DAQ-2025-000165

1
DAQC-CI142250001-24
Site ID 14225 (B1)

MEMORANDUM

TO: FILE – ACTION TARGET INC. – Firearms Training Equipment Manufacturing
Site #2

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: November 27, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: June 13, 2024

SOURCE LOCATION: 3411 South Mountain Vista Parkway
Provo, UT 84606
SOURCE CONTACTS: Alan Holt, Facilities & Maintenance Manager
801-705-9122 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection

PROCESS DESCRIPTION: Manufactures metal firearm targets and related products for the
military, law enforcement, and general consumer use. Painting is
accomplished primarily by spraying with air assisted airless
spray paint guns. Some components are dipped. A shot blast
booth finishes metal prior to painting. The paint area is equipped
with two filter bank walls on either side of the conveyor line.
The filters are changed as needed based on pressure readings.
The paint filter banks vent externally. Several air cleaners on the
second floor are vented within the interior of the structure.
Welding tables, practice range air, area cleaners, and a shot blast
booth air cleaners are vented into the building. A plasma cutter
(burn table) is vented to an external baghouse. A small natural
gas generator is used for emergency purposes.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN142250003-18, dated
November 13, 2018
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines,
NSPS (Part 60) A: General Provisions,
MACT (Part 63) -A: General Provisions,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines

* - ) - # )
2
SOURCE EVALUATION:

Name of Permittee: Permitted Location:
Action Target Inc. – Firearms Training Equipment
Manufacturing Site #2

1281 West 220 North
P.O. Box 636
3411 South Mountain Vista Parkway
Provo, UT 84606
Provo, UT 84601

SIC Code: 3449: (Miscellaneous Structural Metal Work)

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 R307-150 Series. Inventories, Testing and Monitoring. [R307-150]
I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns have occurred since the previous inspection. No limits have been exceeded. No unapproved equipment was observed at the time of inspection. The source submitted their 2023 Emission Inventory and was notified of the submission’s requirements going forward. See the attachments section for additional information.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Action Target Manufacturing
II.A.2 Painting Room Controls: Filters
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II.A.3 One (1) Dip tank Control: Tank Cover

II.A.4 Two Burn Tables Control: 2 M-36 industrial Air Cleaners

II.A.5 Welding Booths Control: Dust Collectors

II.A.6 Abrasive Blaster * Control: Baghouse

II.A.7 One (1) Emergency Engine* Rating: 362 hp
Fuel: Natural Gas
Manufacturer Date: Post-2010
NSPS Applicability: Subpart JJJJ
MACT Applicability: Subpart ZZZZ

II.A.8 Shooting Ranges
Control: Baghouse

II.A.9 One (1) Wood Shop*
Control: Baghouse
Vents Internally

II.A.10 Parts Washer*

II.A.11 Foam-in-Place Unit*
MACT Applicability: Subpart OOOOOO

Included for informational purposes

* Denotes New Equipment

Status: In Compliance. No unapproved equipment was observed at the time of inspection.
Additional information obtained at the time of inspection include:

II.A.3 One (1) Dip Tank - the dip tank has been removed from the site as it is no
longer part of the source’s operations.

Additional information carried over from previous inspections include:

II.A.4. – Two (2) Burn Tables – The referenced, 2 M-36 Industrial Air Cleaners are
mounted above each of the two burn tables and are used solely for cleaning indoor
air. They do not vent externally. One of the burn tables is a water burn table and
creates no emissions. The other burn table is a downdraft burn table with emissions
being collected on the side of the unit before being vented to a Messer Cuttings
Systems spark arrestor followed by an externally venting baghouse that is controlled
by a Farr Dust Collector Controller equipped with a magnehelic gauge.

II.A.5 – Welding Booth – The source currently operates eight welding booths. Each
welding booth’s emissions are controlled at the welding point using adjustable smoke
collector arms which feed into an internally-venting baghouse. There are no
externally-venting emissions associated with this equipment.

II.A.6 – Abrasive Blaster – This is a fully-enclosed Metfin brand blaster that is
controlled by an internally-venting baghouse. There are no externally-venting
emissions associated with this equipment.
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II.A.7 – One (1) Emergency Engine – This generator engine is located on the west side of the building. The engine is a natural-gas fired Ford WSG-1068 6.8L-V10, 362
hp, manufactured post-2010. Specifications were included in the 2018 NOI and can
be found in the source file under DAQ-2018-016401. The generator is a Marelli-brand. The unit is equipped with a DynaGen control panel which has a
non-resettable hour meter.
II.A.8 – Shooting Ranges – Emissions associated with the shooting ranges are vented
through lead-removing filters before being vented to an internally vented baghouse.
There are no externally venting emissions associated with the ranges.
II.A.11 – Foam-in-Place Unit – There are three Speedy Packer Insight SPS-5461
model foam units in use at the source location. All three are fully enclosed, do not vent externally, and produce packing foam. Information provided as part of the NOI
(DAQ-2018-016401) indicates that a single unit is capable of emitting less than 1 lb.
of HAPs annually.

II.B Requirements and Limitations

II.B.1 Sitewide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive
emission source on site to exceed 10% opacity. [R307-306-4, 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. [R307-201-3]
Status: In Compliance. No visible emissions were observed at the time of inspection. See the
attached VEO form for additional information.
II.B.1.b The owner/operator shall vent all emissions from the wood shop, shooting ranges, and abrasive
blaster to the applicable baghouse before being discharged to the atmosphere. [R307-401-8]
Status: In Compliance. All emissions from the wood shop, shooting range, and abrasive
blasting units are vented through a baghouse before discharging internally. They do not vent to the atmosphere.

II.B.1.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse
shall be between 3.0 to 7.0 inches of water column. [R307-401-8]
II.B.1.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. The pressure gauge shall measure the pressure drop in one (1)-inch water column
increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8]

Status: In Compliance. The baghouse readings at the time of inspection were 5.2 inches of
water column for the welding booth and 0 for the shooting ranges and wood shop.
Reviewing records indicate that the baghouse stayed within the ranges of 3-7 and read 0 on
days where the baghouse was not utilized, or maintenance was being conducted on the
baghouse. The baghouses are equipped with technology that self-calibrates the gauges
when required. They are calibrated annually, and the gauges are checked monthly. The
baghouse pressure gauges are recorded daily and stored in a log. This information was
obtained and viewed onsite during the inspection. The only baghouse that vents externally
is the baghouse for equipment II.A.4. The rest of the baghouses vent internally.

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II.B.2 Painting Requirements and Limitations
II.B.2.a The plant-wide emissions of VOC and HAPs from the painting operations shall not exceed:
A. 13.63 tons per rolling 12-month total for VOCs
B. 8.96 tons per rolling 12-month total for Xylene
C. 500 lbs per rolling 12-month total for all other HAPs combined. [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.
The VOC or HAP emissions shall be determined by maintaining a record of VOC or HAP emitting
materials used each month. The record shall include the following data for each material used:
A. Name of the VOCs or HAPs emitting material, such as: paint, solvent, thinner, etc.

B. Density of each material used (pounds per gallon)

C. Percent by weight of all VOC or HAP in each material used

D. Gallons of each VOC or HAP emitting material used

E. The amount of VOC or HAP emitted monthly by each material used shall be calculated
by the following procedure:

VOC = (% VOC by weight/100) x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb)
HAP = (% HAP by weight/100) x [Density (lb/gal)] x Gal Consumed x (1 ton/2000 lb)

F. The amount of VOC or HAP emitted monthly from all materials used

The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC or HAP
emissions. [R307-401-8]

Status: In Compliance. The rolling 12-month emission totals from June 2023 to May 2024,
for VOC, xylene, and all HAPs combined are as follows:

0.22 tons of VOCs emitted
0.4 tons of all HAPs combined emitted
0 tons of xylene emitted

Action Target has removed the dip tanks from their site, as well as changing the paints that
are utilized on site. Xylene has been removed from the products they use and they are
utilizing water-based paints that do not contain VOCs. Emissions are calculated following
the formulas established in the AO. Information about VOCs from Action Target’s paint
supplier was viewed onsite at the time of inspection. See the attachments section for
additional information regarding the VOC spreadsheet and SDS for the new paints.

II.B.2.b The owner/ operator shall ensure all dip tanks are covered when not in use.
[R307-350-7, R307-401-8]

Status: Not Applicable. The dip tanks are no longer used as part of the operations and have
been removed from the facility.

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II.B.2.c The owner/operator shall equip the painting room with particulate filters. All emissions from spray painting operations shall pass through this control system before being vented to the atmosphere.
[R307-401-8]
Status: In Compliance. Particulate filters are installed on the paint room and emissions pass
through a control system before exiting the facility.
II.B.2.d The owner/ operate shall employ the following work practices at all times to reduce VOC
emissions:
A. All VOC-containing coatings, thinners, and coating-related waste materials shall be
stored in closed containers
B. Ensure that mixing and storage containers used for VOC-containing coatings, thinners,
and coating-related waste material are kept closed at all times except when depositing or
removing these materials, unless a container has activated carbon or other control method
approved by the EPA Administrator;

C. Minimize spills of VOC-containing coatings, thinners, and coating-related waste materials

D. Convey VOC-containing coatings, thinners, and coating-related waste materials from
one location to another in closed containers, containers with activated carbon or other
control method approved by the EPA Administrator

E. Minimize VOC emission from cleaning of application, storage, mixing, and conveying
equipment by ensuring that equipment cleaning is performed without atomizing the
cleaning solvent and all spent solvent is captured in closed container. [R307-350-7]

Status: In Compliance. The workplace practices listed in this section of the AO were
observed to be followed at the time of inspection. All VOC-containing materials were stored
in closed containers.

II.B.2.e The owner/operator shall comply with the VOC Content Limits for metal parts and products
coating operations as listed in R307-350-5. [R307-350-5]

II.B.2.e.1 Compliance shall be based on material SDS sheets and inventory reports. [R307-350]

Status: In Compliance. All VOC content limits and rules established in R307-350 are
followed by the source. The source has changed their paints to no longer include xylene.
They have also switched to water-based paints that no longer include VOCs. Information
from Action Target’s paint supplier about the VOC content of the new paint was viewed
onsite at the time of inspection. See the attachments section for additional information about
the new paints SDS.

II.B.3 Emergency Engine Requirements

II.B.3.a The owner/operator shall not operate the emergency engine on site for more than 100 hours
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

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II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months.
Records documenting the operation of the emergency engine shall be kept in a log and shall
include the following:
A. The date the engine was used
B. The duration of operation in hours

C. The reason for the emergency engine's usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]
Status: In Compliance. The rolling 12-month total from June 2023 to May 2024, for
generator hours is as follows:
16 hours of run time.

Generator hours stored in a log that contains the date, duration, and reason the generator
was used. The generator has a non-resettable meter installed on it. This record was viewed
at the time of inspection.

II.B.3.b The owner/operator shall only use natural gas as fuel in the emergency engine. [R307-401-8]

Status: In Compliance. The generator only operates on natural gas and no other fuel
source.

II.B.3.c Regardless of construction, reconstruction, or modification date, the emergency engine on site
shall comply with the emission standards listed in 40 CFR 60 Subpart JJJJ. [40 CFR 60 Subpart
JJJJ, R307-401-8]

II.B.3.c.1 The owner/operator shall maintain documentation demonstrating that the emergency engine on
site meets the emission standards contained in 40 CFR 60 Subpart JJJJ for emergency engines.
[40 CFR 60 Subpart JJJJ, R307-401-8]

Status: In Compliance. The source maintains the documentation about the emission
standards and specifications for the emergency generator onsite. This was viewed onsite at
the time of inspection.

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) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Status: In Compliance. The 362 hp generator applies to this subpart. The generator operated under 100
hours within the last rolling 12-month period, operating for 16 hours. A non-resettable meter is installed
on the generator and is only operated with natural gas. No diesel fuel is utilized in the generator. The
generator is maintained according to the manufacturer's specifications.
NSPS (Part 60) A: General Provisions

Status: In Compliance. Compliance with subpart A is determined by compliance with applicable federal
subparts. In compliance with Subpart JJJJ.

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MACT (Part 63) -A: General Provisions

Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable federal
subparts. In Compliance with Subpart ZZZZ.
MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. See status of NSPS (Part 60) JJJJ for compliance information regarding the
generator onsite.

MACT (Part 63) -OOOOOO: National Emissions Standards for Hazardous Air Pollutants for flexible
Polyurethane Foam Production and Fabrication Area Sources

Status: Not Applicable. The Foam-In-Place Unit, II.A.11, is incorrectly identified as being subject to
Subpart OOOOOO. This piece of equipment is not subject to this rule.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This area source rule is applicable to Subpart JJJJ. See Section III for
compliance information.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. The state rule applies to applicable federal subparts. Subpart ZZZZ applies
to this state rule. See status of Subpart ZZZZ for compliance information.
Solvent Cleaning [R307-304]

Status: Not Applicable. Source is currently exempt from R307-304. Source uses acetone for cleaning,
which is an exempt solvent.
Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. Compliance with R307-305 is determined by compliance with AO condition
II.B.1.a.

PM10 Nonattainment and Maintenance Areas: Abrasive Blasting [R307-306]

Status: In Compliance. Compliance with this rule is satisfied by AO condition II.B.1.a. It is also
satisfied by conducting abrasive blasting in an enclosed space and venting to an internally-venting
baghouse.
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. Compliance with R307-325 is determined by compliance with AO condition
II.B.2.d.

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Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. The source operates a Safety Brand parts washer. At the time of inspection
the machine was not in use and the lid was closed.
Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. Compliance with R307-350 is determined by compliance with AO conditions
II.B.2.d, II.B.2.e, and II.B.2.e.1.

EMISSION INVENTORY:

Listed below are the Actual Emissions Inventory provided from Action Target Inc. – Firearms Training
Equipment Manufacturing Site #2. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN142250003-18, dated November 13, 2018, is provided. The 2023 Emission Inventory is listed
below and can be found in the attachments section. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 651.58
Carbon Monoxide 0.23 0.27
Nitrogen Oxides 3.55 1.48
Particulate Matter - PM10 5.93 2.91
Particulate Matter - PM2.5 5.92 2.91
Sulfur Dioxide 0.00
Volatile Organic Compounds 13.95 0.15

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Total HAPs (CAS #THAPS) 182
Xylenes (Isomers And Mixture) (CAS #1330207) 17912

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN142250003-18,
dated November 13, 2018: In compliance with the conditions
listed within this AO. The facility is well maintained, and
records were made available upon request on site or via email.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the usual frequency.

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NSR RECOMMENDATIONS: The source has removed the dip tank from II.A.3. That
equipment is no longer part of their source operations.
The source indicated there were plans to add another spray booth
in the future. The permitting process was reviewed
and the source was referred to work with NSR.

Evaluate the following equipment/AO conditions as follows
during the next AO modification:

• II.A.4 – See status of this equipment in Section II.A for
additional information.

• II.A.11 – The source operates three of these units.
Evaluate removal of Subpart OOOOOO applicability.
See status of Subpart OOOOOO in Section III for
additional information.

• II.B.1.b. – Edit this condition as all equipment
referenced vents internally.

• II.B.1.c – This condition is only applicable to the single,
externally-venting baghouse associated with II.A.4. The
source indicated the manufacturer’s specified pressure
drop range differs from the 3.0 to 7.0 inches of water
column currently referenced.

ATTACHMENTS: Applicable Supporting Documentation Included.
2020 Emissions Inventory Report
Action Target Inc. Firearms Training Equipment Manufacturing Site #2 (14225)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)6.7459 <.00001 6.7459
PM10-FIL PM10 Filterable 6.72594 <.00001 6.72594
PM25-PRI PM2.5 Primary (Filt + Cond)6.7355 <.00001 6.7355
PM25-FIL PM2.5 Filterable 6.72594 <.00001 6.72594
PM-CON PM Condensible 0.00956 <.00001 0.00956
NOX Nitrogen Oxides 1.92933 <.00001 1.92933
VOC Volatile Organic Compounds 5.38634 <.00001 5.38634
CO Carbon Monoxide 0.351 <.00001 0.351

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
2023 Emissions Inventory Report
Action Target Inc. Firearms Training Equipment Manufacturing Site #2 (14225)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)2.9141 <.00001 2.9141
PM10-FIL PM10 Filterable 2.90675 <.00001 2.90675
PM25-PRI PM2.5 Primary (Filt + Cond)2.9141 <.00001 2.9141
PM25-FIL PM2.5 Filterable 2.90675 <.00001 2.90675
PM-CON PM Condensible 0.00735 <.00001 0.00735
SO2 Sulfur Dioxide 0.0003 <.00001 0.0003
NOX Nitrogen Oxides 1.4841 <.00001 1.4841
VOC Volatile Organic Compounds 0.1545 <.00001 0.1545
CO Carbon Monoxide 0.27 <.00001 0.27
NH3 Ammonia 0.009 <.00001 0.009

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
Jordan Garahana <[e-mail]>
Requested documents as per site inspection on 6-13-2024
6 messages
Alan Holt <[e-mail]>Fri, Jun 14, 2024 at 11:45 AM
To: "[e-mail]" <[e-mail]>
Cc: Steven Williams <[e-mail]>
Jordan
Here are the documents that you requested yesterday during your inspection at Action Target Inc. If I have
missed any or if you have any more questions, please let me know.
Thanks Alan Holt

Alan Holt Facilities & Maintenance Manager-Office#: 801-705-9122 [e-mail]

7 attachments
45872 Action Target Gray Primer.pdf
774K
45873 Action Target Black Primer.pdf
696K
45874 Action Target ATI Blue Semi Gloss.pdf
686K
45875 Action Target Green Primer.pdf
665K
45876 Action Target Genesis Gray Primer.pdf
666K
5569 Raptor Protective Coating-Black Base.pdf
1872K
Rolling VOCs and HAPs January 2023 - May 2024.xlsx
20K
Jordan Garahana <[e-mail]>Fri, Jul 19, 2024 at 7:56 AM
To: Alan Holt <[e-mail]>
Hey Alan,
12/23/24, 9:49 AM State of Utah Mail - Requested documents as per site inspection on 6-13-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1801859492653135723&simpl=msg-f:180185949265313572…1/3
I have one thing I need in order for me to complete my inspection. I need you to submit your 2023 Emission Inventory that
was due on April 15 of this year. Please submit that as soon as possible and let me know when you have submitted it.
Thanks,
Jordan Garahana
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Alan Holt <[e-mail]>Fri, Jul 19, 2024 at 8:03 AM
To: Jordan Garahana <[e-mail]>
Jordan this is the emission inventory report from January of 2023 thru May 2024. There are to sheets on the
report. Let me know if this is correct.

Alan Holt Facilities & Maintenance Manager-Office#: 801-705-9122 [e-mail]

From: Jordan Garahana <[e-mail]>
Sent: Friday, July 19, 2024 7:56 AM
To: Alan Holt <[e-mail]>
Subject: Re: Requested documents as per site inspecon on 6-13-2024

Exercise Caution: This email originated from outside our organization. DO NOT click on any images, links, or open any
attachments, unless you have verified the sender and determined the content is safe.
[Quoted text hidden]
12/23/24, 9:49 AM State of Utah Mail - Requested documents as per site inspection on 6-13-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1801859492653135723&simpl=msg-f:180185949265313572…2/3
This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report this email as spam.
Rolling VOCs and HAPs January 2023 - May 2024.xlsx
20K
Jordan Garahana <[e-mail]>Fri, Jul 19, 2024 at 8:33 AM
To: Alan Holt <[e-mail]>
Hey Alan,
The Emission Inventory is submitted through SLEIS. The last one that Action Target submitted was for 2020, in 2021.
Here is a copy of the one that was submitted in 2021. Please let me know if you have any questions.
Thanks,
Jordan
[Quoted text hidden]
P_SR_TOTAL_EMIS_BY_SRC_20240719_0832.pdf
29K
Alan Holt <[e-mail]>Fri, Jul 19, 2024 at 9:12 AM
To: Jordan Garahana <[e-mail]>
Ok I will get that done. thanks
[Quoted text hidden]
Jordan Garahana <[e-mail]>Mon, Dec 23, 2024 at 9:49 AM
To: Alan Holt <[e-mail]>
Hey Alan,
Since it is the end of the year, I was told to remind you of the requirements of submitting the Emission Inventory for your
facility since yours wasn't submitted on time. It is currently supposed to be submitted every 3 years, so the next
submission will be in 2027 for the year of 2026. Please let me know if you have any questions.
Thanks,
Jordan
[Quoted text hidden]
12/23/24, 9:49 AM State of Utah Mail - Requested documents as per site inspection on 6-13-2024
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1801859492653135723&simpl=msg-f:180185949265313572…3/3
Part Number Description
1014 2541N-Primer - Black-Being phased out
1015 2897-Primer - Gray - Being phased out
1036 474-Xylene Substitute - Being phased out
5569 Raptor Liner-Black
19438 3 parts 2217-Epoxy-Blue/1 part 2013-Epoxy-catalyst - Being phased out
19439 3 parts 2057-Epoxy - Slate Gray/1 part 2013-Epoxy-catalyst - Being phased out
24214 2242-Primer - Blue - Being phased out
24683 840-Acetone
45872 Action Target Gray Primer
45873 Action Target Black Primer
45874 Action Target Blue Semi Gloss
45875 Action Target Green Primer
45876 Action Target Genesis Gray Primer
Total Lbs.
Total Tons
Part Number Description
1014 2541N-Primer - Black-Being phased out
1015 2897-Primer - Gray - Being phased out
1036 474-Xylene Substitute - Being phased out
5569 Raptor Liner-Black
19438 3 parts 2217-Epoxy-Blue/1 part 2013-Epoxy-catalyst - Being phased out
19439 3 parts 2057-Epoxy - Slate Gray/1 part 2013-Epoxy-catalyst - Being phased out
24214 2242-Primer - Blue - Being phased out
24683 840-Acetone
45872 Action Target Gray Primer
45873 Action Target Black Primer
45874 Action Target Blue Semi Gloss
45875 Action Target Green Primer
45876 Action Target Genesis Gray Primer
Total HAPs' by wt.
Part Number Description
1014 2541N-Primer - Black-Being phased out
1015 2897-Primer - Gray - Being phased out
1036 474-Xylene Substitute - Being phased out
5569 Raptor Liner-Black
19438 3 parts 2217-Epoxy-Blue/1 part 2013-Epoxy-catalyst - Being phased out
19439 3 parts 2057-Epoxy - Slate Gray/1 part 2013-Epoxy-catalyst - Being phased out
24214 2242-Primer - Blue - Being phased out
Total VOCs'
Total HAPs'
Total Xylene
24683 840-Acetone
45872 Action Target Gray Primer
45873 Action Target Black Primer
45874 Action Target Blue Semi Gloss
45875 Action Target Green Primer
45876 Action Target Genesis Gray Primer
Total xylene by wt.
Xylene by tons
Feb 22 - Jan 23 March 22 - Feb 23 April 22 - March 23 May 22 - April 23
654.43 534.13 293.53 293.53
500.94 12.10 12.10 12.10
0.00 0.00 0.00 0.00
210.60 208.00 169.00 143.00
834.00 861.00 831.00 831.00
59.98 59.98 29.99 29.99
36.21 24.14 24.14 24.14
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
2296.16 1699.35 1359.76 1333.76
1.15 0.85 0.68 0.67
Feb 22 - Jan 23 March 22 - Feb 23 April 22 - March 23 May 22 - April 23
1.08 0.88 0.48 0.48
0.83 0.02 0.02 0.02
0.00 0.00 0.00 0.00
0.09 0.09 0.07 0.06
0.81 0.83 0.80 0.80
0.07 0.07 0.03 0.03
0.06 0.04 0.04 0.04
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
2.93 1.93 1.45 1.44
Feb 22 - Jan 23 March 22 - Feb 23 April 22 - March 23 May 22 - April 23
0.52 0.42 0.23 0.23
0.49 0.01 0.01 0.01
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.40 0.42 0.40 0.40
0.03 0.03 0.02 0.02
0.03 0.02 0.02 0.02
Formula: VOC content x Usage =
Formula: % of Haps' in product / 100 x Density x Usage =
Formula: % of Xylene in product / 100 x Density x Usage =
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
1.48 0.90 0.68 0.68
0.00 0.00 0.00 0.00
June 22 - May 23 July 22 - June 23 Aug 22 - July 23 Sept 22 - Aug 23
12.03 0.00 120.30 120.30
12.10 0.00 0.00 0.00
0.00 0.00 0.00 0.00
143.00 130.00 122.20 137.80
825.00 771.00 759.00 669.00
29.99 29.99 29.99 29.99
24.14 24.14 24.14 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
1046.26 955.13 1055.63 957.09
0.52 0.48 0.53 0.48
June 22 - May 23 July 22 - June 23 Aug 22 - July 23 Sept 22 - Aug 23
0.02 0.00 0.20 0.20
0.02 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.06 0.05 0.05 0.06
0.80 0.75 0.73 0.65
0.03 0.03 0.03 0.03
0.04 0.04 0.04 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.97 0.87 1.06 0.94
June 22 - May 23 July 22 - June 23 Aug 22 - July 23 Sept 22 - Aug 23
0.01 0.00 0.09 0.09
0.01 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.40 0.37 0.37 0.32
0.02 0.02 0.02 0.02
0.02 0.02 0.02 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.46 0.41 0.50 0.44
0.00 0.00 0.00 0.00
Oct 22 - Sept 23 Nov 22 - Oct 23 Dec 22 - Nov 23 Jan 24 - Dec 23
120.30 120.30 120.30 120.30
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
176.80 148.20 158.60 101.40
558.00 363.00 363.00 297.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
855.10 631.50 641.90 518.70
0.43 0.32 0.32 0.26
Oct 22 - Sept 23 Nov 22 - Oct 23 Dec 22 - Nov 23 Jan 24 - Dec 23
0.20 0.20 0.20 0.20
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.07 0.06 0.07 0.04
0.54 0.35 0.35 0.29
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.81 0.61 0.62 0.53
Oct 22 - Sept 23 Nov 22 - Oct 23 Dec 22 - Nov 23 Jan 24 - Dec 23
0.09 0.09 0.09 0.09
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.27 0.18 0.18 0.14
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.37 0.27 0.27 0.24
0.00 0.00 0.00 0.00
Part Number Description
1014 2541N-Primer - Black-Being phased out
1015 2897-Primer - Gray - Being phased out
1036 474-Xylene Substitute - Being phased out
5569 Raptor Liner-Black
19438 3 parts 2217-Epoxy-Blue/1 part 2013-Epoxy-catalyst - Being phased out
19439 3 parts 2057-Epoxy - Slate Gray/1 part 2013-Epoxy-catalyst - Being phased out
24214 2242-Primer - Blue - Being phased out
24683 840-Acetone
45872 Action Target Gray Primer
45873 Action Target Black Primer
45874 Action Target Blue Semi Gloss
45875 Action Target Green Primer
45876 Action Target Genesis Gray Primer
Total Lbs.
Total Tons
Part Number Description
1014 2541N-Primer - Black-Being phased out
1015 2897-Primer - Gray - Being phased out
1036 474-Xylene Substitute - Being phased out
5569 Raptor Liner-Black
19438 3 parts 2217-Epoxy-Blue/1 part 2013-Epoxy-catalyst - Being phased out
19439 3 parts 2057-Epoxy - Slate Gray/1 part 2013-Epoxy-catalyst - Being phased out
24214 2242-Primer - Blue - Being phased out
24683 840-Acetone
45872 Action Target Gray Primer
45873 Action Target Black Primer
45874 Action Target Blue Semi Gloss
45875 Action Target Green Primer
45876 Action Target Genesis Gray Primer
Total HAPs' by wt.
Part Number Description
1014 2541N-Primer - Black-Being phased out
1015 2897-Primer - Gray - Being phased out
1036 474-Xylene Substitute - Being phased out
5569 Raptor Liner-Black
19438 3 parts 2217-Epoxy-Blue/1 part 2013-Epoxy-catalyst - Being phased out
19439 3 parts 2057-Epoxy - Slate Gray/1 part 2013-Epoxy-catalyst - Being phased out
Total VOCs'
Total HAPs'
Total Xylene
24214 2242-Primer - Blue - Being phased out
24683 840-Acetone
45872 Action Target Gray Primer
45873 Action Target Black Primer
45874 Action Target Blue Semi Gloss
45875 Action Target Green Primer
45876 Action Target Genesis Gray Primer
Total xylene by wt.
Xylene by tons
Feb 23 - Jan 24 March 23- Feb 24 April 23 - March 24 May 23- April 24
120.30 120.30 120.30 120.30
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
153.40 169.00 169.00 169.00
297.00 225.00 141.00 141.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
570.70 514.30 430.30 430.30
0.29 0.26 0.22 0.22
Feb 23 - Jan 24 March 23- Feb 24 April 23 - March 24 May 23- April 24
0.20 0.20 0.20 0.20
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.06 0.07 0.07 0.07
0.29 0.22 0.14 0.14
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.55 0.49 0.41 0.41
Feb 23 - Jan 24 March 23- Feb 24 April 23 - March 24 May 23- April 24
0.09 0.09 0.09 0.09
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.14 0.11 0.07 0.07
0.00 0.00 0.00 0.00
Formula: VOC content x Usage =
Formula: % of Haps' in product / 100 x Density x Usage =
Formula: % of Xylene in product / 100 x Density x Usage =
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.24 0.20 0.16 0.16
0.00 0.00 0.00 0.00
June 23- May 24 July 23 - June 24 Aug 23 - July 24 Sept 23 - Aug 24
120.30
0.00
0.00
208.00
117.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
445.30
0.22
June 23- May 24 July 23 - June 24 Aug 23 - July 24 Sept 23 - Aug 24
0.20
0.00
0.00
0.09
0.11
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.40
June 23- May 24 July 23 - June 24 Aug 23 - July 24 Sept 23 - Aug 24
0.09
0.00
0.00
0.00
0.06
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.15
0.00
Oct 23- Sept 24 Nov 23 - Oct 24 Dec 23 - Nov 24 Jan 23- Dec 24
Oct 23- Sept 24 Nov 23 - Oct 24 Dec 23 - Nov 24 Jan 23- Dec 24
Oct 23- Sept 24 Nov 23 - Oct 24 Dec 23 - Nov 24 Jan 23- Dec 24