HomeMy WebLinkAboutDAQ-2024-011332Tesoro Logistics Operations LLC
539 South Main Street
Findlay, OH 45840
Tel: 419.422.2721
Vn Ovenrurcnr Mat
Utah Division of Air Quality UTAH DEPARTMENT OF
Attn: Bryce Bird - ETWIBONMENTAL OUAU]Y
195 North 1950 West
P.O. Box 144820 S. P - :
Salt Lake City, Utah 841 16
DIVISION OF AIR QUALIT''
40 CFR 63 Subpart A and CC Periodic Reports
Tesoro Logistics Operations. LLC. Salt Lake CiB Truck Loading Rack and Remote Tank Farm
Dear Mr. Bird:
Please find enclosed the periodic report for Tesoro Logistics Operations, LLC, Salt Lake City Truck Loading
Rack and Remote Tank Farm (herein referred to as Tesoro Logistics) covering the time period between
January 15, 2024 and July 14, 2024. This reporl includes the periodic repoft in accordance with 40 CFR
63.654,40 CFR 63.'10 and Table 6 - General Provisions Applicability to Subpart CC in the Appendix to
Subpart CC - Tables.
I certify under penalty of law that, based on information and belief formed after reasonable inquiry, the
statements and information contained in the startup, shutdown, and malfunction report are true, accurate,
and complete.
lf you have additional questions or require more information, please contact Tina Harper at 615-499-1641
or at kkharper@marathonpetroleum.com.
Sincerely,
I 0"*g,&, fir*^*
Angela Brown
Vice President
Health, Environmental, Safety, and Security
Logistics & Storage Terminals
Attachment: PERIODIC EXCESS EMISSION AND STARTUP, SHUTDOWN, MALFUNCTION REPORT
September 6,2024
B-2-15659
cc:
USEPA Region Vlll
1595 Wynkoop Street
Mail Code ENF-AT
Denver, CO 80202-1129
VtA OVERNIGHT MAIt
PERIODIC EXCESS EMISSION AND STARTUP,
SHUTDOWN, MALFUNCTION REPORT
REFINERY MACT (40 CFR 63 Subpart CC)
Reporting Period:
January 15, 2024 - Iuly 14, 2A24
sa,, La ke ., J;i::?
..lilff :fi'::lT"llle ra nk Fa rm
475 West 900 North
Salt Lake City, Utah 84103
' lmWn''
DIVISION OF AIR OUALITY
Periodic Excess Emission Report
September 2024
Contents
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
List of Tobles
Gasoline Loading Rack Periodic Report pertaining to Tank Trucks or Cargo Tanks
563.6ss(b), 63.428(gX1), 63.428(hX2) & (3)........... .........11
Gasoline Loading Rack Periodic Report pertaining to Monitoring $53.654(b),63.428(hX1)
12
Group 1 lnternal Floating Roof Annual (visual hatch) lnspections Conducted During the
Reporting Period 563.655(gX2Xi) .................. ...........'........' 1 3
Group 1 lnternal Floating Roof lnternal lnspections Conducted During the Reporting
Group 1 lnternal Floating Roof lnternal lnspections Conducted During the Reporting
Group 1 Floating Roof lnspections Conducted During the Reporting Period
Pressure Relief Devices in OHAP gas or vapor service subject to $63.6480(1).......................17
Pressure Relief Devices in OHAP gas or vapor service subject to $63.648O(2).......................18
Notification of Compliance Status Update - Storage Vessels......... ....,..................19
Notification of Compliance Status Update - Miscellaneous Process Vents..............................20
Notification of Compliance Status Update - Pressure Relief Devices.........................................21
List of Attochments
Attachment A - Secondary Seal Gap Calculations
Attachment B - Primary Seal Gap Calculations
1.0 563.655 Subport CC Periodic Reporling
Pursuant to $63.655(e), the following section contains the required information specified in paragraphs (a)
through (g) in 563.655. Each specified requirement is identified in bold text and Tesoro Logistics'response
is provided information is in non-bold text.
This compliance report covers the period beginning on the compliance date forthis affected source,
January 15,2024 through )uly 14,2024.
l.l $63.65s(o)
Each owner or operator subject to the wastewater provisions in 563.647 shall comply with the
recordkeeping and reporting provisions in 5561.355 and 61.357 of 4O CFR part 61, subpart FF
unless they are complying with the wastewater provisions specified in paragraph (o)(2)(ii) of
563.640. There are no additional reporting and recordkeeping requirements for wastewater under
this subpart unless a wastewater stream is included in an emissions average. Recordkeeping and
reporting for emissions averages are specified in 563.653 and in paragraphs (0(5) and (gX8) of this
section.
The requirements of 40 CFR 63.655(a) apply to the entire Tesoro "Facility" (includes the Truck
Loading Rack, RefineU, and Remote Tank Farm) in accordance with 40 CFR 63.655(a). The Tesoro
"Facility" complies with the annual reporting provisions in $61.357 of 40 CFR part 61, and Logistics
source is included in the report for Tesoro Refining and Marketing Company. There are no
additional reporting requirements for wastewater under 40 CFR 63 Subpart CC.
Under 40 CFR 61.357(c), if the total annual benzene quantity from facility waste is less than 10
Mg/yrbutisequaltoorgreaterthanl Mg/yr,thentheowneroroperatorshallsubmittothe
Administrator one of the following, as appropriate:
A report that updates the information listed in paragraphs 961.357(a) (1)through (a)(3) of this
section. The report is to be submitted annually and whenever there is a change in the process
generating the waste stream that could cause the total annual benzene quantity from facility
waste to increase to 10 Mg/yr or more, or
lf the information in the annual report required by 561.357(a)(1) through (a)(3) is not changed
in the following year, the owner or operator may submlt a statement to that effect.
A separate report regarding the TAB is submitted in accordance with $61.357(c) by Tesoro
Refining and Marketing Company, that include the Logistics' assets.
1.2 $63.6ss(b)
Each owner or operator subject to the gasoline loading rack provisions in 563.650 shall comply with
the recordkeeping and reporting provisions in $63.428 (b) and (c), (g)(1), (h)(1) through (h)(3), and
(k) of subpart R. These requirements are summarized in table 4 of this subpart. There are no
1.
2.
additiona! reporting and recordkeeping requirements for gasoline loading racks under this subpart
untess a loading rack is included in an emissions average. Recordkeeping and reporting for
emissions averages are specified in 963.653 and in paragraphs (0(5) and (gX8) of this section.
The following information is found in Table 1.
o Each loading of a gasoline cargo tank for which vapor tightness documentation had not
been previously obtained by the facility; 1563.a28(gX1)l
o Each instance of a nonvapor-tight gasoline cargo tank loading at the facility in which the
owner or operator failed to take steps to assure that such cargo tank would not be
reloaded at the facility before vapor tightness documentation for that cargo tank was
obtained, I563.428(hx2)l
. Each reloading of a nonvapor-tight gasoline cargo tank at the facility before vapor
tightness documentation for that cargo tank is obtained by the facility in accordance with
563.422(c)(2). [$63.428hX3)]
Table 2 notes each exceedance or failure to maintain, as appropriate, the monitored operating
parameter value determined under $63.425(b). The report includes the monitoring data for the
days on which exceedances or failures occurred, and a description and tlming of the steps taken
to repair or perform maintenance on the vapor collection and processing systems or the CMS (if
the CMS indicated that the operating parameter value was exceeded or not maintained).
t563.428(h)(1)l
1.3 $63.6ss(c)
Each owner or operator subiect to the marine tank vessel loading operation standards in 563.651
shall comply with the recordkeeping and reporting provisions in 5563.557(a) and 63.567(c) through
(k) of subpart Y. These requirements are summarized in table 5 of this subpart. There are no
additional reporting and recordkeeping requirements for marine tank vessel loading operations
under this subpart unless marine tank vessel loading operations are included in an emissions
average. Recordkeeping and reporting for emissions averages are specified in 563.653 and in
paragraphs (0(5) and (gX8) of this section.
Tesoro Logistics does not have marine loading regulated under40 CFR 63 Subpart Yand Subpart
cc.
1.4 S63.6ss(d)
Each owner or operator subject to the equipment leaks standards in 563.648 shall comply with the
recordkeeping and reporting provisions in paragraphs (dXl) through (dX6) of this section.
Tesoro Logistics has chosen to complywith the equipment leaks standards in 563.648 by
complying with the provisions of 40 CFR 60 Subpart Wa. Therefore, its periodic reporting
obligation is delineated in 40 CFR 6A.487a. Tesoro Logistics currently submits a quarterly report
to the Utah Division of Air Quality with the information required in 40 CFR 60.487a and Utah's
R307-326-7. These reports satisfy the requirements of 40 CFR 63.655(d).
l.s $63.6s5(e)
Each owner or operator of a source subject to this subpart shall submit the reports listed in
paragraphs (e)(1) through (eX3) of this section except as provided in paragraph (hX5) of this
section, and shal! keep records as described in paragraph (i) of this section.
Tesoro Logistics submits this report pursuant to 563.655(eX2). 563.655(e)(1) and Section (3)
reporting requirements are not applicable for this periodic report.
r.6 $63.655(f)
Each owner or operator of a source subject to this subpart shall submit a Notification of
Compliance Status report within 150 days after the compliance dates specified in 563.540(h) with
the exception of Notification of Compliance Status reports submitted to comply with 553.640(lX3)
and for storage vessels subject to the compliance schedule specified in 963.6a0(h)(2).
Not applicable for this periodic report.
1.7 $63.65s(g)
The owner or operator of a source subject to this subpart shall submit Periodic Reports no later
than 60 days after the end of each 6-month period when any of the information specified in
paragraphs (gxl) through (7) of this section or paragraphs (gxg) through (14) of this section is
collected. The first 6-month period shal! begin on the date the Notification of Compliance Status
report is required to be submatted. A Periodic Report is not required if none of the events
identified in paragraphs (g)(1) through (7) of this section or paragraphs (g)(9) through (14) of this
section occurred during the 5-month period unless emissions averaging is utilized. Quarterly
reports must be submitted for emission points included in emission averages, as provided in
paragraph (gX8) of this section. An owner or operator may submit reports required by other
regulations in place of or as part of the Periodic Report required by this paragraph (g) if the
reports contain the information required by paragraphs (g)(1) through (14) of this section.
ln accordance with 40 CFR 53.655(g), the periodic report is submitted no later than 60 days after
the end of each 6-month period when any of the compliance exceptions specified in paragraphs
(g)(1)through (gX6)of this section occur.
$63.655(g)(1) For storage vessels, Periodic Reports shall include the information specified for
Periodic Reports in paragraphs (gX2) through (5) of this section. lnformation related to gaskets,
slotted membranes, and sleeve seals is not required for storage vessels that are part of an existing
source complying with $63.645.
Tesoro Logistics summarizes inspection results, as required, in the following sections. When
complying with 563.646, Tesoro Logistics does not report inspection failures related to gaskets,
slotted membranes, and sleeve seals.
963.655(gX2) Internal floating roofs.
563.655(g)(2Xi) An owner or operator who elects to comply with 963.646 by using a fixed roof and
an internal floating roof or by using an external floating roof converted to an internal floating roof
shall submit the results of each inspection conducted in accordance with 963.120(a) of subpart G in
which a failure is detected in the control equipment.
Tesoro Logistics summarizes inspection results, as required, in the following sections.
563.655(9)(2XD(A) For vessels for which annual inspections are required under 963.120(a)(2)(i) or
(a)(3)(ii) of subpart G, the specifications and requirements listed in paragraphs (gX2XiXAXl)
through (3) of this section apply.
563.655(9)(2)(i)(A)(1) A failure is defined as any time in which the internalfloating roof is not
resting on the surface of the liquid inside the storage vesset and is not resting on the leg supports;
or there is liquid on the floating roof; or the seal is detached from the internal floating roof; or
there are holes, teals, or other openings in the seal or seal fabric; or there are visible gaps between
the sealand the wallof the storage vessel.
Annual inspections for which a failure was detected in the control equipment are summarized in
Table 3.
563.655(gX2XD(AX2) Except as provided in paragraph (gX2)(iXAX3) of this section, each Periodic
Report shall include the date of the inspection, identification of each storage vessel in which a
failure was detected, and a description of the failure. The Periodic Report shall also describe the
nature of and date the repair was made or the date the storage vessel was emptied.
Annual inspections forwhich a failurewas detected,the date of the inspection, identification of
each storage vessel in which a failure was detected, and a description of the failure are
summarized in Table 3.
!63.655(g)(2XD(AX3) lf an extension is utilized in accordance with 563.120(aXa) of subpart G, the
owner or operator shall, in the next Periodic Report, identify the vessel; include the documentation
specified in 963.120(a)(4) of subpart G; and describe the date the storage vesselwas emptied and
the nature of and date the repair was made.
Tesoro Logistics did not utilize an extension during this reporting period.
$63.655(gX2Xi)(B) For vessels for which inspections are required under 963.120(a)(2Xii), (aX3Xi),
or (aX3Xiii) of subpart G (i.e., internal inspections), the specifications and requirements listed in
paragraphs (gX2XiXBXl) and (2) of this section apply.
963.655(gX2XD(B)(1) A failure is defined as any time in which the internal floating roof has defects;
or the primary seal has holes, tears, or other openings in the seal or the seal fabric; or the
secondary seal (if one has been installed) has holes, tear:s, or other openings in the seal or the seal
fabric; or, for a storage vessel that is part of a new source, the gaskets no longer close off the liquid
surface from the atmosphere; or, for a storage vessel that is part of a new source, the slotted
membrane has more than a 10 percent open.
lnternalinspections forwhich a failure was detected in the control equipment are summarized in
Table 4.
963.655(gX2)(D(BX2) Each Periodic Report shall include the date of the inspection, identification of
each storage vessel in which a failure was detected, and a description of the failure. The Periodic
Report shall also describe the nature of and date the repair was made.
lnternal inspections forwhich a failure was detected, the date of the inspection, identification of
each storage vessel in which a failure was detected, and a description of the failure are
summarized in Table 4.
563.655(gx2Xii) An owner or operator who elects to comply with 963.660 by using a fixed roof and
an internal floating roof shall submit the results of each inspection conducted in accordance with
563.1063(c)(1), (dxl), and (dX2) of subpart WW in which a failure is detected in the control
equipment. For vessels for which inspections are required under 963.1063(c) and (d), the
specifications and requirements listed in paragraphs (g)(2Xii)(A) through (C) of this section apply.
Tesoro Logistics' Group 'l storage vessels are compliant with 563.660.
(A) A failure is defined in 563.1063(d)(1) of subpart l/UW.
lnspections for which a failure was detected in the control equipment are summarized in Table 5.
(B) Each Periodic Report sha!! include a copy of the inspection record required by 953.1065(b) of
subpart WW when a failure occurs.
lnspections forwhich a failure was detected in the control equipment are summarized in Table 5.
(C) An owner or operator who elects to use an extension in accordance with 553.1063(e)(2) of
subpart WW shall, in the next Periodic Report, submit the documentation required by
563.1063(e)(2).
Tesoro Logistics did not utilize an extension during this reporting period
563.655(gX3) External floating roofs.
963.655(g)(3Xi) An owner or operator who elects to comply with 963.645 by using an external
floating roof shall meet the periodic repofting requirements specified in paragraphs (gX3)(iXA)
through (C) of this section.
Not applicable. Tesoro Logistics does not operate external floating roof tanks at the Truck
Loading Rack.
(A) The owner or operator shall submit, as part of the Periodic Report, documentation of
the results of each seal gap measurement made in accordance with 563.120(b) of subpart G
in which the seal and sea! gap requirements of 563.120(bX3), (4), (5), or (6) of subpart G are
not met. This documentation shall include the information specified in paragraphs
(g)(3Xi)(AXl) through (4) of this section.
Not applicable. Tesoro Logistics does not operate erternal floating roof tanks at the
Truck Loading Rack.
(B) lf an extension is utilized in accordance with 563.120(bx7)(ii) or (b)(8) of subpart G, the
owner or operator shall, in the next Periodic Report, identify the vessel; include the
documentation specified in 563.120(bX7)(ii) or (b)(8) of subpart G, as applicable; and
describe the date the vessel was emptied and the nature of and date the repair was made.
Not applicable. Tesoro Logistics does not operate external floating roof tanks at the
Truck Loading Rack.
(C) The owner or operator shall submit, as part of the Periodic Report, documentation of
any failures that are identified during visual inspections required by 563.120(bX1O) of
subpart G. This documentation shall meet the specifications and requirements in
paragraphs (gX3XiXCXl) and (2) of this section.
(CXl) A failure is defined as any time in which the external floating roof has defects; or the
primary seal has holes or other openings in the seal or the seal fabric; or the secondary sea!
has holes, tears, or other openings in the seal or the seal fabric; or, for a storage vessel that
is paft of a new source, the gaskets no longer close off the liquid surface from the
atmosphere; or, for a storage vessel that is part of a new source, the slotted membrane has
more than 10 percent open area.
Not applicable. Tesoro Logistics does not operate external floating roof tanks at the
Truck Loading Rack.
(CX2) Each Periodic Report shall include the date of the inspection, identification of each
storage vessel in which a failure was detected, and a description of the failure. The Periodic
Report shall also describe the nature of and date the repair was made.
Not applicable. Tesoro Logistics does not operate external floating roof tanks at the
Truck Loading Rack.
963.655(g)(3Xii) An owner or operator who elects to comply with 563.660 by using an externa!
floating roof shall meet the periodic reporting requirements specified in paragraphs (gX3XaiXA)
and (B) of this section.
(A) For vessels for which inspections are required under 953.1053(c)(2), (dX1), and (d)(3) of
subpart WW, the owner or operator shall submit, as part of the Periodic Report, a copy of
the inspection record required by 963.1065(b) of subpart WW when a failure occurc. A
failure is defined in $63.1053(dxl).
Not applicable. Tesoro Logistics does not operate erternalfloating roof tanks at the
Truck Loading Rack.
(B) An owner or operator who elects to use an extension in accordance with 963.1063(eX2)
or (c)(2)(iv)(B) of subpart WW shall, in the next Periodic Report, submit the documentation
required by those ParagraPhs.
Notapplicable. TesoroLogisticsdoesnotoperateexternal floatingrooftanksattheTruckLoading
Rack.
$63.655(gX4) [Reserved]
563.655(g)(5) An owner or operator who elects to comply with 563.546 or 963.660 by installing a
ctosed vent system and controldevice shallsubmit, as paft of the next Periodic Report, the
information specified in paragraphs (g)(s)(i) through (v) of this section, as applicable.
Tesoro Logistics does not have any Group 1 tanks that comply with $63.646 or $63.660 by the use
of a closed vent system and control device.
963.655(gX6) For miscellaneous process vents for which continuous parameter monitorc are
required by this subpart, periods of excess emissions shall be identified in the Periodic Reports and
shall be used to determine compliance with the emission standards.
Tesoro Logistics does not have Group 1 Miscellaneous Process Vents controlled by a flare.
963.655(g)(6)(i) Period of excess emission means any of the following conditions:
Not applicable. Tesoro Logistics does not have Group 1 MPV's.
(A) An operating day when the daily average value of a monitored parameter, except
presence of a flare pilot flame, is outside the range specified in the Notification of
Compliance Status report. Monitoring data recorded during periods of monitoring system
breakdown, repairs, calibration checks and zero (low-level) and high-level adjustments shall
not be used in computing daily average vatues of monitored parameterc.
(A) Not applicable. Tesoro Logistics does not have Group 'l MPVs controlled by a flare.
(B) An operating day when all pilot flames of a flare are absent.
(B) Not applicable. Tesoro Logistics does not have Group 1 MPVs controlled bya flare.
(C) An operating day when monitoring data required to be recorded in paragraphs (iX3) (i)
and (ii) of this section are available for less than 75 percent of the operating hours.
(C) Not applicable. Tesoro Logistics does not have Group 1 MPVs recording data.
(D) For data compression systems under paragraph (hXsXiiD of this section, an operating
day when the monitor operated for less than 75 percent of the operating hours or a day
when less than 18 monitoring values were recorded.
(D) Not applicable. Tesoro Logistics does not use data compression systems.
963.655(gX6)(ii) For miscellaneous process vents, excess emissions shall be reported for the
operating parameters specified in Table 7 of this subpart unless other site-specific parameter(s)
have been approved by the operating permit authority.
Not applicable. Tesoro Logistics complies with 563.643(a), therefore, the requirements of Subpart
CC Table 7 do not aPPlY.
563.555(g)(6Xiii) For periods in closed vent systems when a Group 1 miscellaneous process vent
stream was detected in the bypass line or diverted from the controldevice and either directly to
the atmosphere or to a control device that does not comply with the requirements in 963.643(a),
report the date, time, duration, estimate of the volume of gas, the concentration of organic HAP in
the gas and the resulting mass emissions of organic HAP that bypassed the control device. For
periods when the flow indicator is not operating, report the date, time, and duration.
Not applicable. Tesoro Logistics does not have Group 'l MPV's.
563.655(gX7) lt a performance test for determination of compliance for a new emission point
subject to this subpart or for an emission point that has changed from Group 2 to 6roup 1 is
conducted during the period covered by a Periodic Report, the results of the performance test shall
be included in the Periodic Report.
No performance tests were conducted during the reporting period that demonstrated a change
from Group 2 status to Group 1 or for demonstrating compliance of a new emission point subject
to Subpart CC.
563.6SS(gX8) The owner or operator of a source shall submit quarterly reports for all emission
points included in an emissions average.
Not applicable. Tesoro Logistics does not seek to complywith Subpart CC by using the emission
averaging provisions presented in 563.652, therefore no quarterly report is required in accordance
wlth $63.655(g)(8).
963.655(gX9) For heat exchange systems. Periodic Reports must include the information in
s63.6ss(g)(e).
Not applicable. Tesoro Logistics does not have heat exchange systems subject to Subpart CC.
963.655(gX10) For pressure relief devices subiect to the requirements 963.548(), Periodic Reports
must include the information specified in paragraphs (gxl0Xi) through (iii) of this section.
963.655(gX10)(i) For pressure relief devices in organic HAP gas or vaPor selvice, pursuant to
963.648(D(1), report any instrument reading of 500 ppm or greater.
Pressure relief devices (PRD)in organic HAP gas orvaporservice, pursuantto 563.648()('1)where
an instrument reading of 500 ppm or greater occurred is summarized in Table .
563.655(gX1O)(iD For pressure relief devices in organic HAP gas or vapor service subiect to
563.648(j)(2), report confirmation that any monitoring required to be done during the reporting
period to show compliance was conducted.
For PRDs in organic HAP gas or vapor service subject to 563.6480)(2), monitoring required to
demonstrate compliance is summarized in Table .
563.655(gxlOXiiD For pilot-operated pressure relief devices in organic HAP service, report each
pressure retease to the atmosphere through the pilot vent that equals or exceeds 72 pounds of VOC
per day, including duration of the pressure release through the pilot vent and estimate of the mass
quantity of each organic HAP released.
Not applicable. Tesoro Logistics does not have pilot operated PRDs at the asset that it operates.
563.65s(gxlOXiv) For pressure relief devices in organic HAP seruice subject to 963.648O(3), rePort
each pressure retease to the atmosphere, including duration of the pressure release and estimate of
the mass quantity of each organic HAP released, and the results of any root cause analysis and
corrective action analysis completed during the reporting period, including the corrective actions
imptemented during the reporting period and, if applicable, the implementation schedule for
ptanned corrective actions to be implemented subsequent to the reporting period.
No OHAP PRDs at the facility experienced a release during the reporting period.
963.655(g)(11) For flares subject to 563.670, Periodic Reports must include the information
specified in paragraphs (g)(11)(i) through (iv) of this section.
Not appllcable. Tesoro Logistics does not operate a flare.
963.655(g)(12) For delayed coking units, the Periodic Report must include the information
specified in paragraphs (gxl2)(i) through (iv) of this section.
Not applicable. Tesoro Logistics does not operate a delayed coking unit.
963.655(g)(13) For maintenance vents subject to the requirements in 963.643(c), Periodic Reports
must include the information specified in paragraphs (g)(13Xi) through (iv) of this section for any
release exceeding the applicable limits in 553.643(cXl). For the purposes of this reporting
requirement, owners or operatorc complying with 563.643(cXl)(iv) must repoft each venting event
for which the lower explosive limit is 20 percent or greater.
Note: The provisions for maintenance vents subject to 563.643(c)were not applicable until
December 26,2018. All maintenance vent activities were within regulatory limits during the
applicable reporting period.
963.655(gX14) Any changes in the information provided in a previous Notification of Compliance
Status report.
Table,Table, and Table 11 contain anychanges in the information provided in a previous NOCS
rePort.
The cover letter for this report contains the name, title, and signature of the responsible official who is
certifying its accuracy. [563.1 0(d)(5)(i)]
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Attachment A
Secondary Seal Gap Calculations
NO SEAL GAP MEASUREMENT INS
REPORTING PERIOD.
ECTION COMPLIANCE EXCEPTIONS WERE FOUND DURING THE
Attachment B
Primary Seal Gap Calculations
NO SEAL GAP MEASUREMENT I
REPORTING PERIOD.
TION COMPLIANCE EXCEPTIONS WERE FOUND DURING THE
sEP - I 2024
DIVISION OF AIR QUALITY