DAQ-2025-001969

Tesoro Logistics Operations LLC
March 4,2025
Utah Division of Air Quality
Attn: Bryce Bird
195 North 1950 West
P.O. Box 144820
salt Lake city, Utah 84116
40 CFR 53 Subpart A and CC Periodic Reports
539 South Main Street
Findtay, OH 45840
Tel: [phone]
Vn Ovrnrurexr Mntl
Tesoro Logistics Operations. LLC. Salt Lake City Truck Loading Rack
Dear Mr. Bird:
Please find enclosed the periodic report for Tesoro Logistics Operations, LLC, Salt Lake City Truck Loading
Rack (herein referred to as Tesoro Logistics) covering the time period between July 15, 2024 and January
14,2025. This report includes the periodic report in accordance with 40 CFR 63.654,40 CFR 53.10 and
Table 6 - General Provisions Applicability to Subpart CC in the Appendix to Subpart CC - Tables. Please
note,the assets located atthe RemoteTank Farm are included inthe periodic reportforthe refinery
assets submitted by Tesoro Refining and Marketing Company.
I certify under penalty of law that, based on information and belief formed after reasonable inquiry, the
statements and information contained in the startup, shutdown, and malfunction repoft are true, accurate,
and complete.
lf you have additional questions or require more information, please contact Tina Harper at615-499-1641
or at [e-mail].
Sincerely,
Vice President
Health, Environmental, Safety, and Security
Logistics & Storage Terminals
Attachment: PERIODIC EXCESS EMISSION AND STARTUP, SHUTDOWN, MALFUNCTION REPORT
UTAH DEPARTMENT OF
ENVIRONMENTAT QUALIry
DI',/ISION OF AIR QUALITY
B-2-15659
USEPA Region Vlll
1595 Wynkoop Street
Mail Code ENF-AT
Denver, CO 80202-1129
VIA OvERNIGHT MAIt
PERIODIC EXCESS EMISSION AND STARTUP,
SHUTDOWN, MALFUNCTION REPORT
REFINERY MACT (40 CFR 63 Subpaft CC)
Reporting Period:
July 15, 2024 - tanuary 14,2025
Tesoro Logistics Operations, LLC
Salt Lake City Truck Loading Rack
475 West 900 North
Salt Lake City, Utah 84103
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Periodic Excess Emission Report
Morch 2025
Contents
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
List of Tobles
Gasoline Loading Rack Periodic Report pertaining to Tank Trucks or Cargo Tanks
563.6ss(b), 63.a28(gx1),63.428(h)(2) & (3).... .... .........11
Gasoline Loading Rack Periodic Report pertaining to Monitoring $63.65a(b), 63.428(hxl)
Group 1 lnternal Floating Roof Annual (visual hatch) lnspections Conducted During the
Reporting Period 563.655(g)(2)(i) ... .......... .....................13
Group 1 lnternal Floating Roof lnternal lnspections Conducted During the Reporting
Group 1 lnternal Floating Roof lnternal lnspections Conducted During the Reporting
Group 1 Floating Roof lnspections Conducted During the Reporting Period
Pressure Relief Devices in OHAP gas or vapor service subject to 563.648()(1).......................17
Pressure Relief Devices in OHAP gas or vapor service subject to 563.6480(2).......................18
Notification of Compliance Status Update - Storage Vessels......... .......................19
Notification of Compliance Status Update - Miscellaneous Process Vents..............................20
Notification of Compliance Status Update - Pressure Relief Devices.........................................21
List of Attochments
Attachment A - Secondary Seal Gap Calculations
Attachment B - Primary Seal Gap Calculations
1.0 563.655 Subport CC Periodic Reporting
Pursuant to 563.655(e), the following section contains the required information specified in paragraphs (a)
through (g) in 563.655. Each specified requirement is identified in bold teK and Tesoro Logistics'response
is provided information is in non-bold text.
This compliance report covers the period beginning on the compliance date for this affected source, July
15,2024 through January 14,2025.
l.l $6s.6ss(o)
Each owner or operator subject to the wastewater provisions in 953.547 shall comply with the
recordkeeping and reporting provisions in 9961.355 and 51.357 of 40 CFR part 61, subpart FF
unless they are complying with the wastewater provisions specified in paragraph (o)(2)(ii) of
563.640. There are no additional reporting and recordkeeping requirements for wastewater under
this subpart unless a wastewater stream is included in an emissions average. Recordkeeping and
reporting for emissions averages are specified in 563.653 and in paragraphs (0(5) and (g)(8) of this
section.
The requirements of 40 CFR 63.655(a) applyto the entlre Tesoro "Facility" (includes the Truck
Loading Rack, Refinery, and Remote Tank Farm) in accordance with 40 CFR 63.655(a). The Tesoro
"Facility" complieswith the annual reporting provisions in 561.357 of 40 CFR part 61, and Logistics
source is included in the report for Tesoro Refining and Marketing Company. There are no
additronal reporting requirements for wastewater under 40 CFR 63 Subpart CC.
Under 40 CFR 61.357(c), if the total annual benzene quantity from facility waste is less than 10
Mg/yr but is equal to or greater than 1 Mg/yr, then the owner or operator shall submit to the
Administrator one of the following, as appropriate:
1.A report that updates the information listed in paragraphs 561.357(a) ('l) through (a)(3) of this
section. The report is to be submitted annually and whenever there is a change in the process
generating the waste stream that could cause the total annual benzene quantity from facility
waste to increase to '1 0 Mg/yr or more, or
lf the information in the annual report required by 561.357(a)(1)through (a)(3) is not changed
in the following year, the owner or operator may submit a statement to that effect.
A separate report regarding the TAB is submitted in accordance with 551.357(c) by Tesoro
Refining and Marketing Company, that include the Logistics' assets.
1.2 $63.6ss(b)
Each owner or operator subject to the gasoline loading rack provisions in 553.650 shall comply with
the recordkeeping and reporting provisions in 563.428 (b) and (c), (g)(1), (h)(1) through (h)(3), and
(k) of subpart R. These requirements are summarized in table 4 of this subpart. There are no
2.
additional reporting and recordkeeping requirements for gasoline loading racks under this subpart
unless a loading rack is included in an emissions average. Recordkeeping and reporting for
emissions averages are specified in 563.653 and in paragraphs (0(5) and (g)(8) of this section.
The following information is found in Table '1.
o Each loading of a gasoline cargo tank for which vapor tightness documentation had not
been previously obtained by the facility; t563.a28(g)(1)l
Each instance of a nonvapor-tight gasoline cargo tank loading at the facility in which the
owner or operator failed to take steps to assure that such cargo tank would not be
reloaded at the facility before vapor tightness documentation for that cargo tank was
obtained, [563.428(h) (2)]
Each reloading of a nonvapor-tight gasoline cargo tank at the facility before vapor
tightness documentation for that cargo tank is obtained by the facility in accordance with
9$.a22G)Q) t563 428h)(3)l
Table 2 notes each exceedance or failure to maintain, as appropriate, the monitored operating
parameter value determined under 563.425(b). The report includes the monitoring data for the
days on which exceedances or failures occurred, and a description and timing of the steps taken
to repair or perform maintenance on the vapor collection and processing systems orthe CMS (if
the CMS indicated that the operating parameter value was exceeded or not maintained).
t563.428(hX1)l
I.s S63.65s(c)
Each owner or operator subject to the marine tank vessel loading operation standards in 953.651
shall comply with the recordkeeping and reporting provisions in 9963.567(a) and 53.557(c) through
(k) of subpart Y. These requirements are summarized in tabte 5 of this subpart. There are no
additional reporting and recordkeeping requirements for marine tank vessel loading operations
under this subpart unless marine tank vessel loading operations are included in an emissions
average. Recordkeeping and reporting for emissions averages are specified in 563.653 and in
paragraphs (0(5) and (g)(8) of this section.
Tesoro Logistics does not have marine loading regulated under 40 CFR 53 Subpart Y and Subpart
CC.
1.4 $63.6s5(d)
Each owner or operator subject to the equipment leaks standards in 963.648 shall comply with the
recordkeeping and reporting provisions in paragraphs (d)(1) through (dX6) of this section.
Tesoro Logistics has chosen to comply with the equipment leaks standards in 563.648 by
complying with the provisions of 40 CFR 60 Subpart VVa. Therefore, its periodic reporting
obligation is delineated in 40 CFR 60.487a. Tesoro Logistics currently submits a quarterly report
to the Utah Division of Air Quality with the information required in 40 CFR 60.487a and Utah's
R307-326-7. These reports satisfy the requirements of 40 CFR 63.655(d).
l.s S63.65s(e)
Each owner or operator of a source subject to this subpart shall submit the reports listed in
paragraphs (e)(1) through (e)(3) of this section except as provided in paragraph (h)(5) of this
section, and shall keep records as described in paragraph (i) of this section.
Tesoro Logistics submits this report pursuant to 563.655(e)(2). 563.655(e)(1) and Section (3)
reporting requirements are not applicable for this periodic report.
r.6 s63.6ss(f)
Each owner or operator of a source subject to this subpart shall submit a Notification of
Compliance Status report within 150 days after the compliance dates specified in 553.540(h) with
the exception of Notification of Compliance Status reports submitted to comply with 563.640(l)(3)
and for storage vessels subject to the compliance schedule specified in 963.6a0(h)(2).
Not applicable for this periodic report.
1.7 $63.65s(g)
The owner or operator of a source subject to this subpart sha!! submit Periodic Reports no later
than 60 days after the end of each 6-month period when any of the information specified in
paragraphs (g)(1) through (7) of this section or paragraphs (g)(9) through (14) of this section is
collected. The firct 6-month period shall begin on the date the Notification of Compliance Status
report is required to be submitted. A Periodic Report is not required if none of the events
identified in paragraphs (g)(1) through (7) of this section or paragraphs (gX9) through (14) of this
section occurred during the 6-month period unless emissions averaging is utilized. Quarterly
reports must be submitted for emission points included in emission averages, as provided in
paragraph (gX8) of this section. An owner or operator may submit reports required by other
regulations in place of or as part of the Periodic Report required by this paragraph (g) if the
reports contain the information required by paragraphs (g)(1) through (14) of this section.
ln accordance with 40 CFR 63.655(g), the periodic report is submitted no later than 60 days after
the end of each 6-month period when anyof the compliance exceptions specified in paragraphs
(g)(1) through (g)(6) of this section occur.
563.655(g)(1) For storage vessels, Periodic Reports shall include the information specified for
Periodic Reports in paragraphs (gX2) through (5) of this section. lnformation related to gaskets,
slotted membranes, and sleeve seals is not required for storage vessels that are part of an existing
source complying with 563.645.
Tesoro Logistics summarizes inspection results, as required, in the following sections. When
complying with 563.646, Tesoro Logistics does not report inspection failures related to gaskets,
slotted membranes, and sleeve seals.
963.655(gX2) lnternal floating roofs.
963.655(gX2Xi) An owner or operator who elects to comply with 563.646 by using a fixed roof and
an internal floating roof or by using an external floating roof converted to an internal floating roof
shall submit the results of each inspection conducted in accordance with 963.120(a) of subpart G in
which a failure is detected in the control equipment.
Tesoro Logistics summarizes inspection results, as required, in the following sections.
563.655(g)(2XiXA) For vessels for which annua! inspections are required under 963.120(a)(2)(i) or
(a)(3)(ii) of subpart G, the specifications and requirements listed in paragraphs (gX2XiXA)(1)
through (3) of this section apply.
563.655(gX2XD(AX1) A failure is defined as any time in which the internalfloating roof is not
resting on the surface of the liquid inside the storage vessel and is not resting on the leg supports;
or there is liquid on the floating roof; or the seal is detached from the internal floating roof; or
there are holes, tears, or other openings in the seal or seal fabric; or there are visible gaps between
the seal and the wall of the storage vessel.
Annual inspections for which a failure was detected in the control equipment are summarized in
Table 3.
563.655(g)(2XiXA)(2) Except as provided in paragraph (g)(2)(:XA)(3) of this section, each Periodic
Report shall inctude the date of the inspection, identification of each storage vessel in which a
failure was detected, and a description of the failure. The Periodic Report shall also describe the
nature of and date the repair was made or the date the storage vessel was emptied.
Annual inspections forwhich a failure was detected, the date of the inspection, identification of
each storage vessel in which a failure was detected, and a description of the failure are
summarized in Table 3.
563.655(g)(2XD(A)(3) lf an extension is utilized in accordance with 963.120(a)(4) of subpart G, the
owner or operator shall, in the next Periodic Report, identify the vessel; include the documentation
specified in 953.120(a)(4) of subpart G; and describe the date the storage vessel was emptied and
the nature of and date the repair was made.
Tesoro Logistics did not utilize an extension during this reporting period.
563.555(gX2XiXB) For vessels for which inspections are required under 953.120(a)(2)(ii), (a)(3)(i),
or (a)(3)(iii) of subpart G (i.e., internal inspections), the specifications and requirements listed in
paragraphs (g)(2)(:)(BXl) and (2) of this section apply.
563.655(g)(2XiXBXl ) A failure is def ined as any time in which the internal floating roof has defects;
or the primary seal has holes, tears, or other openings in the seal or the seal fabric; or the
secondary seal (if one has been installed) has holes, tears, or other openings in the seal or the seal
fabric; or, for a storage vessel that is part of a new source, the gaskets no longer close off the liquid
surface from the atmosphere; or, tor a storage vessel that is part of a new source, the slotted
membrane has more than a 10 percent open.
lnternal inspections forwhich a failure was detected in the control equipment are summarized in
Table 4.
563.655(gX2XiXBX2) Each Periodic Report shall include the date of the inspection, identification of
each storage vessel in which a failure was detected, and a description of the failure. The Periodic
Report shall also describe the nature of and date the repair was made.
lnternal inspections forwhich a failure was detected, the date of the inspection, identification of
each storage vessel in which a failure was detected, and a description of the failure are
summarized in Table 4.
563.655(g)(2)(ii) An owner or operator who elects to comply with 963.660 by using a fixed roof and
an internal floating roof shal! submit the results of each inspection conducted in accordance with
$63.1063(c)(1), (d)(1), and (d)(2) of subpart WW in which a failure is detected in the control
equipment. For vessels for which inspections are required under 563.1063(c) and (d), the
specifications and requirements listed in paragraphs (g)(2)(ii)(A) through (C) of this section apply.
Tesoro Logistics'Group 1 storage vessels are compliant with 563.660.
(A) A failure is defined in 563.1063(dX1) of subpart WW.
lnspections forwhich a failure was detected in the control equipment are summarized in Table 5
(B) Each Periodic Report shall include a copy of the inspection record required by 553.1065(b) of
subpart W\Al when a failure occurs.
lnspections forwhich a failure was detected in the control equipment are summarized in Table 5
(C) An owner or operator who elects to use an extension in accordance with 563.1053(e)(2) of
subpart WW shall, in the next Periodic Report, submit the documentation required by
563.1063(e)(2).
Tesoro Logistics did not utilize an extension during this reporting period.
563.655(gX3) External floating roofs.
963.655(gX3Xi) An owner or operator who elects to comply with 953.646 by using an external
floating roof shall meet the periodic reporting requirements specified in paragraphs (gX3XiXA)
through (C) of this section.
Not applicable. Tesoro Logistics does not operate external floating roof tanks at the Truck
Loading Rack.
(A) The owner or operator shall submit, as part of the Periodic Report, documentation of
the results of each seal gap measurement made in accordance with 563.120(b) of subpart G
in which the seal and seal gap requirements of 563.120(bX3), (4), (5), or (6) of subpart G are
not met. This documentation shall include the information specified in paragraphs
(g)(3)(i)(A)(1) through (4) of this section.
Not applicable. Tesoro Logistics does not operate erternal floating roof tanks at the
Truck Loading Rack.
(B) lf an extension is utilized in accordance with 953.120(b)(7)(ii) or (b)(8) of subpart G, the
owner or operator shall, in the next Periodic Report, identify the vesseh include the
documentation specified in 963.12O(bXTXii) or (b)(8) of subpart G, as applicable; and
describe the date the vessel was emptied and the nature of and date the repair was made.
Not applicable. Tesoro Logistics does not operate erternal floating roof tanks at the
Truck Loading Rack.
(C) The owner or operator shall submit, as part of the Periodic Report, documentation of
any failures that are identified during visua! inspections required by 563.120(bX10) of
subpart G. This documentation shall meet the specifications and requirements in
paragraphs (gX3)(i)(C)(1) and (2) of this section.
(CXl) A failure is defined as any time in which the external floating roof has defects; or the
primary seal has holes or other openings in the seal or the seal fabric; or the secondary seal
has holes, tears, or other openings in the seal or the seal fabric; or, for a storage vessel that
is part of a new source, the gaskets no Ionger close off the liquid surface from the
atmosphere; or, tor a storage vessel that is part of a new source, the slotted membrane has
more than 10 percent open area.
Not applicable. Tesoro Logistics does not operate externalfloating roof tanks at the
Truck Loading Rack.
(CXz) Each Periodic Report shall include the date of the inspection, identification of each
storage vessel in which a failure was detected, and a description of the failure. The Periodic
Report shall also describe the nature of and date the repair was made.
Not applicable. Tesoro Logistics does not operate external floating roof tanks atthe
Truck Loading Rack.
963.655(gx3Xii) An owner or operator who elects to comply with 563.660 by using an external
floating roof shall meet the periodic reporting requirements specified in paragraphs (gX3XiiXA)
and (B) of this section.
(A) For vessels for which inspections are required under $63.1063(c)(2), (dxl), and (d)(3) of
subpart WW, the owner or operator shall submit, as part of the Periodic Report, a copy of
the inspection record required by 563.1065(b) of subpart WW when a failure occurc. A
failure is defined in 563.1063(d)(1).
Not applicable. Tesoro Logistics does not operate external floating roof tanks at the
Truck Loading Rack.
(B) An owner or operator who elects to use an extension in accordance with 963.1063(eX2)
or (c)(2)(iv)(B) of subpart WW sha!|, in the next Periodic Report, submit the documentation
required by those paragraphs.
Not applicable. Tesoro Logistics does not operate external floating roof tanks atthe
Truck Loading Rack.
963.655(g)(4) lReserved]
563.655(9)(5) An owner or operator who elects to comply with 563.646 or 553.650 by installing a
closed vent system and control device shallsubmit, as part of the next Periodic Report, the
information specified in paragraphs (gXsXi) through (v) of this section, as applicable.
Tesoro Logistics does not have any Group 1 tanks that comply with 563.646 or 563.660 by the use
of a closed vent system and control device.
963.655(g)(6) For miscellaneous process vents for which continuous parameter monitors are
required by this subpart, periods of excess emissions shal! be identified in the Periodic Reports and
shall be used to determine compliance with the emission standards.
Tesoro Logistics does not have Group 1 Miscellaneous Process Vents controlled by a flare
$63.655(g)(6Xi) Period of excess emission means any of the following conditions:
Not applicable. Tesoro Logistics does not have Group 'l MPV's.
(A) An operating day when the daily average value of a monitored parameter, except
presence of a flare pilot flame, is outside the range specified in the Notification of
Compliance Status report. Monitoring data recorded during periods of monitoring system
breakdown, repairs, calibration checks and zero (!ow-level) and high-level adjustments shall
not be used in computing daily average values of monitored parameters.
(A) Not applicable. Tesoro Logistics does not have Group 1 MPVs controlled by a flare.
(B) An operating day when all pilot flames of a flare are absent.
(B) Not applicable. Tesoro Logistics does not have Group 1 MPVs controlled by a flare.
(C) An operating day when monitoring data required to be recorded in paragraphs (iX3) (i)
and (ii) of this section are available for less than 75 percent of the operating hours.
(C) Not applicable. Tesoro Logistics does not have Group 1 MPVs recording data.
(D) For data compression systems under paragraph (hxsxiii) of this section, an operating
day when the monitor operated for less than 75 percent of the operating hours or a day
when less than 18 monitoring values were recorded.
(D) Not applicable. Tesoro Logistics does not use data compression systems.
963.655(g)(6)(ii) For miscellaneous process vents, excess emissions shall be reported for the
operating parameters specified in Table 7 of this subpart unless other site-specific parameter(s)
have been approved by the operating permit authority.
Not applicable. Tesoro Logistics complies with $63.643(a), therefore, the requirements of Subpart
CC Table 7 do not apply.
563.655(gX6)(iii) For periods in closed vent systems when a Group 1 miscellaneous process vent
stream was detected in the bypass line or diverted from the controldevice and either directly to
the atmosphere or to a control device that does not compty with the requirements in 963.643(a),
report the date, time, duration, estimate of the volume of gas, the concentration of organic HAP in
the gas and the resulting mass emissions of organic HAP that bypassed the control device. For
periods when the flow indicator is not operating, report the date, time, and duration.
Not applicable. Tesoro Logistics does not have Group 'l MPV's.
963.655(gX7) lf a performance test for determination of compliance for a new emission point
subject to this subpart or for an emission point that has changed from Group 2 to Group 1 is
conducted during the period covered by a Periodic Report, the results of the performance test shall
be included in the Periodic Report.
No performance tests were conducted during the reporting period that demonstrated a change
from Group 2 status to Group 1 or for demonstrating compliance of a new emission point subject
to Subpart CC.
963.655(g)(8) The owner or operator of a source shall submit quarterly reports for all emission
points included in an emissions average.
Not applicable. Tesoro Logistics does not seek to comply with Subpart CC by using the emission
averaging provisions presented in 563.652, therefore no quarterly report is required in accordance
with 963.655(g)(8).
963.655(gX9) For heat exchange systems, Periodic Reports must include the information in
963.6ss(gXe).
Not applicable. Tesoro Logistics does not have heat exchange systems subject to Subpart CC.
963.655(gX10) For pressure relief devices subject to the requirements 563.548(), Periodic Reports
must include the information specified in paragraphs (g)(10)(i) through (iii) of this section.
$63.655(9)(10)(D For pressure relief devices in organic HAP gas or vapor service, pursuant to
563.648(D(1), report any instrument reading of 500 ppm or greater.
Pressure relief devices (PRD) in organic HAP gas or vapor service, pursuant to 563.6480(1) where
an instrument reading of 500 ppm or greater occurred is summarized in Table .
553.655(gxl OXii) For pressure relief devices in organic HAP gas or vapor senrice subject to
953.6480)(2), report confirmation that any monitoring required to be done during the reporting
period to show compliance was conducted.
For PRDs in organic HAP gas or vapor service subject to 563.648(j)(2), monitoring required to
demonstrate compliance is summarized in Table .
563.555(g)(lOxiii) For pilot-operated pressure relief devices in organic HAP service, report each
pressure release to the atmosphere through the pilot vent that equals or exceeds 72 pounds of VOC
per day, including duration of the pressure release through the pilot vent and estimate of the mass
quantity of each organic HAP released.
Not applicable. Tesoro Logistics does not have pilot operated PRDs at the asset that it operates.
563.655(g)(1O)(iv) For pressure relief devices in organic HAP service subject to 963.648()(3), report
each pressure release to the atmosphere, including duration of the pressure release and estimate of
the mass quantity of each organic HAP released, and the results of any root cause analysis and
corrective action analysis completed during the reporting period, including the corrective actions
implemented during the reporting period and, if applicable, the implementation schedule for
planned corrective actions to be implemented subsequent to the reporting period.
No OHAP PRDs atthe facilityexperienced a release during the reporting period.
563.655(gXl 1) For f Iares subject to 953.670, Periodic Reports must include the information
specified in paragraphs (gxl1)(i) through (iv) of this section.
Not applicable. Tesoro Logistics does not operate a flare.
563.655(gxl2) For delayed coking units, the Periodic Report must include the information
specified in paragraphs (gxl2Xi) through (iv) of this section.
Not applicable. Tesoro Logistics does not operate a delayed coking unit.
563.655(gxl3) For maintenance vents subject to the requirements in 563.643(c), Periodic Reports
must include the information specified in paragraphs (g)(13)(i) through (iv) of this section for any
release exceeding the applicable limits in 963.643(c)(1). For the purposes of this reporting
requirement, owners or operators complying with 563.643(cXl)(iv) must report each venting event
for which the Iower explosive limit is 20 percent or greater.
All maintenance vent activities were within regulatory limits during the applicable reporting
period.
963.655(gxl4) Any changes in the information provided in a previous Notification of Compliance
Status report.
Table , Table , and Table 11 contain any changes in the information provided in a previous NOCS
report.
The cover letter for this report contains the name, title, and signature of the responsible official who is
certifying its accuracy. t553.10(dx5xi)l
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Attachment A
Secondary Seal Gap Calculations
NO SEAL GAP MEASUREMENT INSPECTION COMPLIANCE EXCEPTIONS WERE FOUND DURING THE
REPORTING PERIOD.
23
Attachment B
Primary Seal Gap Calculations
NO SEAL GAP MEASUREMENT INSPECTION COMPLIANCE EXCEPTIONS WERE FOUND DURING THE
REPORTING PERIOD.
I
I
-_-t
DIVISION OF AIR OUAL ITY
UTAH Dt':t'JARl MENT OF
E NVIITONMENTAL QUALITY