DAQ-2024-011724

State of Utah
SPENCER J. COX
Goventor
DEIDRE HENDERSON
Lieutenanl Goventor
Department of
Environmental Quality
Kirnberly D. Shelley
Execulive Director
DTVISION OF AIR QUALITY
Bryce C. Bird
Direclor
November 12,2024
Sent Via Certified Mail No. 70022030000044115557
DAQC-l tt0-24
Site ID I1674 (Bl)
Donovan Johnson
SkyWest Airlines, Inc
I129 North 3950 Wesi
Salt Lake City, UT 84116
Dear Mr. Johnson:
Re: Compliance Advisory - SkyWest Airlines, Inc. - Aircraft Repair and Maintenance Operations
Facility, Approval Order (AO) DAQE-ANl16740002-21, Salt Lake County
On June 6,2024, a representative of the Utah Division of Air Quality (DAQ) inspected the SkyWest
Airlines, Inc. - Aircraft Repair and Maintenance Operations Facility located at ll29 North 3950 West
in Salt Lake City, UT, and requested records to be submitted by J;une 24,2024.Follow-up record
requests were made on August | , 2024, and September 9 , 2024. To date, the requested records have
not been submitted which may be a violation of condition I.4 of AO DAQE-AN116740002-21.
SkyWest Airlines, Inc. is required to comply with the above regulations. A written response to this
letter is required within ten (10) business days of receipt of this letter.
Additional details about the above observations and regulations are attached to this letter. Please
contact Irene Tucker at 385-306-6521 or [e-mail] if you have any questions about this letter.
Sincerely,
L4,e,4;
Chad Gilgen, Manager
Minor Source Compliance Section
CG:ITjl
Enclosure: Records Request Email
cc: Salt Lake County Health Department
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820. Salt Lake City, UT 84114-4820
Telephone [phone]. Fax (801) s364099. T.D.D. [phone]
*wl.deq.utah.gov
Printcd on 100% recycled paper
Potential Violations
On June 6,2024, a representative of the Utah Division of Air Quality (DAQ) inspected the
SkyWest Airlines, lnc. - Aircraft Repair and Maintenance Operations Facility located at ll29
North 3950 West in Salt Lake City, UT, and requested records to be submitted by June 24,2024.
Follow-up record requests were made on August 1,2024, and September 9,2024. To date, the
requested records have not been submitted and the DAQ has documented the following potential
violations:
r Condition I.4 of AO DAQE-AN116740002-21
Failure to submit records required by the AO.
DAQC-I tt0-24
Page2
AO Conditions/Rules
DAQE-AN[I67 40002-21, dated September 2, 2021
Condition 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 trriro (2) vears.
The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You are
responsible for complying with the Utah Air Conservation Rules. There are possible administrative
and civil penalties for failing to do so. Section 19-2-115 of the Utah Code Annotated provides that
violators of the Utah Air Conservation Act and/or any order issued there under may be subject to a
civil penalty of up to $10,000 per day for each violation.
The written response to this CA will be considered in resolving the deficiencies documented in this
letter. It may include information demonstrating compliance with the regulations or a schedule to
bring your company back into compliance with the applicable regulations. The DAQ will review your
response and this CA may be revised as a result of that review. Failure to respond in writing within
ten (10) business days of receipt of this CA will be considered in any subsequent enforcement action
and the assessment of penalties.
Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.
This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this
inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the DAQ
did not observe or evaluate, or any other conditions found during future inspections.
A meeting may be requested to discuss this CA. Please contact Irene Tucker at 385-306-6521 or
[e-mail] if you would like to request a meeting or if you have any questions about this letter.
10110124,12:33 PM State of Utah Mail - RECORDS REQUEST FOR APPROVAL ORDER DATED SEPTEMBER 2, 2021
lrene Tucker <[e-mail]>
REGORDS REQUEST FOR APPROVAL ORDER DATED SEPTEMBER 2,2021
7 messages
lrene Tucker <[e-mail]>
To: Donovan Johnson <[e-mail]>
Mon, Jun 10,2024 at 3:47 PM
Mr. Johnson:
I inspected your facility on June 6,2024. Here is the Records Request. Let me know if you have any
questions. Please respond byJune 24,2024.
Sincerely,
lrene Tucker
1. Has there been any modifications to the equipment or processes of this AO? Explain if yes.
2. Has there been any breakdown in the processes or equipment to result in emissions in the last year?
3. Have you replaced any equipment (Boilers, Heating Units) on this AO?
4. Rolling 12-month VOC Emissions
5. Rolling 12-month HAP Emissions
6. Provide the manufacturer's certification of the emission rates for the Emergency Generator Engine and
the Fire Pump Engines
7. Provide the hours of operation of the Emergency Generator Engine and the Fire Pump Engines in
rolling L2-month period
8. Provide a Fuel Certificate for the sulfur content of diesel.
9. Provide the Technical Data Sheets for the coatings used at your facility. Click on the link and select the
Category of Coating to match the corresponding VOC content.
https://adminrules.utah.gov/public/rule/R307-355/Current%20Rules?searchText=R307-355
Donovan Johnson <[e-mail]>
To: lrene Tucker <[e-mail]>
Cc: Brian Anderson <[e-mail]>
Thu, Sep 5,2024 at 3:45 PM
Hello lrene,
I do apologize, this email slipped through the cracks. Please give me a few days to answer to this request. Thank you.
Donovan
On Jun 10,2024,a|3:47 PM, lrene Tucker <[e-mail]> wrote:
[Quoted text hidden]
Donovan Johnson <[e-mail]>
To: lrene Tucker <[e-mail]
Cc: Brian Anderson <[e-mail]>
Mon, Sep 9,2024 at 10:28 AM
Hello lrene,
https://mail.google.com/mail/u/0/?ik=a33cBBba66gv;6111r=pt&search=all&permthid=thread-a:r7435726909422531766&simpl=msg-a:r736962755069039..
10110124,12:33 PM State of Utah Mail - RECORDS REQUEST FOR APPROVAL oRDER DATED SEPTEMBER 2, 2021
thank you for your patience. I have made some responses below. Do you have the full submittal of information from last
inspection? We have had some movement in positions and could use some help with formatting this information for this
inspection.
From: lrene Tucker <[e-mail]>
Sent: Monday, June 10,2024 3:47 PM
To: Donovan Johnson <DoJohnson@sky,west.com>
Subject: [EXTERNAL]RECORDS REQUEST FORAPPROVAL ORDER DATED SEPTEMBER 2,2021
Mr. Johnson:
I inspected your facility on June 6,2024. Here is the Records Request. Let me know if you have any
questions. Please respond byJune 24,2024.
Sincerely,
lrene Tucker
1. Has there been any modifications to the equipment or processes of this AO? Explain if yes, No changes
2. Has there been any breakdown in the processes or equipment to result in emissions in the last year? No
breakdowns existed.
3. Have you replaced any equipment (Boilers, Heating Units) on this AO? No replacements occurred.
4. Rolling 12-month VOC Emissions The Person who tracked this for us retired and we have experienced a
gap as a result
5. Rolling 12-month HAP Emissions The Person who tracked this for us retired and we have experienced a
gap as a result
6. Provide the manufacturer's certification of the emission rates for the Emergency Generator Engine and, the
Fire Pump Engines Have we ever provided this in the past?
7. Provide the hours of operation of the Emergency Generator Engine and the Fire Pump Engines in rolling
12-month period Generator and Fire Pump Engines experienced 0 operation hours for the rolling 12 month
period.
8. Provide a Fuel Certificate for the sulfur content of diesel. Fuel was not added to these engines for the
rolling 12 month period.
9. Provide the Technical Data Sheets for the coatings used at your facility. Click on the link and select the
Category of Coating to match the corresponding VOC content. Do you have this information ftom the last
submission? No changes occurred in coatings.
https://adminrules.utah.gov/public/rule/R307-355/Current%20Rules?searchText=R307-355
https://mail.google.com/mail/u/0/?ik=a33c88ba88&view=pt&search=all&permthid=thread-a:17435726909422531766&simpl=msg-a:1736962755069039... 213
10110124,12:33 PM State of Utah Mail - RECORDS REQUEST FOR APPROVAL ORDER DATED SEPTEMBER 2, 2021
lrene Tucker <[e-mail]> Mon, Sep 9,2024 at 11 :59 AM
To: Donovan Johnson <[e-mail]>
Cc: Brian Anderson <[e-mail]>
ls it possible for me to stop by for less than an hour to go over your responses?
Thanks,
lrene
lQuoted text hiddenl
lrene Tucker <[e-mail] Mon, Sep 9,2024 at 3:02 PM
To: Donovan Johnson <[e-mail]>
Cc: Brian Anderson <[e-mail]>
Hello Brian and Donovan:
Thanks for the email response. By the way Brian, according to the DAQ Database, the most current Approval Order (AO)
DAQE-AN116740002-21, is dated September 2, 202'1. This is the AO that SkyWest was working on when I conducted the
inspection in 2020. During that inspection, SkyWest was given a Notice of Violation for failure to provide requested
records. SkyWest settled for a reduced penalty on condjtion that they stayed in compliance.
This email response, like then in 2020, has no records provided even two months after the Site lnspection. I also noted
that according to the 2020 Emissions lnventory Report for SkyWest, the emissions were very low, and way below the
PTEs of your AO. Therefore, I suggest you contact NSR for a Small Source Exemption designation. Check out the link
below for additional information. Let me know if you have any questions or concerns.
https://deq,utah.gov/air-quality/new-source-review-exemptions-from-permitting-air-quality
Sincerely,
lrene Tucker
[Quoted text hidden]
Donovan Johnson <[e-mail]>
To: lrene Tucker <[e-mail]>
Cc: Brian Anderson <[e-mail]>
Mon, Sep 9,2024 at 4:08 PM
Hello lrene, I am traveling all week. I am happy to have a call with you, or meet with you next week.
[Ouoted text hidden]
lrene Tucker <[e-mail]>
To: Donovan Johnson <[e-mail]>
Cc: Brian Anderson <[e-mail]>
My number is 385-306-6521.
[Quoted text hiddenl
Mon, Sep 9,2024 at4:16 PM
https://mail.google.comimail/u/01?ik=a33c88ba666v;6e1=pt&search=all&permthid=thread-a:17435726909422531766&simpl=msg-a:r736962755069039... 3/3
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