DAQ-2025-000015

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DAQC-1265-24
Site ID 13315 (B1)

MEMORANDUM

TO: FILE – WHITEWATER WHIRLPOOL BATHS & SYSTEMS (WWBS)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: December 23, 2024

SUBJECT: FULL COMPLIANCE EVALUATION (FCE), Major, Utah County,
FRS UT0000004904900257

DATE OF INSPECTION: December 20, 2024

SOURCE LOCATION: Lindon Plastic Composite Plant #1
195 South Geneva Road, Lindon, UT

Pleasant Grove Composite Plant #2
330 West 200 South, Pleasant Grove, UT

MAILING ADDRESS: Whitewater Whirlpool Baths & Systems
195 South Geneva Road,
Lindon, UT 84042

SOURCE CONTACTS: Kirk Williamson, Owner

Brian Urry, Vice-President
Cell: (801)-367-1122

Trevor Urry, Operations Manager
Cell: (385)-477-8002

Marilyn Touchard: Touchard Environmental Services
[phone], [e-mail]

OPERATING STATUS: Both plants (Plant #1 and Plant # 2) were operating at time of the
inspection.

PROCESS DESCRIPTION:

Whitewater Whirlpool Baths & Systems (WWBS) manufactures cultured marble panels, countertops,
accessories, bathtubs, and acrylic sinks. WWBS operates a reinforced plastic composites plant at 195 South
Geneva Road in Lindon (Lindon Plant #1) located in Utah County. WWBS has requested to perform the same
operation at different locations simultaneously if needed at 330 West 200 South in Pleasant Grove (Pleasant
Grove Plant #2) in Utah County. Forms are placed on a track system and transported to a spray booth where a
gel coat is applied using spray guns. Overspray is drawn through the spray booth filter bank which captures
any aerosol droplets. The air passing through the filters is vented through a stack on the top of the building.
The gel-coated forms are then transported out of the booth to a cure area to air dry until tacky. Cured panel,
accessory, and countertop forms go to a casting area where a matrix of resin, Methyl Methacrylate (MMA),
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Methyl Ethyl Ketone Peroxide (MEKP) catalyst, filler (silica sand and/or calcium carbonate), and color may
be applied. This matrix is applied by an autocaster that has a heated tip, mixing occurs at the tip.

Some applications use the existing electric pot mixer, which is mostly used as a backup, specialty jobs, and the
tyvarian area. Cured tub and sink forms go to a fiberglass chop or roll application area where resin and glass
are applied using Venus Magnum chop guns or hand rollers. All resin-coated forms are then placed on a
curing rack. Once completely cured, products are sanded in the finish area and prepped for shipment. The
empty forms are then cleaned with acetone and sent back to the start of the assembly line. The tyvarian area is
a flowcoat process. The glass frames are overlain with an image and flowcoated with resin. The resin is hand-
rolled to remove bubbles. The process is the same except resin is filled using the autocaster.

HAP emissions (styrene) from the resins/gel coats are controlled by following a Work Practice Plan which
conforms with the work practice standards found in Table 4 of 40 CFR 63 Subpart WWWW and by meeting
the applicable emission limits listed in Table 3 of 40 CFR 63 Subpart WWWW.

APPLICABLE REGULATIONS: Title V Operating Permit (TVOP) # 4900257001, dated July 12, 2017,
and revised July 12, 2017

40 CFR Part 63 Subpart A-General Provision
40 CFR Part 63 Subpart WWWW- Reinforced Plastics Composites
Production

SOURCE INSPECTION EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements." (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))
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I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4

This permit may be modified, revoked, reopened, and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation and
reissuance, or termination, or of a notification of planned changes or anticipated
noncompliance shall not stay any permit condition, except as provided under
R307-415-7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4

Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The permit expired on July 12, 2022. Application for permit renewal was received, by the
DAQ, on January 11, 2022, before the due date of January 12, 2022. The DAQ has not issued
the new TVOP to date. Instead, a Shield letter (DAQO-SH0133150002-22), dated February
10, 2022, was sent to Whitewater allowing them to operate under the current permit until the
issuance of the new permit. The new TVOP has not been issued to date. It is a work in
progress.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's failure to have an operating permit will not be a violation of R307-415, until the Director takes final action on the permit renewal application. In such case, the terms and conditions of this permit shall remain in force until permit renewal or denial. This protection shall cease to apply if, subsequent to the completeness determination required pursuant to R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline specified in writing by the Director any additional information identified as being needed to process the application. (R307-415-7b(2))
Status: The application for permit renewal was submitted, to the DAQ, on January 11, 2022. See
status of condition I.D.1.
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I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status:

This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In Compliance – The annual emission fee was paid on August 23, 2024, before the due date of
October 4, 2024.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions
related activity is conducted, or where records are kept under the conditions of this
permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under
this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))
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I.J.2

Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In Compliance – Required records were made available and no claims of confidentiality were
made at time of the inspection and after the inspection. Marilyn Touchard (Touchard
Environmental Services, company environmental consultant), was present at time of the
inspection.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In Compliance – Reports and certifications submitted, by the facility, appeared to have
certification statements and were signed by responsible officials.

I.L Compliance Certification.

Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports):
(R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b

The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum,
the monitoring and related recordkeeping and reporting requirements in this
permit. If necessary, the permittee also shall identify any other material
information that must be included in the certification to comply with section
113(c)(2) of the Act, which prohibits knowingly making a false certification or
omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or
means designated in Provision I.L.1.b. The certification shall identify each
deviation and take it into account in the compliance certification. The certification
shall also identify as possible exceptions to compliance any periods during which
compliance is required and in which an excursion or exceedance as defined under
40 CFR Part 64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

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I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In Compliance – The July 1, 2023, through June 30, 2024, annual compliance certification was
received on July 12, 2024. It was received on time and deemed acceptable.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and
listed in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d

The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))
Status: Not Applicable – See section III of this permit.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

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I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the
emergency. (R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated.
(R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4

This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))
Status: No emergency events have been reported since the last inspection which was conducted on
March 8, 2024.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.
Status: These are statements of fact and not inspection items (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
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monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or

appropriate recordings for continuous monitoring instrumentation, and copies of
all reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c

Additional record keeping requirements, if any, are described in Section II, Special
Provisions.
Status: In Compliance – Required records were provided at time of the inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit.
(R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit
requirements including those attributable to upset conditions as defined in this
permit, the probable cause of such deviations, and any corrective actions or
preventative measures taken. Prompt, as used in this condition, shall be defined as
written notification within the number of days shown under "Enforceable Dates
and Timelines" at the front of this permit. Deviations from permit requirements
due to breakdowns shall be reported in accordance with the provisions of
R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:
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Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b

All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail
code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In Compliance – The six-month monitoring report, received January 24, 2024, for report
period July 1, 2023 – December 31, 2023, and the report received July 12, 2024, for report
period January 1, 2024 – June 30, 2024, did not list any deviations. Both reports were deemed
acceptable.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due
to expire, unless the terms and conditions of this permit have been extended
pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or
that inaccurate statements were made in establishing the emissions standards or
other terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d

Additional applicable requirements are to become effective before the renewal
date of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

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I.T.2

I.T.3
Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In Compliance – The 2023 annual emission inventory was received on April 13, 2024. The
2024 annual emission inventory will be due on April 15, 2025. See emission inventory below
and the SLEIS Database.

I.V. Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Spray Booths B-1 and B-2
Two (2) spray booths B-1 with 4 stacks and B-2 with 6 stacks. Equipped with paint arrestor filter
system for capturing overspray.

II.A.3 Non-Atomized Spray Guns
Six (6) non-atomized spray guns used in the spray booths to apply gel coat finishes. No unit-
specific applicable requirements.

II.A.4 Mixing System with Pot Mixer
Styrene resin is mixed in the mixing system equipped with a 21.6 gallon container with an
exposed surface area less the 500 square inches. No unit-specific applicable requirements.

II.A.5 Roll Out System
Roll out system. No unit-specific applicable requirements.

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II.A.6 Cleaning Operations
Three (3) Vat/Potwash systems. No unit-specific applicable requirements.

II.A.7

Natural Gas Boiler
Three (3) 0.175 MMBtu/hr natural gas boiler.
Status: In Compliance –

Plant #1:
It was verified that the unapproved water trap was enclosed at time of the inspection. There are
two spray booth stacks for spray booth #1 (item II.A.2). It was also noted that there are two non-
atomizing spray guns (item II.A.3) and an auto caster. Next, the Vat/Potwash Systems (item II.A.6)
is only used to clean the backup pot mixers. The pot mixers and Vat/Potwash System have not been
used for years. All three boilers have been removed from plant (item II.A7). Natural gas space
heaters are currently operating at the plant.

Plant #2:
Spray booth #2 (item II.A.2) and spray guns (item II.A.3) were removed from the plant before June
2021, the date the plant was put into production. The new spray booth is currently in the design
process and has not been installed to date. There is only one auto caster currently operating at the
facility. Next, the Vat/Potwash Systems (item II.A.6) is only used to clean the backup pot mixers.
The pot mixers and Vat/Potwash System have not been used for years. Natural gas space heaters
are currently operating at the plant.

See Status of conditions II.B.1.c, II.B.1.h, and II.B.2.a.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Permitted Source.

II.B.1.a Condition:

Emission of styrene from both plants combined shall be no greater than 29.52 tons per 12-month period.
[Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN133150005-17].

II.B.1.a.1 Monitoring:

Styrene emissions shall be determined on a rolling 12-month total. Based on the twentieth day of
each month, a new 12-month total shall be calculated using the data from the previous 12 months.

II.B.1.a.2 Recordkeeping:

Styrene emissions shall be determined by maintaining a record of Styrene emitting materials used
each month. The records shall include the following data for each material used:

(a) Name of the Styrene emitting material, such as; paint, adhesive, solvent, thinner, reducers,
chemical compounds, toxics, isocyanates, etc.
(b) Density of each material used (pounds per gallon).
(c) Percent by weight of Styrene in each material used.
(d) Gallons of each Styrene emitting material used each month.
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(e) The amount of Styrene emitted monthly by each material used, calculated by the following
procedure:

Styrene = (% Styrene by Weight) x (0.09) x (Density lb) x (gal consumed) x (1 ton)
(100) (gal) (2,000 lb)

(f) The total amount of Styrene emitted monthly from all materials used.
(g) The amount of Styrene reclaimed for the month shall be similarly quantified and subtracted
from the quantities calculated above, to provide the monthly total Styrene emissions.

II.B.1.a.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In Compliance – Combined Styrene emissions as of November 2024:

Pollutant Limit (Tons) Actual Emissions (Tons)
Styrene 29.52 16.67

II.B.1.b Condition:

Emission of methyl methacrylate (MMA) from both plants combined shall be no greater than 0.48 tons
per 12-month period. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in
DAQE-AN133150005-17].

II.B.1.b.1 Monitoring:

MMA emissions shall be determined on a rolling 12-month total. Based on the twentieth day of
each month, a new 12-month total shall be calculated using the data from the previous 12 months.

II.B.1.b.2 Recordkeeping:

MMA emissions shall be determined by maintaining a record of MMA emitting materials used
each month. The records shall include the following data for each material used:
(a) Name of the MMA emitting material, such as; paint, adhesive, solvent, thinner, reducers,
chemical compounds, toxics, isocyanates, etc.
(b) Density of each material used (pounds per gallon).
(c) Percent by weight of MMA in each material used.
(d) Gallons of each MMA emitting material used each month.
(e) The amount of MMA emitted monthly by each material used, calculated by the following
procedure:

MMA = (% MMA by Weight) x (0.09) x (Density lb) x (gal consumed) x (1 ton)
(100) (gal) (2,000 lb)

(f) The total amount of MMA emitted monthly from all materials used.
(g) The amount of MMA's reclaimed for the month shall be similarly quantified and subtracted
from the quantities calculated above, to provide the monthly total MMA emissions.

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II.B.1.b.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In Compliance – Combined Methyl Methacrylate (MMA) as of November 2024:

Pollutant Limit (Tons) Actual Emissions (Tons)
MMA 0.48 0.0083

II.B.1.c Condition:

Unless otherwise specified in this permit, at all times, including periods of startup, shutdown, and
malfunction, the permittee shall, to the extent practicable, maintain and operate any permitted plant
equipment, 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. [Authority granted under R307-401-8(2) [BACT];
condition originated in DAQE-AN133150005-17]

II.B.1.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.c.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.c.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In Compliance – Primary filters are changed out daily. A photo log is kept of when the paint
booth’s secondary filters are inspected and replaced. Weekly inspections of the secondary filters
are conducted on Wednesdays. If required, the filters are changed out on Thursdays. See status of
condition II.B.2.a.

II.B.1.d Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[Authority granted under 40 CFR 82.150(b); condition originated in 40 CFR 82 Subpart F]

II.B.1.d.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

14
II.B.1.d.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.d.3

Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In Compliance – Whitewater contracts Professional Heating and Air to conduct all of their heating
and air conditioning (A/C) needs. A/C are maintenanced on an as-needed basis. The company
certifies that all refrigerants, for on-site air conditioners, are maintained and serviced. One A/C
was last serviced on June 4, 2024.

II.B.1.e Condition:

The permittee shall comply with all applicable requirements in 40 CFR 63, Subpart WWWW - National
Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production including,
but not limited to, the following: all operations, including repair operations, shall meet the applicable
organic HAP emission limits and work practice standards in Table 3 and 4 of 40 CFR 63 Subpart
WWWW. The permittee shall comply with the applicable General Provisions in 40 CFR 63.1-15 as
identified in Table 15 of 40 CFR 63, Subpart WWWW. [Authority granted under 40 CFR 63.5780 -
63.5935; condition originated in 40 CFR 63 Subpart WWWW]. [40 CFR 63.5785(a), 40 CFR 63.5805(b),
40 CFR 63.5805(g), 40 CFR 63.5835(a)].

II.B.1.e.1 Monitoring:

The permittee shall perform all applicable monitoring required in 40 CFR 63.5796; 63.5797;
63.5805; 63.5810 (first paragraph), (a), (b), and (d); 63.5895(d); 63.5900(a), (a)(2)-(a)(4), and
(c); and any applicable monitoring requirements from 40 CFR 63, Subpart A -- National
Emissions Standards for Hazardous Air Pollutants: General Provisions as outlined in Table 15 of
40 CFR Subpart WWWW. The permittee shall certify, in the annual compliance statement
required in Section I of this permit, its compliance status with the applicable requirements of 40
CFR 63, Subpart WWWW.

II.B.1.e.2 Recordkeeping:

The permittee shall maintain all records required in 40 CFR 63.5915(a), (c), and (d); 63.5895(c)
and (d); 63.5920; and any applicable recordkeeping requirements from 40 CFR 63 Subpart A
General Provisions as outlined in Table 15 of 40 CFR Subpart WWWW. There are no additional
recordkeeping requirements except as outlined in Provision I.S.1 of this permit.

II.B.1.e.3

Reporting:

The permittee shall submit all reports required in 40 CFR 63.5900; 63.5905; 63.5910(a), (b), (c),
(d), (g), and (i); and any applicable reporting requirements from 40 CFR 63 Subpart A General
Provisions as outlined in Table 15 of 40 CFR Subpart WWWW. There are no additional
reporting requirements except as outlined in Section I of this permit.

Status: In Compliance – The most recent semi-annual subpart WWWW report, dated July 11, 2024, was
received on July 12, 2024, and deemed acceptable No deviations were reported.

15
II.B.1.f Condition:

For applicable requirements originating in 40 CFR 63 Subpart WWWW: At all times, including periods
of startup, shutdown, and malfunction, the permittee shall operate and maintain any affected source,
including associated air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions. During a period of startup,
shutdown, or malfunction, this general duty to minimize emissions requires that the permittee reduce
emissions from the affected source to the greatest extent which is consistent with safety and good air
pollution control practices. The general duty to minimize emissions during a period of startup, shutdown,
or malfunction does not require the permittee to achieve emission levels that would be required by the
applicable standard at other times if this is not consistent with safety and good air pollution control
practices, nor does it require the permittee to make any further efforts to reduce emissions if levels
required by the applicable standard have been achieved. Determination of whether such operation 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, review of operation and maintenance procedures, review
of operation and maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart
WWWW, 40 CFR 63 Subpart A]. [40 CFR 63.5835(c), 40 CFR 63.6(e)(1)(i)].

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.f.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance – The most recent semi-annual subpart WWWW report, dated July 11, 2024, was
received on July 12, 2024, and deemed acceptable. No deviations were reported. Subpart WWWW
is also mentioned in the current annual compliance certification received on July 12, 2024. See
status of conditions I.L and II.B.1.e.

II.B.1.g Condition:

The permittee shall store any volatile organic compound (VOC) and HAP containing materials and VOC
and HAP laden rags in covered containers except when in use. [Authority granted under R307-401-
8(1)(a) [BACT]; condition originated in DAQE-AN133150005-17]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

16
II.B.1.g.3

Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In Compliance – Currently only Acetone rags are used for cleaning the pot mixers and for wiping
tables. Rags are also used to clean up VOC and HAP containing material. No open VOC and HAP
containers or VOC and HAP laden rags were noted at time of the inspection. The rags are put in
covered containers as needed.

II.B.1.h Condition:

The permittee shall notify the Director in writing when the installation of new equipment at Plant #2 in
the affected unit has been completed and is operational, as an initial compliance inspection is required.
To ensure proper credit when notifying the Director, send your correspondence to the Director, Attn:
NSR Section.

If the installation has not been completed by September 23, 2018 for this condition, the Director shall be
notified in writing on the status of the installation. At that time, the Director shall require documentation
of the continuous installation of the operation and may revoke the AO in accordance with R307-401-18,
UAC. [Authority granted under R307-401-8 [BACT]; condition originated in DAQE-AN133150005-17]

II.B.1.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.h.2 Recordkeeping:

As applicable, the permittee shall maintain a copy of each notification required by this permit
condition in accordance with Provision I.S.1 of this permit.

II.B.1.h.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In Compliance – According to Marilyn Touchard with Touchard Environmental Services, Plant #2
has been shut down and only started to operate in June of 2021. A new pot mixer has been recently
ordered for this plant. The equipment installation notice, dated December 14, 2022, was
submitted. See status of condition II.A.

II.B.2 Spray Booths B-1 and B-2.

II.B.2.a Condition:

Visible emissions shall be no greater than 10% opacity. [Authority granted under R307-401-8(1)(a)
[BACT]; condition originated in DAQE-AN133150005-17]

II.B.2.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the external vents and particulate filters
shall be inspected weekly. Inspections shall consist of the following:

17
(a) Inspection for holes in the particulate filters.
(b) Inspection of the particulate filters to determine proper installation within the support rack.

II.B.2.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.a.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance – According to the facility, the secondary filters are checked for holes and are
changed out every Thursday (weekly). See status of condition II.B.1.c.

II.B.2.b Condition:

The spray booth shall be equipped with a set of paint arrestor filters to control particulate emission. The
filters shall be maintained and replaced according to the manufacturer's recommendations. All air exiting
the booth shall pass through this control system before being vented to the atmosphere. [Authority
granted under R307-401-8 [BACT]; condition originated in DAQE- AN133150005-17]

II.B.2.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.b.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.b.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In Compliance – See status of conditions II.B.1.c and II.B.2.a.

II.B.3 Boilers.

II.B.3.a Condition:

Visible emissions shall be no greater than 10% opacity. [Authority granted under R307-401-8(1)(a)
[BACT]; condition originated in DAQE-AN133150005-17]

II.B.3.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.a.2 Recordkeeping:

In lieu of visible emissions observations, records of fuel usage shall be maintained to demonstrate
that only natural gas is being burned.
18
II.B.3.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not Applicable – The three boilers have been removed from Plant #1. The boilers were never
installed or operated in Plant #2. Natural gas space heaters are currently operating in both Plants
#1 and #2.

II.C Emission Trading
(R307-415-6a(10))

Not Applicable to this source.

II.D Alternative Operating Scenarios
(R307-415-6a(9))

Not Applicable to this source.

II.E Source-Specific Definitions

Not Applicable to this source.

III.A SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

EMISSION INVENTORY: The 2023 Annual Emission Inventory was received on April 13, 2024. The
2024 Annual Emission Inventory will be due by April 15, 2025. See status of condition I.U.
19

PREVIOUS ENFORCEMENT
ACTIONS: May 12, 2022 (DAQC-505-22) – Warning Letter

COMPLIANCE STATUS
RECOMMENDATIONS: In Compliance with the conditions of the Title V Operating Permit #
4900257001, dated July 12, 2017, and revised July 12, 2017, at time
of the inspection.

HPV: Not Applicable.

COMPLIANCE
ASSISTANCE: Discussed the new permit that will eventually replace the current
operating Permit # 4900257001. AO DAQE-AN133150005-17, is
currently being revised to show information regarding the three
removed boilers and the natural gas space heaters that are currently in
operation at both Plants #1 and #2. See status of condition II.B.3.a.

RECOMMENDATION FOR
NEXT INSPECTION: Verify that the new permit has been issued. Inspect as usual.

ATTACHMENTS: VEO Form
Correspondence
Joe Rockwell <[e-mail]>
Stamped copies of certification
2 messages
marilyn touchard <[e-mail]>Mon, Sep 30, 2024 at 2:02 PM
To: "[e-mail]" <[e-mail]>
Sent from Yahoo Mail for iPhone
4 attachments
IMG_3279.jpg
1763K
IMG_3277.jpg
3150K
IMG_3278.jpg
2454K
12/19/24, 6:18 PM State of Utah Mail - Stamped copies of certification
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1811652606652285079&simpl=msg-f:18116526066522850…1/2
IMG_3276.jpg
3142K
Joe Rockwell <[e-mail]>Mon, Sep 30, 2024 at 3:18 PM
To: marilyn touchard <[e-mail]>
Thanks Marilyn.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/19/24, 6:18 PM State of Utah Mail - Stamped copies of certification
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1811652606652285079&simpl=msg-f:18116526066522850…2/2
Joe Rockwell <[e-mail]>
Fw: Compliance Certifications needing signature
3 messages
marilyn touchard <[e-mail]>Mon, Sep 30, 2024 at 2:06 PM
To: Joe Rockwell <[e-mail]>
Here is the complete copy of the signed reports that were submitted on July 12, 2024.
----- Forwarded Message -----
From: Brian Urry <[e-mail]>
To: marilyn touchard <[e-mail]>
Sent: Thursday, July 11, 2024 at 02:54:08 PM MDT
Subject: Re: Compliance Certifications needing signature
I will mail the EPA to the Denver office today by Certified Mail.
Brian Urry | VP of Finance
Whitewater Inc
195 S Geneva Rd. | Lindon, UT 84042
M: 801.367.1122 | O: 801.785.3555 | www.whitewaterinc.com
On Thu, Jul 11, 2024 at 9:30 AM marilyn touchard <[e-mail]> wrote:
Good Morning Brian,
I have attached the compliance certifications for your facility that require signature. Will you please have them put on
company letterhead and sign them. A copy of the reports need to be mailed via certified mail to EPA (see address on
letter to EPA). Please send me a copy of the signed documents and I can deliver them to UDAQ to ensure they are
received by the 12th as required by the permit.
Please let me know if you have any questions or concerns.
Thanks and have a great day!
Marilyn
Internal Whitewater Email
4 attachments
EPA NESHAP Compliance Cert July 2024.pdf
362K
EPA WWBS July 2024 Annual TVOP Certification Compliance Methods.pdf
475K
EPA WWBS TVOP Monitoring Report January 2024 - June 2024.pdf
386K
EPA UDAQ NESHAP Compliance Cert July 2024.pdf
360K
Joe Rockwell <[e-mail]>Mon, Sep 30, 2024 at 3:18 PM
To: marilyn touchard <[e-mail]>
Thanks Marilyn.
12/19/24, 6:16 PM State of Utah Mail - Fw: Compliance Certifications needing signature
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1811652876527107924&simpl=msg-f:18116528765271079…1/2
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Joe Rockwell <[e-mail]>Tue, Oct 1, 2024 at 5:10 PM
To: marilyn touchard <[e-mail]>
Everything looked good. So I submitted the ACC report.
For future reference:
Might want to cross reference permit conditions with ACC Report.
Don't think all the conditions in the previous years ACC report matched up with the current ACC report.
Thanks Marilyn,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/19/24, 6:16 PM State of Utah Mail - Fw: Compliance Certifications needing signature
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1811652876527107924&simpl=msg-f:18116528765271079…2/2
Joe Rockwell <[e-mail]>
Whitewater Whirlpool
3 messages
Jared Crosby <[e-mail]>Fri, Dec 6, 2024 at 10:25 AM
To: Joe Rockwell <[e-mail]>
Attached AO. 
--
Jared Crosby
Environmental Engineer | Operating Permits Section
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
Whitewater Whirlpool AO.pdf
81K
Joe Rockwell <[e-mail]>Fri, Dec 6, 2024 at 10:42 AM
To: Jared Crosby <[e-mail]>
Thanks for all the good information, Jared.
Have a good weekend,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Jared Crosby <[e-mail]>Fri, Dec 6, 2024 at 10:46 AM
To: Joe Rockwell <[e-mail]>
Thank you Joe, you as well.
12/18/24, 4:20 PM State of Utah Mail - Whitewater Whirlpool
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1817712721001821841&simpl=msg-f:18177127210018218…1/2
Jared
[Quoted text hidden]
12/18/24, 4:20 PM State of Utah Mail - Whitewater Whirlpool
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1817712721001821841&simpl=msg-f:18177127210018218…2/2
Joe Rockwell <[e-mail]>
Fw: Modify AO to remove boilers
2 messages
marilyn touchard <[e-mail]>Wed, Dec 18, 2024 at 9:52 AM
To: Joe Rockwell <[e-mail]>
Hi Joe,
Just an FYI, I sent this NOI for an AO modification request to Tad to see what else he needs for us to do to update the
approval order. I just called and left a message for him since I have not heard back from him yet. I want to make sure you
know that we are actively working to get everything finalized for the renewal.
Thank you and I will see you Friday,
Marilyn
----- Forwarded Message -----
From: marilyn touchard <[e-mail]>
To: Tad Anderson <[e-mail]>
Cc: Jared Crosby <[e-mail]>
Sent: Sunday, December 15, 2024 at 08:36:23 PM MST
Subject: Modify AO to remove boilers
Hi Tad,
I had a conversation with Jared Crosby regarding our TVOP renewal. Whitewater removed their 3 boilers many years ago
and essentially use small space heaters (nothing that would require permitting per the exemption under R307-401-10 for
heating equipment using natural gas < 5 mmbtu/hr) these units are not subject to 40 CFR 63 subpart DDDDD and are not
subject to R307-315/316 either as they are all smaller than 2 mmbtu/hr and are not boilers. Can you please let me know
what I need to submit, I have looked for specific forms under the NSR section of the UDAQ website and can't see
anything that is necessarily appropriate for these small, direct fired heating units.
I am attaching form 2 to request a modification to our existing AO to remove the 3 boilers from the AO. Will you please let
me know what other form(s) are needed to move forward with the modification so Jared can finalize our TVOP renewal.
My phone number is 801-430-1593.
Thank you,
Marilyn
WWBS NOI AO modification 12152024.pdf
294K
Joe Rockwell <[e-mail]>Wed, Dec 18, 2024 at 3:24 PM
To: marilyn touchard <[e-mail]>
Marilyn -
Thank you for taking care of the new permit requirements. Looks like we need to get in touch with Tad.
I will see you on Friday @ 10:00 am.
Joe Rockwell | Environmental Scientist
Phone: [phone]
12/18/24, 3:42 PM State of Utah Mail - Fw: Modify AO to remove boilers
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1818797801252912618&simpl=msg-f:18187978012529126…1/2

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/18/24, 3:42 PM State of Utah Mail - Fw: Modify AO to remove boilers
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1818797801252912618&simpl=msg-f:18187978012529126…2/2