain Resort on the Approval Order (AO) DAQE-AN124030012-23, dated January 18, 2023. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 9340.00 Carbon Monoxide 12.49 Nitrogen Oxides 27.26 Particulate Matter - PM10 2.27 Particulate Matter - PM2.5 2.27 Sulfur Oxides 1.37 Volatile Organic Compounds 3.83 Hazardous Air Pollutant PTE lbs/yr Acetaldehyde (CAS #75070) 2 Acrolein (CAS #107028) 0 Benzene (Including Benzene From Gasoline) (CAS #71432) 8 Formaldehyde (CAS #50000) 17 Generic HAPs (CAS #GHAPS) 15 Hexane (CAS #110543) 249 Naphthalene (CAS #91203) 1 Toluene (CAS #108883) 4 Xylenes (Isomers And Mixture) (CAS #1330207) 2 PREVIOUS ENFORCEMENT ACTIONS: No enforcement action within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN124030012-23, dated January 18, 2023, the overall status is: Out of Compliance. A Compliance Advisory (DAQC-820-24) was issued on August 15, 2024, for unpermitted generators. A Warning (DAQC-944-24) was issued on September 23, 2024. No further action is recommended at this time. Only inspect in the winter or summer when staff are present and able to assist. Do not inspect during the in-between off season. 9 HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at typical frequency for this type of source. NSR RECOMMENDATIONS: NOI was submitted on August 29, 2024, for additional generators. ATTACHMENTS: VEO form, email correspondence, generator usage, maintenance logs explaining generator usage, ULSD invoices, SDS, used oil test results Daniel Riddle <driddle@utah.gov> 12403 - Follow up to air quality inspection 9 messages Daniel Riddle <driddle@utah.gov>Thu, May 9, 2024 at 3:53 PM To: tbradley2@vailresorts.com, jessica.gibbons@vailresorts.com Tom and Jessica I observed your facility today at Park City Mountain Resorts. However, I may have come too far into the off season, because I could not locate anyone to take me around. I was there to do an unannounced air quality inspection. For these inspections, we also require certain records to be submitted. Here are the records that I require to complete my inspection report. From AO DAQE-AN1240300012-23: Condition II.B.2.a - emergency generator engine usage for maintenance purposes for all generators (April 2023 - March 2024) Condition II.B.2.d - record of invoice for ULSD purchase Please provide these records by May 16, 2024. If this email should have gone to another recipient, please forward it to them. Thanks and let me know if you have any questions. Best, Daniel -- Daniel Riddle (he/him) Environmental Scientist | Minor Source Compliance M: (385) 222-1357 airquality.utah.gov Jessica Gibbons <Jessica.Gibbons@vailresorts.com>Thu, May 16, 2024 at 3:20 PM To: Daniel Riddle <driddle@utah.gov> Hi Daniel, Please see the attached response to the May 9th records request. Let me know if you need any additional information or if anything needs clarification. Below is some updated contact information for you. Address: Canyons Team Building 3843 Lower Village Rd Park City, UT 84098 Phone: 303-404-8000 Thank you, Jessica Gibbons (she/her) 9/4/24, 10:23 AM State of Utah Mail - 12403 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6792406356254825128&simpl=msg-a:r-72375666451709…1/5 Regional Compliance Specialist Park City Mountain Resort Cell: 906-235-3152 Environmental Incident: 303-404-8000 Visit the Environmental Compliance Ops Site for Helpful Resources 3E SDS Library From: Daniel Riddle <driddle@utah.gov> Sent: Thursday, May 9, 2024 3:53 PM To: tbradley2@vailresorts.com; Jessica Gibbons <Jessica.Gibbons@vailresorts.com> Subject: 12403 - Follow up to air quality inspection ATTENTION: This eMail originated from outside of Vail Resorts and may or may not be legitimate. Although we do our best to screen phishing emails, please use extra caution before opening any attachments or clicking on any links unless you are absolutely sure the source of the email is trusted. If in doubt about the legitimacy of this email, please use the Report Phish button for validation. [Quoted text hidden] The information contained in this message is confidential and intended only for the use of the individual or entity named above, and may be privileged. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please reply to the sender immediately, stating that you have received the message in error, then please delete this e-mail. Thank you. Records Request Response PCMR May 2024.pdf 1738K Daniel Riddle <driddle@utah.gov>Thu, May 23, 2024 at 9:42 AM To: Jessica Gibbons <Jessica.Gibbons@vailresorts.com> Thanks for sending this over - I'll let you know if I have any questions. [Quoted text hidden] Daniel Riddle <driddle@utah.gov>Thu, Jun 27, 2024 at 10:34 AM To: Jessica Gibbons <Jessica.Gibbons@vailresorts.com> Jessica, I visited the site again yesterday to look at some of your equipment and to perform a Visible Emissions Observation. I have a few questions in regards to your records: According to Conditions II.A.2 and II.A.3 of AO DAQE-AN124030012-23, you have 50 generators permitted for this site. However, your records list a total of 54 generators. Were these 4 additional generators added since your most recent AO update in January 2023? This might be a compliance issue since Condition I.3 states "Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved" In 2020, you were using "BZ7483 PARTS WSH SLVNT CTRS R19935 5 GAL" in your parts washer as well as "Calumet 142 Flash <1%" in solvent cleaning (attached below). Are these products still in use, or are new products being used for any parts washing or solvent cleaning operations? Could you send me the names and SDS or TDS for any new products? The Flat Iron EPU that was mistakenly left running - does it use gasoline or diesel? Does the Motherlode SPU use gas or diesel? Condition II.B.3.a - do the boilers and water heaters ever use propane or just natural gas? Condition II.B.6.a - can you show via an oil analysis that any used oil burned does not exceed the ppm limits for the constituents in Table 1 as required by UAC R315? I'm attaching that full rule below - see Table 1 as well as R315-15. The analysis from the previous inspection is also attached below. UAC R307-306 (Attached) - how often does confined blasting occur? Has anyone ever recorded a Visible Emissions Observation when blasting is taking place? Thanks and let me know if you have any questions, Daniel [Quoted text hidden] 4 attachments 2023 ao.pdf 1672K 9/4/24, 10:23 AM State of Utah Mail - 12403 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6792406356254825128&simpl=msg-a:r-72375666451709…2/5 R315-15.pdf 289K VRCPC old records.pdf 3290K R307-306.pdf 73K Daniel Riddle <driddle@utah.gov>Tue, Jul 16, 2024 at 11:15 AM To: Jessica Gibbons <Jessica.Gibbons@vailresorts.com> Hi Jessica - I wanted to check in to see if you have made any progress on these items? Thanks, Daniel [Quoted text hidden] Jessica Gibbons <Jessica.Gibbons@vailresorts.com>Wed, Jul 17, 2024 at 12:29 PM To: Daniel Riddle <driddle@utah.gov> 9/4/24, 10:23 AM State of Utah Mail - 12403 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6792406356254825128&simpl=msg-a:r-72375666451709…3/5 Hi Daniel, Apologies for the delay, please see the responses below. According to Conditions II.A.2 and II.A.3 of AO DAQE-AN124030012-23, you have 50 generators permitted for this site. However, your records list a total of 54 generators. Were these 4 additional generators added since your most recent AO update in January 2023? This might be a compliance issue since Condition I.3 states "Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved" I am waiting on one more response about the generators on site, though at this time it appears that NOIs were not submitted for the additional generators. I am working on getting engine information for all of our generators so we can make sure everything is correct and then we will submit an NOI to have them added to the permit. In 2020, you were using "BZ7483 PARTS WSH SLVNT CTRS R19935 5 GAL" in your parts washer as well as "Calumet 142 Flash <1%" in solvent cleaning (attached below). Are these products still in use, or are new products being used for any parts washing or solvent cleaning operations? Could you send me the names and SDS or TDS for any new products? A new product is being used – Water Works Storm Ultra Degreaser. Please see attached SDS. The Flat Iron EPU that was mistakenly left running - does it use gasoline or diesel? Does the Motherlode SPU use gas or diesel? Flat Iron EPU runs on gasoline and Motherlode SPU runs on diesel. And for clarity, neither of the engines were left running, just the switch was left to “on” which means the hour meter continued to count even though the engine was not running. Condition II.B.3.a - do the boilers and water heaters ever use propane or just natural gas? There are three boilers that are 2MMbtu that only use natural gas. There are other boilers at the resort that use propane but they are under 1MMbtu. Condition II.B.6.a - can you show via an oil analysis that any used oil burned does not exceed the ppm limits for the constituents in Table 1 as required by UAC R315? I'm attaching that full rule below - see Table 1 as well as R315-15. The analysis from the previous inspection is also attached below. See attached UAC R307-306 (Attached) - how often does confined blasting occur? Has anyone ever recorded a Visible Emissions Observation when blasting is taking place? Confined blasting does not occur often. To my knowledge no one has recorded Visible Emissions Observations while blasting is taking place. I will let you know as soon as I get information about the generators confirmed. Please let us know if you need any additional information. [Quoted text hidden] 2 attachments Storm-Ultra-SDS.pdf 225K 20230209_Used Oil Burner Test Results.pdf 1340K Daniel Riddle <driddle@utah.gov>Wed, Jul 31, 2024 at 10:17 AM To: Jessica Gibbons <Jessica.Gibbons@vailresorts.com> Jessica, Please keep me updated on NOI submission progress. I will have to issue a Compliance Advisory for the unpermitted equipment. Once you receive that, you have ten business days to respond to it. The DAQ can then determine if we go forward with a warning letter, a no-further action letter, or a penalty. [Quoted text hidden] Jessica Gibbons <Jessica.Gibbons@vailresorts.com>Wed, Jul 31, 2024 at 11:36 AM To: Daniel Riddle <driddle@utah.gov> Daniel, Thank you for the update, I am just waiting on a few pieces of information for the NOI. I will be trying to get it all set by next week. 9/4/24, 10:23 AM State of Utah Mail - 12403 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6792406356254825128&simpl=msg-a:r-72375666451709…4/5 Will the Compliance Advisory be sent by email or paper mail? I just want to make sure all of our contact information is correct as we have been running into issues with that in the past. The email should be mine or envirocompliance@vailresorts.com. The address should be Jessica Gibbons PO Box 39 Park City, UT 84060 Thank you, Jessica Gibbons (she/her) Regional Compliance Specialist Park City Mountain Resort Cell: 906-235-3152 Environmental Compliance Hotline: 303-404-8000 [Quoted text hidden] Daniel Riddle <driddle@utah.gov>Wed, Jul 31, 2024 at 1:26 PM To: Jessica Gibbons <Jessica.Gibbons@vailresorts.com> It is sent through certified mail. I will make sure to use this address. Thank you [Quoted text hidden] 9/4/24, 10:23 AM State of Utah Mail - 12403 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r6792406356254825128&simpl=msg-a:r-72375666451709…5/5 Records Request Response Prepared to Respond to the May 9th, 2024 Park City Mountain Resort Records Request Prepared By: VR CPC Holding, Incorporated Doing Business As Park City Mountain Resort 390 Interlocken Crescent Broomfield, CO 80021 303-404-8000 TABLE OF CONTENTS ATTACHMENTS •Attachment A: Monthly Hours of Usage •Attachment B: Flat Iron Maintenance Log December 2023 •Attachment C: Motherlode Maintenance Log April 2023 •Attachment D: Diesel Fuel Specification RECORDS REQUEST RESPONSE Purpose This report has been prepared by VR CPC Holding, Incorporated - Doing Business As - Park City Mountain Resort (“Park City”) to respond to the Utah Department of Environmental Quality Division of Air Quality May 9, 2024, records request. Request Records for Condition II.B.2.a - emergency generator engine usage for maintenance purposes for all generators (April 2023 - March 2024) Response See Attachment A for Monthly Hours of Usage based on the hour meter readings. •Flat Iron EPU – The hours listed for December 2023 are 123.6, exceeding the 100 hour 12-month rolling operating limit. Upon further investigation this exceedance was not due to the engine operating, but due to the engine power switch being left in the on position. This causes the meter to keep running even though the engine is not running. This happened with a few other engines that month, just not for so long. This engine is an EVAC only source (not a standby) which means that in case of a power outage, or a prime mover failure, we will only run it for half a lap (about 10 minutes) to clear the line and shut the lift down until we can run it back on electric. In review of the engine operating logs, the engine run time in the month of December 2023 was 1.17 hours. See Attachment B for the engine logs for Flat Iron from December 2023. Engine was not used from March 23, 2023 to December 25, 2023. •Motherlode SPU – The hour meter for Motherlode SPU was replaced in November of 2023. The engine did not run after April 9, 2023 through October 2023. The meter did not capture hours for April 2023 but the maintenance log captured 0.6 run time hours. See Attachment C for the April 2023 maintenance logs. Request Condition II.B.2.d - record of invoice for ULSD purchase Response See Attachment D for the most recent invoices for ULSD for both the Willow Maintenance Shop and King Maintenance Shop locations. Attachment A Monthly Hours Apr-23 May-23 Jun-23 Jul-23 Aug-23 Sep-23 Oct-23 Nov-23 Dec-23 Jan-24 Feb-24 Mar-24 Equipment Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours Hour Meter Reading Monthly Hours First Time SPU1 575.9 2.9 575.9 0 575.9 0 575.9 0 575.9 0 575.9 0 575.9 0 579 3.1 583.4 4.4 587.3 3.9 587.9 0.6 588.6 0.7 First Time EPU2 482.6 4.6 482.6 0 482.6 0 482.6 0 482.6 0 482.6 0 482.6 0 487 4.4 492.7 5.7 496.9 4.2 497.8 0.9 500 2.2 Three Kings SPU 332.8 5.2 332.8 0 332.8 0 332.8 0 332.8 0 332.8 0 332.8 0 332.8 0 337.9 5.1 342.7 4.8 344.3 1.6 345.6 1.3 Three Kings EPU2 139.6 5.6 139.6 0 139.6 0 139.6 0 139.6 0 139.6 0 139.6 0 139.6 0 144.9 5.3 150.5 5.6 151.3 0.8 152.4 1.1 Payday SPU1 124.4 3.4 124.4 0 125.8 1.4 128.3 2.5 129.7 1.4 129.7 0 131.4 1.7 133 1.6 135 2 142 7 147 5 154 7 Payday EPU2 478 0.6 478 0 480.7 2.7 483 2.3 484 1 485.4 1.4 487.6 2.2 487.9 0.3 491 3.1 496 5 497 1 499 2 Town SPU1 734.97 0.7 734.97 0 736.23 1.26 736.92 0.69 738.17 1.25 738.17 0 738.17 0 738.17 0 740 1.83 743.45 3.45 744 0.55 745 1 Jupiter SPU1 636 1 636 0 636 0 636 0 636 0 636 0 636 0 636 0 636 0 638.2 2.2 638.91 0.71 639.76 0.85 Thaynes SPU1 615 1.26 615 0 615 0 615 0 615 0 615 0 615 0 615 0 616.16 1.16 617.74 1.58 618.37 0.63 619.47 1.1 Silverlode SPU1 109.5 5.2 109.5 0 109.5 0 109.5 0 109.5 0 109.5 0 109.5 0 109.5 0 112.9 3.4 115.4 2.5 117.1 1.7 118.9 1.8 Silverlode EPU2 558.2 4.2 558.2 0 558.2 0 558.2 0 558.2 0 558.2 0 558.2 0 558.2 0 559.8 1.6 563 3.2 564.6 1.6 566.3 1.7 Motherlode SPU1 5437 0.5 5437 0 5437 0 5437 0 5437 0 5437 0 5437 0 1 1 1 0 3 2 4.3 1.3 5.8 1.5 Motherlode EPU2 315.9 0.1 315.9 0 315.9 0 315.9 0 315.9 0 315.9 0 315.9 0 315.9 0 316.3 0.4 316.6 0.33 316.83 0.23 317 0.17 Bonanza SPU1 94.7 1.9 94.7 0 94.7 0 94.7 0 94.7 0 94.7 0 94.7 0 94.7 0 97 2.3 99.6 2.6 100.8 1.2 102.4 1.6 Bonanza EPU2 578.2 2.7 578.2 0 578.2 0 578.2 0 578.2 0 578.2 0 578.2 0 578.2 0 581 2.8 583.8 2.8 585.1 1.3 586.6 1.5 Pioneer EPU1 716 0.2 716 0 716 0 716 0 716 0 716 0 716 0 716 0 717.73 1.73 718.74 1.01 719.4 0.66 720.36 0.96 McConkeys SPU1 840 12 840 0 840 0 840 0 840 0 840 0 840 0 840 0 844 4 846.6 2.6 859.5 12.9 871 11.5 McConkeys EPU2 473.4 3.4 473.4 0 473.4 0 473.4 0 473.4 0 473.4 0 473.4 0 473.4 0 481 7.6 486.6 5.6 488 1.4 489 1 Eagle EPU1 618.35 0 618.35 0 618.35 0 618.35 0 618.35 0 618.35 0 618.35 0 618.35 0 618.35 0 620.47 2.12 621 0.53 622.74 1.74 Silver Star SPU1 238.2 0 238.2 0 238.2 0 238.2 0 238.2 0 238.2 0 238.2 0 238.2 0 238.2 0 239.3 1.1 240 0.7 241 1 Crescent SPU 496 4 496 0 496 0 521 25 523 2 523 0 526 3 526 0 529 3 532 3 533 1 534 1 Crescent EPU 264.1 6.1 264.1 0 264.5 0.4 265 0.5 269.9 4.9 269.9 0 272.3 2.4 272.3 0 275.1 2.8 278 2.9 279.4 1.4 280.4 1 King Con SPU1 147 0.5 147 0 147 0 147 0 147 0 147 0 147 0 147 0 147 0 149.8 2.8 153 3.2 153.9 0.9 King Con EPU2 118.2 0.9 118.2 0 118.2 0 118.2 0 118.2 0 118.2 0 118.2 0 118.2 0 118.2 0 121.4 3.2 121.9 0.5 122.4 0.5 Dreamcatcher EPU 211 3 211 0 211 0 211 0 211 0 211 0 211 0 211 0 212 1 216 4 217 1 218 1 Frostwood EPU 9288.6 1.4 9288.6 0 9288.6 0 9288.6 0 9288.6 0 9288.6 0 9288.6 0 9288.6 0 9293.6 5 9295 1.4 9296 1 9297 1 Saddleback EPU 471.6 2.9 471.6 0 471.6 0 471.6 0 471.6 0 471.6 0 471.6 0 475.9 4.3 481 5.1 484 3 484 0 486 2 Super Condor EPU 274.9 1.9 274.9 0 274.9 0 274.9 0 274.9 0 274.9 0 274.9 0 274.9 0 274.9 0 276.3 1.4 277 0.7 279 2 OBX EPU 92.5 2.5 92.5 0 92.5 0 92.5 0 92.5 0 92.5 0 92.5 0 92.5 0 134.7 42.2 138.8 4.1 139 0.2 140 1 OBX SPU 152.33 0.18 152.33 0 152.33 0 152.33 0 152.33 0 152.33 0 152.33 0 152.33 0 157.24 4.91 161.03 3.79 162 0.97 163 1 Sunpeak EPU 288 1 288 0 288 0 288 0 288 0 288 0 288 0 288 0 290 2 293 3 294 1 295 1 Shortcut EPU 2601.5 0 2601.5 0 2601.5 0 2601.5 0 2601.5 0 2601.5 0 2601.5 0 2601.5 0 2603.9 2.4 2603.9 0 2603.9 0 2603.9 0 Timberline EPU 185.7 2.8 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 185.7 0 Timberline SPU 228.7 2.9 228.7 0 228.7 0 228.7 0 228.7 0 228.7 0 228.7 0 228.7 0 233.2 4.5 236 2.8 238 2 239 1 9990 EPU 430.7 2.7 430.7 0 430.7 0 430.7 0 430.7 0 430.7 0 430.7 0 430.7 0 437 6.3 441 4 442 1 443 1 Dreamscape EPU 339.7 9.7 339.7 0 339.7 0 339.7 0 339.7 0 339.7 0 339.7 0 339.7 0 341 1.3 346 5 351 5 354 3 Daybreak EPU 81.8 1.5 81.8 0 81.8 0 81.8 0 81.8 0 81.8 0 81.8 0 81.8 0 95 13.2 98 3 99 1 100 1 Sunrise EPU 2167.1 0.3 2167.1 0 2167.1 0 2167.1 0 2167.1 0 2167.1 0 2167.1 0 2167.1 0 2168.5 1.4 2171 2.5 2207 36 2233 26 Red Pine SPU 601 3 601 0 601 0 606 5 608 2 609 1 609 0 609 0 616 7 619 3 620 1 621 1 Red Pine EPU 80 3 80 0 81 1 83 2 85 2 86 1 86 0 93 7 93.1 0.1 95.4 2.3 95.4 0 96 0.6 Tombstone SPU 463 2 463 0 463 0 463 0 463 0 463 0 463 0 463 0 470 7 474 4 474 0 478 4 Tombstone EPU 112.5 1.2 112.5 0 112.5 0 112.5 0 112.5 0 112.5 0 112.5 0 112.5 0 115 2.5 117 2 117 0 118 1 Peak 5 EPU 3776.3 5.3 3776.3 0 3776.3 0 3776.3 0 3776.3 0 3776.3 0 3776.3 0 3776.3 0 3834 57.7 3839 5 3840 1 3840 0 High Meadow EPU 102.96 1.72 102.96 0 102.96 0 102.96 0 102.96 0 102.96 0 102.96 0 104.2 1.24 107.6 3.4 110.56 2.96 111 0.44 113 2 High Meadow SPU 88.8 2.3 88.8 0 88.8 0 88.8 0 88.8 0 88.8 0 88.8 0 89.8 1 94 4.2 96.8 2.8 97 0.2 98 1 Cabriolet EPU 123.6 0 123.6 0 124.5 0.9 129.5 5 130.9 1.4 133 2.1 133 0 134.5 1.5 137 2.5 140.7 3.7 141 0.3 143 2 Cabriolet SPU 142.8 0 142.8 0 143.7 0.9 149.7 6 150.2 0.5 152 1.8 152 0 153.1 1.1 157 3.9 159.9 2.9 160 0.1 162 2 Iron Mountain SPU 139 0 139 0 139 0 139 0 139 0 139 0 139 0 139 0 143.9 4.9 147.4 3.5 148 0.6 149 1 Iron Mountain EPU 116.9 3.2 116.9 0 116.9 0 116.9 0 116.9 0 116.9 0 116.9 0 116.9 0 120.1 3.2 125.6 5.5 126 0.4 127 1 Quicksilver SPU 190.6 1.6 190.6 0 190.6 0 190.6 0 190.6 0 190.6 0 190.6 0 190.6 0 198.21 7.61 203 4.79 204 1 205 1 Quicksilver EPU 163.2 0 163.2 0 163.2 0 163.2 0 163.2 0 163.2 0 163.2 0 163.2 0 193.9 30.7 198.4 4.5 199 0.6 200 1 Flat Iron EPU 281.4 0 281.4 0 281.4 0 281.4 0 281.4 0 281.4 0 281.4 0 281.4 0 405 123.6 412 7 415 3 422 7 Over And Out EPU 99.6 3.1 99.6 0 99.6 0 99.6 0 99.6 0 99.6 0 99.6 0 99.6 0 103.8 4.2 107.7 3.9 108 0.3 108 0 Over And Out SPU 118.8 3 118.8 0 118.8 0 118.8 0 118.8 0 118.8 0 118.8 0 118.8 0 127 8.2 133 6 133 0 134 1 Attachment B Flat Iron Maintenance Logs December 2023 CB-19 FLAT IRON - - - DATE (MM/DD/VY) LIFT MAINTENANCE EPU 000 PARK CITY ITEM Sat EPU Hours Run Time Emission Color: Blk, Gry, Cir If Black , Corrective Action Reason for Run Oil Pressure @ RPM's Voltage Fuel Level Oil Level Check Secondary Containment, Shut Off Valve, and Venting Torque Converter Fluid ALL CHECKS COMPLETED BY Radio# and Printed Name Signature of Person Completing Log Date Sat Sun Lead/Supervisor/Manager Name Lead/Supervisor/Manager Signature Date SEE REVERSE FOR MONTHLY/OTHER rl\ CB-19 FLAT IRON LIFT MAINTENANCE EPU If Black, Corrective Action Oil Level CheckSecondary Containment, Shut Off Valve, and Venting Sat Sun Lead/Supervisor/Manager Name Lead/Supervisor/Manager Signature SEE REVERSE FOR MONTHLY/OTHER RK Attachment C Motherlode SPU Maintenance Log April 2023 Attachment D USLD Invoices ■ ''ROC EST.1954 Invoice REBEL OIL CO., INC 10650 W. Charleston Blvd. Suite 100 Las Vegas, Nevada 89135 (702) 382-5866 Page: If paying by mail, please remit to: REBEL OIL COMPANY, INC- HC P.0. BOX 103342 Pasadena, CA. 91189-3342 Due Date: 4/28/2024 Ship Number: 1136596 Invoice Dale: 4/18/2024 Invoice Number: 1136596-IN Warehouse: W20 Sold To: Customer NO Ship To: BOL#784960 VAIL RESORTS M.NGMNT CANYONS 0006176 390 INTERLOCKEN CRESCENT BROOMFIELD, CO 80021 VAIL CANYONS SHOP 3636 WILLOW DRAW PARK CITY, UT 84098 Customer P.O. Truck Number Terms 2058279 022 10 DAYS PRODUCT QTY Unit DESCRIPTION Price Amount 025 3,396.00 ULSD OFF ROAD #2 DIESEL 2.48660 8,444.49 5108055 4.00 /DELIVER· UNIT 3,396.00 Sign ---------Print Name-------- Date/Time ---------- Due Date: 4/28/2024 3% processing fee will be applied if paid by credit card "Errors in price, extension, and addition are subject to correction" HEffective immediately any returned item from your bank will incur a $100 fee" EMERGENCY CONTACT: 1-800-234-9300 A Finance Charge of 1.5% a month will be applied to all past due accounts Net Invoice: Freight: Sales Tax: Invoice Total: 9,047.70 0.00 635.36 9,683.06 FEDERAL LUST TAX 0.00100 3.40 FEDERAL OIL SPILL TAX 0.00214 7.27 FEDERAL SUPERFUND RECOVERY FEE 0.00405 13.75 UT ENVIRONMENTAL ASSURANCE FEE 0.00650 22.07 2.50029 8,490.98 BG DIESEL FUEL COND. + GAL JUG 79.75000 319.00 Delivery Charges - by Unit 0.07000 237.72 ROC 1 • EST.1954 Invoice REBEL OIL CO., INC 10650 W. Charleston Blvd. Suite 100 Las Vegas, Nevada 89135 (702) 382-5866 Page: If paying by mail, please remit to: REBEL OIL COMPANY, INC - HC P.O. BOX 103342 Pasadena, CA. 91189-3342 Due Date: 4/27/2024 Ship Number: 1136442 Invoice Date: 4/17/2024 Invoice Number: 1136442-IN Warehouse: W20 BOL#784864 Sold To: VAIL RESORTS MNGMNT PCMR 390 INTERLOCKEN CRESCENT BROOMFIELD, CO 80021 Customer NO 0006166 Ship To: VAIL RESORTS MNGMNT PCMR 1310 LOWELL AVE PARK CITY, UT 84060 Customer P.O. 2058280 Truck Number 022 Terms 10 DAYS PRODUCT QTY Unit DESCRIPTION Price Amount 025 4,620.00 ULSD OFF ROAD #2 DIESEL 2.49760 11,538.91 FEDERAL LUST TAX 0.00100 4.62 FEDERAL OIL SPILL TAX 0.00214 9.89 FEDERAL SUPERFUND RECOVERY FEE 0.00405 18.71 UT ENVIRONMENTAL ASSURANCE FEE 0.00650 30.03 2.51129 11,602.16 /DELIVER - UNIT 4,620.00 Delivery Charges - by Unit 0.07000 323.40 Sign--------- Print Name-------- Date/Time --------- - Due Date: 4/27/2024 3% processing fee will be applied if paid by credit card "Errors in price, extension, and addition are subject to correction" "Effective immediately any returned item from your bank will incur a $100 fee" EMERGENCY CONTACT: 1-800-234-9300 A Finance Charge of 1.5% a month will be applied to all past due accounts Net Invoice: Freight: Sales Tax: Invoice Total: 11,925.56 0.00 836.57 12,762.13 ANALYTICAL REPORT February 22, 2023 E.T. Technologies, Inc. Sample Delivery Group:L1584771 Samples Received:02/11/2023 Project Number: Description: Site:PARK CITY FACILITY Report To:Greg Neville 6030 W. California Avenue Magna, UT 84044 Entire Report Reviewed By: February 22, 2023 [Preliminary Report] John Hawkins Project Manager Results relate only to the items tested or calibrated and are reported as rounded values. This test report shall not be reproduced, except in full, without written approval of the laboratory. Where applicable, sampling conducted by Pace Analytical National is performed per guidance provided in laboratory standard operating procedures ENV-SOP-MTJL-0067 and ENV-SOP-MTJL-0068. Where sampling conducted by the customer, results relate to the accuracy of the information provided, and as the samples are received. Pace Analytical National 12065 Lebanon Rd Mount Juliet, TN 37122 615-758-5858 800-767-5859 www.pacenational.com 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 1 of 12 February 23, 2023 John Hawkins Project Manager ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 1 of 12 TABLE OF CONTENTS Cp: Cover Page 1 Tc: Table of Contents 2 Ss: Sample Summary 3 Cn: Case Narrative 4 Sr: Sample Results 5 USED OIL #1 L1584771-01 5 Qc: Quality Control Summary 6 Wet Chemistry by Method 9023 6 Wet Chemistry by Method D93/1010A 7 Metals (ICP) by Method 6010B 8 Polychlorinated Biphenyls (GC) by Method 8082M 9 Gl: Glossary of Terms 10 Al: Accreditations & Locations 11 Sc: Sample Chain of Custody 12 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 2 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 2 of 12 SAMPLE SUMMARY Collected by Collected date/time Received date/time USED OIL #1 L1584771-01 Solid Michelle Bethune 02/09/23 00:00 02/11/23 08:00 Method Batch Dilution Preparation Analysis Analyst Location date/time date/time Wet Chemistry by Method 9023 WG2004157 1 02/13/23 11:56 02/15/23 10:52 LOH Mt. Juliet, TN Wet Chemistry by Method D93/1010A WG2007625 1 02/16/23 21:32 02/16/23 21:32 CRB Mt. Juliet, TN Metals (ICP) by Method 6010B WG2005174 1 02/13/23 23:40 02/14/23 11:35 ZSA Mt. Juliet, TN Polychlorinated Biphenyls (GC) by Method 8082M WG2008794 1 02/22/23 07:49 02/22/23 15:00 CCW Mt. Juliet, TN 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 3 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 3 of 12 CASE NARRATIVE All sample aliquots were received at the correct temperature, in the proper containers, with the appropriate preservatives, and within method specified holding times, unless qualified or notated within the report. Where applicable, all MDL (LOD) and RDL (LOQ) values reported for environmental samples have been corrected for the dilution factor used in the analysis. All Method and Batch Quality Control are within established criteria except where addressed in this case narrative, a non-conformance form or properly qualified within the sample results. By my digital signature below, I affirm to the best of my knowledge, all problems/anomalies observed by the laboratory as having the potential to affect the quality of the data have been identified by the laboratory, and no information or data have been knowingly withheld that would affect the quality of the data. [Preliminary Report] John Hawkins Project Manager 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 4 of 12 John Hawkins Project Manager ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 4 of 12 SAMPLE RESULTS - 01 L1584771 USED OIL #1 Collected date/time: 02/09/23 00:00 Wet Chemistry by Method 9023 Result Qualifier RDL Dilution Analysis Batch Analyte mg/kg mg/kg date / time Extracted TOX ND 100 1 02/15/2023 10:52 WG2004157 Wet Chemistry by Method D93/1010A Result Qualifier Dilution Analysis Batch Analyte Deg. F date / time Ignitability DNI at 170 1 02/16/2023 21:32 WG2007625 Metals (ICP) by Method 6010B Result Qualifier RDL Dilution Analysis Batch Analyte mg/kg mg/kg date / time Arsenic ND 2.00 1 02/14/2023 11:35 WG2005174 Cadmium ND 0.500 1 02/14/2023 11:35 WG2005174 Chromium ND 1.00 1 02/14/2023 11:35 WG2005174 Lead 0.648 0.500 1 02/14/2023 11:35 WG2005174 Polychlorinated Biphenyls (GC) by Method 8082M Result Qualifier RDL Dilution Analysis Batch Analyte mg/kg mg/kg date / time PCB 1016 ND 0.0500 1 02/22/2023 15:00 WG2008794 PCB 1221 ND 0.0500 1 02/22/2023 15:00 WG2008794 PCB 1232 ND 0.0500 1 02/22/2023 15:00 WG2008794 PCB 1242 ND 0.0500 1 02/22/2023 15:00 WG2008794 PCB 1248 ND 0.0500 1 02/22/2023 15:00 WG2008794 PCB 1254 ND 0.0500 1 02/22/2023 15:00 WG2008794 PCB 1260 ND 0.0500 1 02/22/2023 15:00 WG2008794 (S) Decachlorobiphenyl 98.0 60.0-140 02/22/2023 15:00 WG2008794 (S) Tetrachloro-m-xylene 127 60.0-140 02/22/2023 15:00 WG2008794 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 5 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 5 of 12 QUALITY CONTROL SUMMARYWG2004157 Wet Chemistry by Method 9023 L1584771-01 Method Blank (MB) (MB) R3891101-1 02/15/23 10:02 MB Result MB Qualifier MB MDL MB RDL Analyte mg/kg mg/kg mg/kg Extracted TOX U 30.0 100 Laboratory Control Sample (LCS) (LCS) R3891101-2 02/15/23 10:06 Spike Amount LCS Result LCS Rec.Rec. Limits LCS Qualifier Analyte mg/kg mg/kg %% Extracted TOX 250 264 106 85.0-115 L1584580-03 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD) (OS) L1584580-03 02/15/23 10:23 • (MS) R3891101-3 02/15/23 10:25 • (MSD) R3891101-4 02/15/23 10:34 Spike Amount Original Result MS Result MSD Result MS Rec.MSD Rec.Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits Analyte mg/kg mg/kg mg/kg mg/kg %%%%% Extracted TOX 1000 ND 1110 1110 111 111 1 80.0-120 0.114 20 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 6 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 6 of 12 QUALITY CONTROL SUMMARYWG2007625 Wet Chemistry by Method D93/1010A L1584771-01 L1584801-01 Original Sample (OS) • Duplicate (DUP) (OS) L1584801-01 02/16/23 21:32 • (DUP) R3891787-3 02/16/23 21:32 Original Result DUP Result Dilution DUP RPD DUP Qualifier DUP RPD Limits Analyte Deg. F Deg. F %% Ignitability DNI at 170 DNI at 170 1 0.000 10 Laboratory Control Sample (LCS) • Laboratory Control Sample Duplicate (LCSD) (LCS) R3891787-1 02/16/23 21:32 • (LCSD) R3891787-2 02/16/23 21:32 Spike Amount LCS Result LCSD Result LCS Rec.LCSD Rec.Rec. Limits LCS Qualifier LCSD Qualifier RPD RPD Limits Analyte Deg. F Deg. F Deg. F %%%%% Ignitability 126 125 127 99.1 101 95.6-104 1.59 10 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 7 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 7 of 12 QUALITY CONTROL SUMMARYWG2005174 Metals (ICP) by Method 6010B L1584771-01 Method Blank (MB) (MB) R3890777-1 02/14/23 10:52 MB Result MB Qualifier MB MDL MB RDL Analyte mg/kg mg/kg mg/kg Arsenic U 0.518 2.00 Cadmium U 0.0471 0.500 Chromium U 0.133 1.00 Lead U 0.208 0.500 Laboratory Control Sample (LCS) (LCS) R3890777-2 02/14/23 10:54 Spike Amount LCS Result LCS Rec.Rec. Limits LCS Qualifier Analyte mg/kg mg/kg %% Arsenic 100 96.1 96.1 80.0-120 Cadmium 100 97.3 97.3 80.0-120 Chromium 100 99.4 99.4 80.0-120 Lead 100 98.0 98.0 80.0-120 L1584480-78 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD) (OS) L1584480-78 02/14/23 10:57 • (MS) R3890777-5 02/14/23 11:05 • (MSD) R3890777-6 02/14/23 11:07 Spike Amount Original Result MS Result MSD Result MS Rec.MSD Rec.Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits Analyte mg/kg mg/kg mg/kg mg/kg %%%%% Arsenic 100 ND 90.8 88.0 90.8 88.0 1 75.0-125 3.13 20 Cadmium 100 ND 92.4 92.4 92.1 92.0 1 75.0-125 0.0899 20 Chromium 100 18.8 112 119 93.1 100 1 75.0-125 6.04 20 Lead 100 44.3 136 137 91.9 92.7 1 75.0-125 0.605 20 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 8 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 8 of 12 QUALITY CONTROL SUMMARYWG2008794 Polychlorinated Biphenyls (GC) by Method 8082M L1584771-01 Method Blank (MB) (MB) R3893806-1 02/22/23 14:42 MB Result MB Qualifier MB MDL MB RDL Analyte mg/kg mg/kg mg/kg PCB 1016 U 0.0167 0.0500 PCB 1221 U 0.0167 0.0500 PCB 1232 U 0.0167 0.0500 PCB 1242 U 0.0167 0.0500 PCB 1248 U 0.0167 0.0500 PCB 1254 U 0.0167 0.0500 PCB 1260 U 0.0167 0.0500 (S) Decachlorobiphenyl 114 60.0-140 (S) Tetrachloro-m-xylene 103 60.0-140 Laboratory Control Sample (LCS) (LCS) R3893806-2 02/22/23 14:51 Spike Amount LCS Result LCS Rec.Rec. Limits LCS Qualifier Analyte mg/kg mg/kg %% PCB 1016 1.00 1.03 103 60.0-140 PCB 1260 1.00 1.15 115 60.0-140 (S) Decachlorobiphenyl 109 60.0-140 (S) Tetrachloro-m-xylene 100 60.0-140 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 9 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 9 of 12 GLOSSARY OF TERMS Guide to Reading and Understanding Your Laboratory Report The information below is designed to better explain the various terms used in your report of analytical results from the Laboratory. This is not intended as a comprehensive explanation, and if you have additional questions please contact your project representative. Results Disclaimer - Information that may be provided by the customer, and contained within this report, include Permit Limits, Project Name, Sample ID, Sample Matrix, Sample Preservation, Field Blanks, Field Spikes, Field Duplicates, On-Site Data, Sampling Collection Dates/Times, and Sampling Location. Results relate to the accuracy of this information provided, and as the samples are received. Abbreviations and Definitions MDL Method Detection Limit. ND Not detected at the Reporting Limit (or MDL where applicable). RDL Reported Detection Limit. Rec.Recovery. RPD Relative Percent Difference. SDG Sample Delivery Group. (S)Surrogate (Surrogate Standard) - Analytes added to every blank, sample, Laboratory Control Sample/Duplicate and Matrix Spike/Duplicate; used to evaluate analytical efficiency by measuring recovery. Surrogates are not expected to be detected in all environmental media. U Not detected at the Reporting Limit (or MDL where applicable). Analyte The name of the particular compound or analysis performed. Some Analyses and Methods will have multiple analytes reported. Dilution If the sample matrix contains an interfering material, the sample preparation volume or weight values differ from the standard, or if concentrations of analytes in the sample are higher than the highest limit of concentration that the laboratory can accurately report, the sample may be diluted for analysis. If a value different than 1 is used in this field, the result reported has already been corrected for this factor. Limits These are the target % recovery ranges or % difference value that the laboratory has historically determined as normal for the method and analyte being reported. Successful QC Sample analysis will target all analytes recovered or duplicated within these ranges. Original Sample The non-spiked sample in the prep batch used to determine the Relative Percent Difference (RPD) from a quality control sample. The Original Sample may not be included within the reported SDG. Qualifier This column provides a letter and/or number designation that corresponds to additional information concerning the result reported. If a Qualifier is present, a definition per Qualifier is provided within the Glossary and Definitions page and potentially a discussion of possible implications of the Qualifier in the Case Narrative if applicable. Result The actual analytical final result (corrected for any sample specific characteristics) reported for your sample. If there was no measurable result returned for a specific analyte, the result in this column may state “ND” (Not Detected) or “BDL” (Below Detectable Levels). The information in the results column should always be accompanied by either an MDL (Method Detection Limit) or RDL (Reporting Detection Limit) that defines the lowest value that the laboratory could detect or report for this analyte. Uncertainty (Radiochemistry)Confidence level of 2 sigma. Case Narrative (Cn) A brief discussion about the included sample results, including a discussion of any non-conformances to protocol observed either at sample receipt by the laboratory from the field or during the analytical process. If present, there will be a section in the Case Narrative to discuss the meaning of any data qualifiers used in the report. Quality Control Summary (Qc) This section of the report includes the results of the laboratory quality control analyses required by procedure or analytical methods to assist in evaluating the validity of the results reported for your samples. These analyses are not being performed on your samples typically, but on laboratory generated material. Sample Chain of Custody (Sc) This is the document created in the field when your samples were initially collected. This is used to verify the time and date of collection, the person collecting the samples, and the analyses that the laboratory is requested to perform. This chain of custody also documents all persons (excluding commercial shippers) that have had control or possession of the samples from the time of collection until delivery to the laboratory for analysis. Sample Results (Sr) This section of your report will provide the results of all testing performed on your samples. These results are provided by sample ID and are separated by the analyses performed on each sample. The header line of each analysis section for each sample will provide the name and method number for the analysis reported. Sample Summary (Ss)This section of the Analytical Report defines the specific analyses performed for each sample ID, including the dates and times of preparation and/or analysis. Qualifier Description The remainder of this page intentionally left blank, there are no qualifiers applied to this SDG. 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 10 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 10 of 12 Pace Analytical National 12065 Lebanon Rd Mount Juliet, TN 37122 Alabama 40660 Nebraska NE-OS-15-05 Alaska 17-026 Nevada TN000032021-1 Arizona AZ0612 New Hampshire 2975 Arkansas 88-0469 New Jersey–NELAP TN002 California 2932 New Mexico ¹TN00003 Colorado TN00003 New York 11742 Connecticut PH-0197 North Carolina Env375 Florida E87487 North Carolina ¹DW21704 Georgia NELAP North Carolina ³41 Georgia ¹923 North Dakota R-140 Idaho TN00003 Ohio–VAP CL0069 Illinois 200008 Oklahoma 9915 Indiana C-TN-01 Oregon TN200002 Iowa 364 Pennsylvania 68-02979 Kansas E-10277 Rhode Island LAO00356 Kentucky ¹ ⁶KY90010 South Carolina 84004002 Kentucky ²16 South Dakota n/a Louisiana AI30792 Tennessee ¹ ⁴2006 Louisiana LA018 Texas T104704245-20-18 Maine TN00003 Texas ⁵LAB0152 Maryland 324 Utah TN000032021-11 Massachusetts M-TN003 Vermont VT2006 Michigan 9958 Virginia 110033 Minnesota 047-999-395 Washington C847 Mississippi TN00003 West Virginia 233 Missouri 340 Wisconsin 998093910 Montana CERT0086 Wyoming A2LA A2LA – ISO 17025 1461.01 AIHA-LAP,LLC EMLAP 100789 A2LA – ISO 17025 ⁵1461.02 DOD 1461.01 Canada 1461.01 USDA P330-15-00234 EPA–Crypto TN00003 ACCREDITATIONS & LOCATIONS ¹ Drinking Water ² Underground Storage Tanks ³ Aquatic Toxicity ⁴ Chemical/Microbiological ⁵ Mold ⁶ Wastewater n/a Accreditation not applicable * Not all certifications held by the laboratory are applicable to the results reported in the attached report. * Accreditation is only applicable to the test methods specified on each scope of accreditation held by Pace Analytical. 1 Cp 2Tc 3Ss 4Cn 5Sr 6Qc 7Gl 8Al 9Sc ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/22/23 21:38 11 of 12 ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE: E.T. Technologies, Inc.L1584771 02/23/23 07:46 11 of 12 Safety Data Sheet GHS Safety Data Sheet Keteca USA, Inc SDS Number: KP-5 F1 Page 1 of 5 Revision Date: 7/11/2023 Water Works™ Storm Ultra Product Identifier: SDS Number: Product Code: Revision Date: Version: Product Description: Product Use: Instructions: Supplier Details: Phone: Water Works™ Storm Ultra KP-5 F1 WWSU 7/11/2023 01 Concentrated industrial aqueous cleaner / degreaser. Industrial aqueous cleaner / degreaser. Recommended dilution is 3 - 5% Use according to manufacturer’s directions. Keteca USA, Inc encourages and expects the user to read and understand the entire (M)SDS, as there is important information throughout the document. We expect the user to follow the precautions identified in this document unless the user's use conditions would necessitate other appropriate methods or actions. Keteca USA, Inc 4280 W. Opportunity Way Phoenix, AZ 85086 877-418-1306 Emergency Telephone Number: CHEMTREC Within USA and Canada: 1-800-424-9300 Outside USA and Canada: +1 703-527-3887 (collect calls accepted) Classification of the Substance or Mixture GHS Classification in Accordance with 29 CFR 1910 (OSHA HCS): Health, Eye Irritation, 2 B GHS Label Elements, Including Precautionary Statements GHS Signal Word: WARNING GHS Hazard Pictograms: no GHS pictograms indicated for this product GHS Hazard Statements: May cause eye irritation GHS Precautionary Statements: IF SWALLOWED: Low toxicity if swallowed. Small amounts swallowed incidentally as a result of normal handling operations are not likely to cause injury; however, swallowing larger amounts may cause injury. IF ON SKIN: Wash with soap and water. IF INHALED: Prolonged exposure is not expected to cause adverse effects. IF IN EYES: Rinse continuously with water for several minutes. Remove contact lenses if present and easy to do. Continue rinsing. Hazards not Otherwise Classified (HNOC) or not Covered by GHS Inhalation: Prolonged exposure is not expected to cause adverse effects. Skin Contact: Non-irritating. Eye Contact: May cause eye irritation. Ingestion: Small amounts swallowed incidentally as a result of normal handling operations are not likely to cause injury. PRODUCT AND COMPANY IDENTIFICATION 1 HAZARDS IDENTIFICATION 2 Safety Data Sheet GHS Safety Data Sheet Keteca USA, Inc SDS Number: KP-5 F1 Page 2 of 5 Revision Date: 7/11/2023 Water Works™ Storm Ultra Ingredients: DI Water CAS 7732-18-5 66% Trade Secert Non Hazardous Surfactant Blend 34% The specific chemical identity and chemical composition has been withheld as a trade secret. The precise composition of this mixture is a trade secret. A complete disclosure will be provided to a physician or nurse in the event of a medical emergency. Inhalation: Skin Contact: Eye Contact: Ingestion: If symptoms develop, move victim to fresh air. If symptoms persist, obtain medical attention. Wash with soap and water. Flush eyes thoroughly with water for 15 minutes. Remove contact lenses after the initial 1 -2 minutes and continue flushing for several additional minutes. If effects occur, consult physician. If swallowed, seek medical attention if symptoms develop. Do not induce vomiting unless directed to do so by medical personnel. Extinguishing Media: Water fog or fine spray. Dry chemical fire extinguishers. Carbon dioxide fire extinguishers. Foam. General purpose synthetic foams (including AFFF) or protein foams may function, but will be less effective. Fire Fighting Procedures: Use water spray to cool fire exposed containers and fire affected zone until fire is out and danger of reignition has passed. Move container from fire area if this is possible without hazard. Burning liquids may be moved by flushing with water to protect personnel and minimize property damage. Avoid accumulation of water. Special Protective Equipment for Firefighters: Wear positive-pressure self-contained breathing apparatus (SCBA) and protective fire fighting clothing (includes fire fighting helmet, coat, trousers, boots, and gloves). If protective equipment is not available or not used, fight fire from a protected location or safe distance Personal Precautions: Spilled material may cause a slipping hazard. Use appropriate safety equipment. (See Section 8) Methods and materials for containment and cleaning up: Small spills: Absorb with materials such as: sand, vermiculite, absorbent pillows, pads and/or wipes. Do not use water for clean up. Collect in suitable and properly labeled containers. Large spills: Contain spilled material if possible. Pump into suitable and properly labeled containers. Handling Precautions: Storage Requirements: Avoid contact with eyes. Wash thoroughly after handling. Store indoors away from direct sunlight. Keep containers closed when not in use. Shelf life: 24 Months FIRE FIGHTING MEASURES 5 COMPOSITION/INFORMATION ON INGREDIENTS 3 FIRST AID MEASURES 4 ACCIDENTAL RELEASE MEASURES 6 HANDLING AND STORAGE 7 Safety Data Sheet GHS Safety Data Sheet Keteca USA, Inc SDS Number: KP-5 F1 Page 3 of 5 Revision Date: 7/11/2023 Water Works™ Storm Ultra Engineering Controls: Personal Protective Equipment: General ventilation should be sufficient for most operations. HMIS PP, B | Safety Glasses, Gloves Respiratory Protection: Wear respiratory protection when adverse effects, such as respiratory irritation or discomfort have been experienced, or where indicated by your risk assessment process. For most conditions no respiratory protection should be needed; however, if discomfort is experienced, use an approved air-purifying respirator. Appearance: Clear to yellowish Physical State: Liquid Odor: Mild Odor Threshold: No data available Solubility: Misible in water in all proportions Spec Grav./Density: 1.120 - 1.190 (Hydrometer) Viscosity: No data available Boiling Point: No data available Freezing/Melting Pt.: 32°F (0 C) Flammability: no data available Flash Point: >200°F Test Method SW1010 A Partition Coefficient: No data available Vapor Pressure: <1.0 mm Hg @ 68°F (not including water content). Vapor Density: No data available pH: 9.6 - 11.4 VOC: 2 g/l in "Neat" form. Evap. Rate: No data available Auto-Ignition Temp: No data available Decomp Temp: No data available UFL/LFL: No data available Chemical Stability: Materials to Avoid: Hazardous Decomposition: Hazardous Polymerization: Product is stable under normal conditions. This is a water-based product. Strong Acids; Strong Bases; Strong Oxidizing Agents. Will not occur. Will not occur. EXPOSURE CONTROLS/PERSONAL PROTECTION 8 PHYSICAL AND CHEMICAL PROPERTIES 9 STABILITY AND REACTIVITY 10 Safety Data Sheet GHS Safety Data Sheet Keteca USA, Inc SDS Number: KP-5 F1 Page 4 of 5 Revision Date: 7/11/2023 Water Works™ Storm Ultra Likely routes of exposure: Inhalation: Prolonged exposure is not expected to cause adverse effects. Ingestion: Small amounts swallowed incidentally as a result of normal handlingoperations are not likely to cause injury. Skin: Non-irritating. Eyes: May cause eye irritation. Skin Corrosion/Irritation: Non-irritant Eye Damage/Irritation: May cause mild eye irritation Germ Cell Mutagenicity: Mixture does not classify under this category Carcinogenicity: Mixture does not classify under this category Reporductive Toxicity: Mixture does not classify under this category STOT-Single Exposure: Mixture does not classify under this category STOT-Repeated Exposure: Mixture does not classify under this category Aspiration Hazard: Mixture does not classify under this category No Data Available . Dispose of uncontaminated material into sewer where applicable within Federal, State and/or local laws and regulations. Disposal of contaminated material must be in compliance with all Federal, State and/or local laws and regulations. Regulations may vary in different locations. Waste characterizations and compliance with applicable laws are the responsibility solely of the waste generator. DOT Non-Bulk - NOT REGULATED DOT Bulk - NOT REGULATED IMDG - NOT REGULATED ICAO/IATA - NOT REGULATED This information is not intended to convey all specific regulatory or operational requirements/information relating to this product. It is the responsibility of the transporting organization to follow all applicable laws, regulations and rules relating to the transportation of the material. TOXICOLOGICAL INFORMATION 11 ECOLOGICAL INFORMATION 12 DISPOSAL CONSIDERATIONS 13 TRANSPORT INFORMATION 14 Safety Data Sheet GHS Safety Data Sheet Keteca USA, Inc SDS Number: KP-5 F1 Page 5 of 5 Revision Date: 7/11/2023 Water Works™ Storm Ultra OSHA Hazard Communication Standard This product is not a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard, 29 CFR 1910.1200. Superfund Amendments and Reauthorization Act of 1986 Title III (Emergency Planning and Community Right-to-Know Act of 1986) Sections 311 and 312 Immediate (Acute) Health Hazard No Delayed (Chronic) Health Hazard No Fire Hazard No Reactive Hazard No Sudden Release of Pressure Hazard No Superfund Amendments and Reauthorization Act of 1986 Title III (Emergency Planning and Community Right-to-Know Act of 1986) Section 313 To the best of our knowledge, this product does not contain chemicals at levels which require reporting under this statute. California Proposition 65 (Safe Drinking Water and Toxic Enforcement Act of 1986) This product contains no listed substances known to the State of California to cause cancer, birth defects or other reproductive harm, at levels which would require a warning under the statute. US. Toxic Substances Control Act All components of this product are on the TSCA Inventory or are exempt from TSCA Inventory requirements under 40 CFR 720.30 CEPA - Domestic Substances List (DSL) All substances contained in this product are listed on the Canadian Domestic Substances List (DSL) or are not required to be listed. European Inventory of Existing Commercial Chemical Substances (EINECS) The components of this product are on the EINECS inventory or are exempt from inventory requirements. CEPA - Domestic Substances List (DSL) All substances contained in this product are listed on the Canadian Domestic Substances list (DSL) or are not required to be listed. NFPA: HMIS III: HMIS PPE: Health = 0, Fire = 0, Reactivity = 0, Specific Hazard = None Health = 0, Fire = 0, Physical Hazard = 0 B - Safety Glasses, Gloves Keteca USA, Inc urges each customer or recipient of this SDS to study it carefully and consult appropriate expertise, as necessary or appropriate, to become aware of and understand the data contained in this SDS and any hazards associated with the product. The information herein is provided in good faith and believed to be accurate as of the effective date shown above. However, no warranty, express or implied, is given. Regulatory requirements are subject to change and may differ between various locations. It is the buyer's/user's responsibility to ensure that its activities comply with all federal, state, provincial or local laws. The information presented here pertains only to the product as shipped. Since conditions for use of the product are not under the control of the manufacturer, it is the buyer's/user's duty to determine the conditions necessary for the safe use of this product. Due to the proliferation of sources for information such as manufacturer-specific SDSs, we are not and cannot be responsible for SDSs obtained from any source other than ourselves. If you have obtained an SDS from another source or if you are not sure that the SDS you have is current, please contact us for the most current version. Author: Keteca USA, Inc Publication Date: 6/4/2015 Revision No.: 1 None B REGULATORY INFORMATION 15 OTHER INFORMATION 16