DAQ-2024-009320

DAQE-AN101560020-24

{{$d1 }}

Dennis Wilson
Utility Trailer Manufacturing Company
1111 South 1000 West
Clearfield, UT 84016-0387
[e-mail]

Dear Mr. Wilson:

Re: Approval Order: Administrative Amendment to Approval Order to DAQE-AN101560017-17, to
Reduce VOC Emissions
Project Number: N101560020

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on July 27,
2023. Utility Trailer Manufacturing Company must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Tad Anderson, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TA:jg

cc: Davis County Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

July 19, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN101560020-24
Administrative Amendment to
Approval Order to DAQE-AN101560017-17,
to Reduce VOC Emissions

Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]

Issued to
Utility Trailer Manufacturing Company - Trailer Manufacturing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality
July 19, 2024

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN101560020-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Utility Trailer Manufacturing Company Utility Trailer Manufacturing Company - Trailer
Manufacturing Facility

Mailing Address Physical Address
1111 South 1000 West 1111 South 1000 West
Clearfield, UT 84016-0387 Clearfield, UT 84016-0387

Source Contact UTM Coordinates
Name: Dennis Wilson 421,977 m Easting
Phone: [phone],511,236 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12

SIC code 3715 (Truck Trailers)

SOURCE INFORMATION
General Description
Utility Trailer Manufacturing Company (Utility Trailer) operates a refrigerated (climate controlled) truck
trailer manufacturing operation. Utility Trailer had previously been classified as a minor source for the
emission of Volatile Organic Compounds (VOC) but is now considered to be a synthetic minor (SM)
source. Parking areas are paved. Trailer storage areas are covered with rototilled asphalt, gravel, or soil.

NSR Classification
Administrative Amendment

Source Classification
Located in
Davis County
Airs Source Size: SM

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

DAQE-AN101560020-24
Page 4

Project Description
Utility Trailer has requested an administrative amendment to AO DAQE-AN101560017-17 to reduce the
trailer manufacturing facility’s VOC PTE emissions from 69 TPY to 49 TPY. The revised PTE emissions
for the trailer manufacturing facility lower the site-wide PTEs below the major source classification for
sources located in the ozone nonattainment designation in the Northern Wasatch Front nonattainment
area. This permit update has no new equipment or increase in emissions, so it is not subject to UAC,
R307-401-5 and subject to UAC R307-401-12, "Reduction in Air Pollutants."

The last three (3) years of emissions inventories were reviewed to determine the average VOC of actual
emissions. The average actual VOC emissions that were submitted to Utah Division of Air Quality
(UDAQ) for the years 2021, 2022, and 2023 are 33.72 TPY of VOC. This value validates that the trailer
manufacturing facility can reduce the PTE to 49 TPY with the current operations.

Process Description
Utility Trailer manufactures refrigerated truck trailers. Stainless steel is cut and welded together to
fabricate the structural frames for the trailers. Some of the sub-assemblies for trailer frames are dipped
into tanks containing corrosion inhibitors. Painting is conducted in the large, filtered paint spray booths.
Trailer shells constructed from aluminum, stainless steel, wood, and/or fiberglass are mounted onto the
trailer frames. A foaming insulator mixture blended with an expansion agent is injected into the walls,
floors, and ceiling of the trailers. Once the foam insulation cures, the trailers are moved to a final
assembly area where wheels, electrical wiring, lights, and miscellaneous features (such as refrigeration
units) are installed.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Carbon Monoxide 0 5.47
Nitrogen Oxides 0 26.83
Particulate Matter - PM10 0 21.48
Particulate Matter - PM2.5 0 21.48
Sulfur Dioxide 0 0.22
Volatile Organic Compounds -20.00 49.00

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 49000
Change (TPY) Total (TPY)
Total HAPs 0 24.50

DAQE-AN101560020-24
Page 5

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 UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Truck Trailer Fabricator
Source Wide

II.A.2 Building N-14 Freeport Center

II.A.3 Paint Booth
One (1) Spray King Model 500 D-D Down Draft paint spray booth is used to spray-coat trailer
components with 102,000 acfm of total design air flow.

II.A.4 Foam Application Stations
Various Diphenylmethane Diisocyanate foam application stations.

II.A.5 Building at 1111 South, 1000 West

II.A.6 Paint Booths
Three (3) paint spray booths are used to spray coat trailer components.

DAQE-AN101560020-24
Page 6

II.A.7 Dip-Coating Tank
One (1) dip coating tank with cover and vent heated by natural gas, rated at 683,000 BTU.

II.A.8 Paint Booth
One (1) small parts paint booth.

II.A.9 Airless Paint Spray Guns

II.A.10 Foam Application Stations
Various Diphenylmethane Diisocyanate foam application stations.

II.A.11 Enclosed Spray Gun Cleaner(s)

II.A.12 Abrasive Blast Booths
Two (2) abrasive blast booths with dust collectors.

II.A.13 Dust Collector(s)
Woodmill dust collector(s) venting inside of the building.

*Listed for informational purposes only.

II.A.14 Dust Collector(s)
Dust collector(s) for welding fumes that vent inside the building.

*Listed for informational purposes only.

II.A.15 Dust Collector
One (1) Torit, pulse-jet-style welding dust collector with 4000 acfm total design air flow.

II.A.16 Emergency Generator
One (1) Emergency Generator
Maximum Equipment Rating: 205 hp
Fuel Type: Diesel
Federal Requirement: Subpart ZZZZ

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Source Wide
II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10% opacity with the exception of the
emergency diesel generator which shall not exceed 20% opacity.

Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b Utility Trailer shall only use natural gas or liquid propane gas as fuel in the heaters and boilers.
[R307-401-8]

DAQE-AN101560020-24
Page 7

II.B.2 Coating Booth and Blast Booth
II.B.2.a Each coating booth and blast booth baghouse shall be equipped with a manometer or magnehelic
pressure gauge to measure the differential pressure across the filters.

The static pressure differential across the fiber filters in each coating booth shall be maintained
between 0.25 and 1.0 inches of water column.

The static pressure differential across the bags in all blast booth baghouses shall be maintained in
accordance with the manufacturer's specifications.

All pressure gauges shall be located such that an inspector/operator can safely read the indicator
at any time. All readings shall be accurate to within plus or minus 0.1 inches of the water
column. Once per day, the owner/operator shall verify that the differential pressure is within the
permitted range.

Once per operating day for each blast booth or room, the owner/operator shall verify that the
differential pressure is within the permitted range. All pressure gauges shall be located such that
an inspector/operator can safely read the indicator at any time. All readings shall be accurate to
within plus or minus 0.1 inches of the water column.

The results of pressure drop readings shall be recorded and maintained for each blast booth or
room. In addition, documentation of the manufacturer's recommended pressure differential for
the fabric filter shall be kept onsite.

[R307-401]

II.B.2.b All paint spray booths shall be equipped with paint arrester particulate filters to control
particulate emissions. All air exiting the booth shall pass through this control system before
being vented to the atmosphere. [R307-401-8]

II.B.3 Fugitive Dust
II.B.3.a The owner/operator shall abide by all applicable requirements of R307-309 for fugitive emission
and fugitive dust sources. [R307-309]

II.B.3.b The owner/operator shall comply with the abrasive blasting requirements of R307-206.
[R307-206]

II.B.4 VOC and HAP Emissions
II.B.4.a The owner/operator shall abide by all applicable requirements of UAC R307-350 for
Miscellaneous Metal Parts and Products Coatings. All coatings used in trailer manufacturing are
considered extreme-performance coatings. [R307-350]

DAQE-AN101560020-24
Page 8

II.B.4.b The plant-wide VOC and HAP emissions shall not exceed the following:

49.0 tons total VOC per rolling 12-month period.

9.5 tons of any individual hazardous air pollutant (HAP) per rolling 12-month period.

24.5 tons of any combination of hazardous air pollutants per rolling 12-month period.

Compliance with the 12-month limitations for total VOC shall be determined by calculation of a
rolling 12-month total. Compliance with both the individual and combined limits on HAPs will
be deemed satisfied by calculation of the 12-month rolling total for combined HAP.

The plant-wide emissions of VOC and HAP shall be calculated from records of the consumption
of VOC and HAP-containing materials used at the plant each month. These calculations shall be
updated no later than the 15th day of the month following the month which the records reflect.
In order to calculate the 12-month rolling totals for VOC and HAP, the owner/operator will
maintain the following data for each VOC- and HAP-containing material used:

A. Name of the VOC or HAP-emitting material, such as paint, solvent, reducers, additives
etc.

B. Percent volatile by weight of all VOCs and HAPs in each material used.

C. Density in pounds per gallon for each item above, as applied.

D. Gallons Consumed of each VOC or HAPs.

E. The weight in tons of total VOCs and combined HAP emitted on a monthly basis using
the above-described factors and calculated as follows:

VOC = (% Volatile by Weight/100) * (Density lb./gal) * (Gallons Consumed) / (2,000
lb./ton).

HAP = (% HAP by Weight/100) * (Density lb./gal) * (Gallons Consumed) / (2,000
lb./ton).

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

G. The amount of VOC or HAP may be adjusted using purchasing, receiving, and inventory
records. This adjustment may be made at least on an annual basis, but may be applied
monthly if such records are available. Data from receiving logs and inventory counts, or
equivalent, are deemed adequate.

H. The amount of VOC or HAP reclaimed may be quantified and subtracted from the
quantities calculated above. This adjustment may be made at least on an annual basis, but
may be applied monthly if monthly waste generation data are available. Data from
hazardous waste manifests or bills of lading are deemed adequate.

Daily records of consumption shall be recorded for all periods when the plant is
operating.

[R307-401]

DAQE-AN101560020-24
Page 9

II.B.4.c Except for touch-up coating operations, coating operations shall be performed using airless
spray, High Volume Low Pressure (HVLP) spray, dip coating or roller coating
methods/equipment, or other equipment/methods with equivalent coating transfer efficiency
approved by the Director. Airless spray shall only be permitted for high-viscosity coatings.
Equivalency shall be determined by the Director. [R307-401-8]

II.B.5 Emergency Generator Requirements
II.B.5.a The emergency generator hours of operation for maintenance firing purposes shall not exceed 25
hours per rolling 12-month period for each generator. Compliance with each limitation shall be
determined on a rolling 12-month total. No later than 20 days after the end of each month, a new
12-month total shall be calculated using data from the previous 12 months. Records documenting
the generator's hours shall be kept in a log for all periods when the plant is in operation. Engine
hours of operation shall be determined by examination of maintenance records, which shall be
kept on site. [R307-401-8]

II.B.5.b Emergency generators shall be used only when electricity is interrupted or maintenance of the
generators. Records of generator usage shall be kept, and they shall include the following:

A) the date of usage.

B) the hours of usage.

C) the amount of fuel used.

[R307-401-8]

II.B.5.c The owner/operator shall use #1 and/or #2 diesel fuel in the emergency generator. [R307-401-8]

II.B.5.d The sulfur content of the diesel fuel shall not exceed 15 ppm by weight. [R307-203]

II.B.5.d.1 Sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of the diesel fuel shall be either by the owner/operators own testing or test reports
from the fuel marketer. [R307-203]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN101560017-17 dated May 30, 2017
Is Derived From Notice of Intent Document dated July 27, 2023

DAQE-AN101560020-24
Page 10

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN101560020
June 19, 2024

Dennis Wilson
Utility Trailer Manufacturing Company
1111 South 1000 West
Clearfield, UT 840160387
[e-mail]

Dear Dennis Wilson,

Re: Engineer Review - Administrative Amendment to Approval Order to DAQE-
AN101560017-17, to Reduce VOC Emissions
Project Number: N101560020

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review (NSR) permitting program. Utility
Trailer Manufacturing Company should complete this review within 10 business days of receipt.

Utility Trailer Manufacturing Company should contact Tad Anderson at [phone] if there are
questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Tad Anderson at [e-mail] the signed cover letter. Upon receipt of the signed
cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.

If Utility Trailer Manufacturing Company does not respond to this letter within 10 business days, the
project will move forward without source concurrence. If Utility Trailer Manufacturing Company has
concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order
prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N101560020
Owner Name Utility Trailer Manufacturing Company
Mailing Address 1111 South 1000 West
Clearfield, UT, 840160387

Source Name Utility Trailer Manufacturing Company- Trailer Manufacturing
Facility
Source Location 1111 South 1000 West
Clearfield, UT 84016

UTM Projection 421,977 m Easting, 4,511,236 m Northing
UTM Datum NAD27
UTM Zone UTM Zone 12
SIC Code 3715 (Truck Trailers)

Source Contact Dennis Wilson
Phone Number [phone]
Email [e-mail]

Billing Contact Dennis Wilson
Phone Number [phone]
Email [e-mail]

Project Engineer Tad Anderson, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted July 27, 2023
Date of Accepted Application June 5, 2024

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 2
SOURCE DESCRIPTION

General Description
Utility Trailer Manufacturing (Utility Trailer) operates a refrigerated (climate controlled) truck
trailer manufacturing operation. Utility Trailer had previously been classified as a minor source
for emission of Volatile Organic Compounds (VOC) but is now considered to be a synthetic
minor (SM) source. Parking areas are paved. Trailer storage areas are covered with rototilled
asphalt, gravel or soil.

NSR Classification:
Administrative Amendment

Source Classification
Located in, Davis County
Airs Source Size: SM

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Proposal
Administrative Amendment to Approval Order to DAQE-AN101560017-17, to Reduce VOC
Emissions

Project Description
Utility Trailer has requested an administrative Amendment to DAQE-AN101560017-17, to
reduce the trailer manufacture facility VOC PTE emissions from 69 TPY to 49 TPY. The revised
PTE emissions for the trailer manufacture facility lowers the site wide PTEs below the major
source classification for sources located in the ozone nonattainment designation in the Northern
Wasatch Front nonattainment area. This permit update has no new equipment or increase in
emissions so is not subject to UAC R307-401-5 and subject to UAC R307-401-12, "Reduction in
Air Pollutants".

The last three years of emissions inventories were reviewed to determine the average VOC actual
emissions. The average actual VOC emissions that were submitted to UDAQ for the years
2021,2022 and 2023 is 33.72 TPY of VOC. This value validates that the trailer manufacture
facility can reduce the PTE to 49 TPY with the current operations.

Process Description
Utility Trailer manufactures refrigerated truck trailers. Stainless steel is cut and welded together
to fabricate the structural frames for the trailers. Some of the sub-assemblies for trailer frames are
dipped into tanks containing corrosion inhibitors. Painting is conducted in the large, filtered paint
spray booths. Trailer shells constructed from aluminum, stainless steel, wood and/or fiberglass
are mounted onto the trailer frames. A foaming insulator mixture blended with an expansion
agent is injected into the walls, floors, and ceiling of the trailers. Once the foam insulation cures,
the trailers are moved to a final assembly area where wheels, electrical wiring, lights and
miscellaneous features (such as refrigeration units) are installed.

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 3
EMISSION IMPACT ANALYSIS
This administrative amendment does not involve any new or increasing air pollutants. No modeling is required
as per R307-410-4 or R307-410-5 since the emissions rate is decreasing [Last updated June 18, 2024]

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 4
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Carbon Monoxide 0 5.47
Nitrogen Oxides 0 26.83
Particulate Matter - PM10 0 21.48
Particulate Matter - PM2.5 0 21.48
Sulfur Dioxide 0 0.22
Volatile Organic Compounds -20.00 49.00

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 49000
Change (TPY) Total (TPY)
Total HAPs 0 24.50

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 5
Review of BACT for New/Modified Emission Units

1. BACT review regarding BACT Analysis
This permit change does not involve any addition of new equipment or an increase in emission
rates. BACT is not required since it does not require a NOI as per R307-401-5. [Last updated
June 18, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

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 UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 6
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Truck Trailer Fabricator
Source Wide

II.A.2 Building N-14 Freeport Center

II.A.3 Paint Booth
One (1) Spray King Model 500 D-D Down Draft paint spray booth used to spray-coat trailer
components, with 102,000 acfm total design air flow

II.A.4 Foam Application Stations
Various Diphenylmethane Diisocyanate foam application stations

II.A.5 Building at 1111 South 1000 West

II.A.6 Paint Booths
Three (3) paint spray booths used to spray coat trailer components

II.A.7 Dip Coating Tank
One (1) dip coating tank with cover and vent heated by natural gas, rated at 683,000 BTU

II.A.8 Paint Booth
One (1) small parts paint booth

II.A.9 Airless Paint Spray Guns

II.A.10 Foam Application Stations
Various Diphenylmethane Diisocyanate foam application stations

II.A.11 Enclosed Spray Gun Cleaner(s)

II.A.12 Abrasive Blast Booths
Two (2) abrasive blast booths with dust collectors

II.A.13 Dust Collector(s)
Woodmill dust collector(s) venting inside of the building

Listed for informational purposes only

II.A.14 Dust Collector(s)
Dust collector(s) for welding fumes that vent inside the building

Listed for informational purposes only

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 7
II.A.15 Dust Collector
One (1) Torit, pulse-jet style welding dust collector with 4000 acfm total design air flow

II.A.16 Emergency Generator
One (1) Emergency Generator
Maximum Equipment Rating:205 hp
Fuel Type: Diesel
Federal Requirement: Subpart ZZZZ

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Source Wide
II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10% opacity with the exception of the
emergency diesel generator which shall not exceed 20% opacity.

Opacity observations of emissions from stationary sources shall be conducted in accordance
with 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b Utility Trailer shall only use natural gas or liquid propane gas as fuel in the heaters and
boilers. [R307-401-8]

II.B.2 Coating Booth and Blast Booth
II.B.2.a Each coating booth and blast booth baghouse shall be equipped with a manometer or
magnehelic pressure gauge to measure the differential pressure across the filters.

The static pressure differential across the fiber filters in each coating booth shall be
maintained between 0.25 and 1.0 inches of water column.

The static pressure differential across the bags in all blast booth baghouses shall be maintained
in accordance with the
Manufacturer's specifications.

All pressure gages shall be located such that an inspector/operator can safely read the indicator
at any time. All readings shall be accurate to within plus or minus 0.1 inches water column.
Once per day the owner/operator shall verify that the differential pressure is within the
permitted range.

Once per operating day for each blast booth or room, the owner/operator shall verify that the
differential pressure is within the permitted range. All pressure gauges shall be located such
that an inspector/operator can safely read the indicator at any time. All readings shall be
accurate to within plus or minus 0.1 inches water column.

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 8
Results of pressure drop readings shall be recorded and maintained for each blast booth or
room. In addition, documentation of the
Manufacturer's recommended pressure differential for the fabric filter shall be kept onsite.
[R307-401]

II.B.2.b All paint spray booths shall be equipped with paint arrester particulate filters to control
particulate emissions. All air exiting the booth shall pass through this control system before
being vented to the atmosphere. [R307-401-8]

II.B.3 Fugitive Dust
II.B.3.a The owner/operator shall abide by all applicable requirements of R307-309 for Fugitive
Emission and Fugitive Dust sources. [R307-309]

II.B.3.b The owner/operator shall comply with the abrasive blasting requirements of R307-206. [R307-
206]

II.B.4 VOC and HAP Emissions
II.B.4.a The owner/operator shall abide by all applicable requirements of UAC R307-350 for
Miscellaneous Metal Parts and Products Coatings. All coatings used in Trailer manufacturing
are considered Extreme Performance coatings. [R307-350]

II.B.4.b
NEW
The plant-wide VOC and HAP emissions shall not exceed the following:

49.0 tons total VOC per rolling 12-month period
9.5 tons of any individual hazardous air pollutant (HAP) per rolling 12-month period
24.5 tons of any combination of hazardous air pollutants per rolling 12-month period

Compliance with the 12-month limitations for total VOC shall be determined by calculation of
a rolling 12-month total. Compliance with both the individual and combined limits on HAPs
will be deemed satisfied by calculation of the 12-month rolling total for combined HAP.

The plant-wide emissions of VOC and HAP shall be calculated from records of the
consumption of VOC and HAP containing materials used at the plant each month. These
calculations shall be updated no later than the 15th day of the month following the month
which the records reflect. In order to calculate the 12-month rolling totals for VOC and HAP,
the owner/operator will maintain the following data for each VOC-and HAP-containing
materials used:

A. Name of the VOC or HAP emitting material, such as paint, solvent, reducers, additives etc.

B. Percent volatile by weight of all VOCs and HAPs in each material used.

C. Density in pounds per gallon for each item above, as applied.

D. Gallons Consumed of each VOC or HAPs

E. The weight in tons of total VOCs and combined HAP emitted on a monthly basis using the
above-described factors, and calculated as follows:

VOC = (% Volatile by Weight/100) * (Density lb./gal)* (Gallons Consumed) /(2,000
lb./ton)

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 9

HAP = (% HAP by Weight/100) * (Density lb./gal) * (Gallons Consumed) /(2,000 lb./ton)

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

G. The amount of VOC or HAP may be adjusted using purchasing, receiving and inventory
records. This adjustment may be made at least on an annual basis, but may be applied
monthly if such records are available. Data from receiving logs and inventory counts, or
equivalent, are deemed adequate.

H. The amount of VOC or HAP reclaimed maybe quantified and subtracted from the
quantities calculated above. This adjustment may be made at least on an annual basis, but
may be applied monthly if monthly waste generation data are available. Data from hazardous
waste manifests or bills of lading are deemed adequate.

Daily records of consumption shall be recorded for all periods when the plant is operating.
[R307-401]

II.B.4.c Except for touch-up coating operations, coating operations shall be performed using airless
spray, High Volume Low Pressure (HVLP) spray, dip coating or roller coating
methods/equipment, or other equipment/methods with equivalent coating transfer efficiency
approved by the Director. Airless spray shall only be permitted for high viscosity coatings.
Equivalency shall be determined by the Director. [R307-401-8]

II.B.5 Emergency Generator Requirements
II.B.5.a The emergency generator hours of operation for maintenance firing purposes shall not exceed
25 hours per rolling 12-month period for each generator. Compliance with each limitation
shall be determined on a rolling 12-month total. No later than 20 days after the end of each
month, a new 12-month total shall be calculated using data from the previous 12 months.
Records documenting generator's hours shall be kept in a log for all periods when the plant is
in operation. Engine hours of operation shall be determined by examination of maintenance
records, which shall be kept on site. [R307-401-8]

II.B.5.b Emergency generators shall be used only when electricity is interrupted or maintenance of the
generators. Records of generator usage shall be kept, and they shall include the following:

A) the date of usage
B) the hours of usage
C) the amount of fuel used. [R307-401-8]

II.B.5.c The owner/operator shall use #1 and/or #2 diesel fuel in the emergency generator. [R307-401-
8]

II.B.5.d The sulfur content of the diesel fuel shall not exceed 15 ppm by weight. [R307-203]

II.B.5.d.1 Sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of the diesel fuel shall be either by the owner/operators own testing or test
reports from the fuel marketer. [R307-203]

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 10
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Is Derived From Notice of Intent Document dated July 27, 2023
Replaces DAQE-AN101560017-17 dated September 24, 2012

REVIEWER COMMENTS

1. Comment regarding Emission Estimates:
The site wide VOC emissions are calculated on a mass balance of VOC containing material
consumed at the trailer manufacturing facility each month per permit condition II.B.4.b. [Last
updated June 18, 2024]

2. Comment regarding VOC Emissions Reduction:
UDAQ, NSR reviewed the last three years of emissions inventories (actual emissions) to determine
if Utility Trailer, trailer manufacture facility could reduce VOC PTE emissions below the new major
source threshold classification (50 TPY of VOC). The average actual VOC emissions that were
submitted to UDAQ for the years 2021,2022 and 2023 are 33.72 TPY of actual VOC emissions.
This value validates that the trailer manufacture facility can reduce the PTE to 49 TPY with the
current operations and adjust current production. [Last updated June 18, 2024]

3. Comment regarding Permit Analysis:
This project is reducing emissions in the VOC PTE emissions but does not account for CO2e
emissions. This permit change is being conducted as an administrative amendment which does not
require a public comment per UAC R307-401-5. This project is being conducted to reduce
emissions below major source classification (50 TPY). [Last updated June 18, 2024]

4. Comment regarding Ozone SIP:
Utility Trailer has reviewed current operations at the trailer manufacturing facility to determine if the
sitewide VOC PTE emissions can be reduced without impacting production levels or permit
conditions. The reduction in site wide VOC emission will classify trailer manufacturing facility a
synthetic minor (SM) source (less than 50 TPY VOC). Utility Trailer, trailer manufacture facility
will be classified as a SM classification and will not be included in the Moderate Area Ozone State
Implementation Plan Development. [Last updated June 18, 2024]

5. Comment regarding Condition Change:
This administrative amendment was conducted to lower site wide VOC PTE emissions below 50
TPY. The only change to the permit conditions was to the VOC/HAP emitting limits (II.B.4.b)
lowering the VOC from 69.0 to 49 TPY. No other AO conditions were altered. [Last updated June
18, 2024]

6. Comment regarding Additional Permit Changes:
Some changes have been made to the AO due to compliance inspections and peer comments. The
emergency generator engine was updated from 125 kW to 205 hp and the subpart applicability was
added. Condition II.B.4.b expresses an equation to calculate the total VOC and HAP emissions.
The emissions equations have been updated for clarification. [Last updated June 19, 2024]

Engineer Review N101560020: Utility Trailer Manufacturing Company- Trailer Manufacturing Facility
June 19, 2024
Page 11

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

1/2/24, 10:00 PM State of Utah Mail - NOI Review
https://mail.google.com/mail/u/0/?ik=b363bbe9c3&view=pt&search=all&permmsgid=msg-a:r-8802880511112008094&simpl=msg-a:r-8802880511112008094 1/1
Sarah Foran <[e-mail]>
NOI Review
Sarah Foran <[e-mail]>Thu, Dec 7, 2023 at 9:02 AM
To: [e-mail]
Good Morning,
I was assigned to review the NOI submitted for utility trailer.
I think it may be beneficial to meet to discuss the proposed changes and additional information required for me to
complete the project.
Is there a time next week that would work for you for a video call?
Thank you,
Sarah Foran, PE
Environmental Engineer | Major NSR
M: [phone] 
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
2021 Emissions Inventory Report
Utility Trailer Manufacturing Company: Trailer Manufacturing Facility (10156)
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)0.67986 0.50941 1.18926
PM10-FIL PM10 Filterable 0.02746 <.00001 0.02746
PM25-PRI PM2.5 Primary (Filt + Cond)0.67986 0.49422 1.17408
PM25-FIL PM2.5 Filterable 0.02746 <.00001 0.02746
PM-CON PM Condensible 0.08239 <.00001 0.08239
SO2 Sulfur Dioxide 0.00867 0.00455 0.01322
NOX Nitrogen Oxides 1.35877 3.43798 4.79675
VOC Volatile Organic Compounds 32.9795 0.65933 33.63883
CO Carbon Monoxide 0.5782 3.61625 4.19445
7439921 Lead 0.00001 <.00001 0.00001
NH3 Ammonia 0.00708 <.00001 0.00708

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
100414 Ethyl Benzene (HAP)VOC 0.032
108101 Methyl Isobutyl Ketone (HAP)VOC 0.002
108883 Toluene (HAP)VOC 0.15
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.24

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/11
2021 Emissions Inventory Report
Utility Trailer Manufacturing Company: Trailer Manufacturing Facility (10156)
FACILITY
Facility Identifier:10156 Facility Name:Utility Trailer Manufacturing Company: Trailer Manufacturing Facility
Description:
Status:OP - Operating Status Year:2014
NAICS:336212 (Primary) - Truck Trailer Manufacturing
Comments:All permitted conditions are listed in units and processes. Other equipment are listed as informational purposes (DAQ Edit 08/17/2022: informational purposes only equipment includes "Foam
Application Stations")
Review Comments:

CONTACTS
Emissions Contact:Mr. Dennis Wilson
Phone [phone]
Email [e-mail]

ADDRESS
Location Address:1111 South 1000 West.
Clearfield, UT 84016 Mailing Address:1111 South 1000 West.
Clearfield, UT 84016

LOCATION
Latitude (decimal degress):41.098731 Longitude (decimal degress):-112.042337
UTM X (meters):412468.137739 UTM Y (meters):4550240.652781 UTM Zone:12

REPORTING REQUIREMENTS
Minor (State Requirement)
Ozone SIP (Annual Ozone Emission Statement) (SIP Requirement)

ADDITIONAL INFORMATION
Field Name Field Value
Customer ID P000008327A
Owner Name Utility Trailer Manufacturing Company

2/11
RELEASE POINTS
ID Type Description Status Details Location
3677 Vertical Main Stack OP Height: 38.0 FEET, Shape: Circular, Diameter: 3.0 FEET, Temperature:
68.0 F, Flow Rate: 426.23558 ACFS, Velocity: 60.3 FPS Uses Facility Site Location
182854 Vertical Emergency Generator OP Height: 10.0 FEET, Shape: Circular, Diameter: 1.0 FEET, Temperature:
72.0 F, Flow Rate: 12.0 ACFS, Velocity: 15.27887 FPS Uses Facility Site Location
927602 Fugitive Area Forklif t Fugitive OP Fugitive Height: , Fugitive Width: , Fugitive Length: , Fugitive Angle:Uses Facility Site Location
927838 Fugitive Area Yard Tractors & Emergency OP Fugitive Height: , Fugitive Width: , Fugitive Length: , Fugitive Angle:Uses Facility Site Location
939015 Fugitive Area Sw eeper & Rental Forklifts OP Fugitive Height: , Fugitive Width: , Fugitive Length: , Fugitive Angle:Uses Facility Site Location
3/11
CONTROL DEVICES
ID Description Status Control Measure Controlled Pollutants
4/11
EMISSION UNITS
ID Type Description Status Details
996 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Forklift OP Operation Start: , Design Capacity:
1232 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Yard Tractors & Emergency OP Operation Start: , Design Capacity:
13496 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Sw eeper & Rental Forklif ts OP Operation Start: , Design Capacity:
14552 490 - Other evaporative sources Spray Painting OP Operation Start: , Design Capacity:
Comment: Paint Booths
14568 490 - Other evaporative sources Wipe Dow n Cleaning OP Operation Start: , Design Capacity:
17399 490 - Other evaporative sources Caulking OP Operation Start: , Design Capacity:
19960 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Space Heating OP Operation Start: , Design Capacity:
176834 490 - Other evaporative sources Touch Up paint OP Operation Start: , Design Capacity:
5/11
UNIT PROCESSES
Emission Unit ID Unit Process ID SCC Description Status Details
996
Forklift 1 2268003020 Forklift OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
927602 - Forklift Fugitive: 100.0%
1232
Yard Tractors &
Emergency
1 2270002066 Yard Tractors & Emergency OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
927838 - Yard Tractors & Emergency: 100.0%
13496
Sw eeper & Rental
Forklifts
1 2267003030 Sw eeper & Rental Forklif ts OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
939015 - Sw eeper & Rental Forklif ts: 100.0%
14552
Spray Painting 1 40201625 Spray Painting OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
14568
Wipe Dow n Cleaning 1 40200101 Wipe Dow n Cleaning OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
17399
Caulking 1 40200701 Caulking OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
19960
Space Heating 1 10500106 Space Heating OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
176834
Touch Up paint 1 40201625 Spray Painting - Touch Up OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
6/11
PROCESS EMISSIONS
Emission Unit ID Unit Process ID Throughput Operations
996
Forklift
1
Forklift
Annual Throughput: 15,645.0 GALLONS (Natural Gas) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: My throughput is in dekatherms
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)0.000002041723049 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00001597137855
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)0.000002041723049 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00001597137855
Overall Control Efficiency: 0.0%
SO2 - Sulf ur Dioxide 0.000000371714473 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000002907736465
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 0.000064203160191 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000502229220594
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 0.000000901668804 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000007053304219
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 0.00043526505474 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.003404860890703
Overall Control Efficiency: 0.0%
Emission Unit ID Unit Process ID Throughput Operations
1232
Yard Tractors &
Emergency
1
Yard Tractors &
Emergency
Annual Throughput: 39,749.0 GALLONS (Distillate Oil (Diesel)) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: I have included Emergency generator diesel (140 gallons) in the 2021 total
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)0.025470254899 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.506208580990175
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)0.024706147252 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.491022323559874
Overall Control Efficiency: 0.0%
7/11
SO2 - Sulf ur Dioxide 0.00019917707357 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.003958544748666
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 0.16936608426 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)3.36606624162537
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 0.032441444193 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.644757482613778
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 0.15916689116 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)3.16336237835942
Overall Control Efficiency: 0.0%
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
Emission Unit ID Unit Process ID Throughput Operations
13496
Sw eeper & Rental
Forklifts
1
Sw eeper & Rental
Forklifts
Annual Throughput: 4,151.0 GALLONS (Liquif ied Petroleum Gas (LPG)) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)0.0015329563559 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00318165091667
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)0.0015329563559 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00318165091667
Overall Control Efficiency: 0.0%
SO2 - Sulf ur Dioxide 0.00028326326919 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000587912915203
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 0.03440454416 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.07140663140408
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 0.0070182585921 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.014566395707903
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 0.21656810413 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.449487100121815
Overall Control Efficiency: 0.0%
Emission Unit ID Unit Process ID Throughput Operations
14552
Spray Painting
1
Spray Painting
Annual Throughput: 28,890.0 GALLONS (Coating) (Output)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
8/11
Comment: 2.13 lb/gal Weighted VOC including HAPs *Our company w as involved a cyber event last year. Most of our data w as lost. We w ere able to salvage some info and extrapolate for our "process emission"
submissions. As w e go forw ard w e may update. Paint Booth
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.57
PM25-PRI - PM2.5 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.57
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)30.7
100414 - Ethyl Benzene 3_0 - Material Balance (no EF)0.02
Emission Comment: total for all coatings
108101 - Methyl Isobutyl Ketone 3_0 - Material Balance (no EF)0.001
Emission Comment: total for all coatings
1330207 - Xylenes (Mixed Isomers) 3_0 - Material Balance (no EF)0.12
Emission Comment: total for all coatings
Emission Unit ID Unit Process ID Throughput Operations
14568
Wipe Dow n
Cleaning
1
Wipe Dow n
Cleaning
Annual Throughput: 2,303.0 GALLONS (Coating) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 260.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: 1.4 lb/gal w eighted VOC including HAPS no HAP above thresholds
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)1.6
Emission Unit ID Unit Process ID Throughput Operations
17399
Caulking
1
Caulking
Annual Throughput: 13,768.0 GALLONS (Coating) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 50.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: 0.09 lb/gal VOC w eighted
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)0.06
Emission Unit ID Unit Process ID Throughput Operations
9/11
19960
Space Heating
1
Space Heating
Annual Throughput: 28.91 MILLION CUBIC FEET (Natural Gas) (Input)
Start Time: 06:30 AM, Stop Time: 02:30 PM
Average Hours/Day: 8.0, Days/Week: 5.0, Weeks/Year: 16.0
Actual Days/Year: 80.0
Actual Hours/Year: 640.0
Monthly Operations: Jan: 26.0%, Feb: 30.0%, Mar: 16.0%, Apr: 6.7%, May: 3.4%, Jun: 0.0%, Jul: 0.0%, Aug:
0.0%, Sep: 0.0%, Oct: 2.3%, Nov: 5.3%, Dec: 10.3%
Emission Unit ID Unit Process ID Throughput Operations
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)7.6 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.109857999999999
Overall Control Efficiency: 0.0%
PM10-FIL - PM10 Filterable 1.9 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.027464499999999
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)7.6 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.109857999999999
Overall Control Efficiency: 0.0%
PM25-FIL - PM2.5 Filterable 1.9 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.027464499999999
Overall Control Efficiency: 0.0%
PM-CON - PM Condensible 5.7 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.0823935
Overall Control Efficiency: 0.0%
SO2 - Sulf ur Dioxide 0.6 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.008673
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 94.0 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)1.35877
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 5.5 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.0795025
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 40.0 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.5782
Overall Control Efficiency: 0.0%
7439921 - Lead 0.0005 E6FT3 - MILLION CUBIC FEET 8_4 - EPA Emission Factor (pre-control)0.0000072275
Overall Control Efficiency: 0.0%
NH3 - Ammonia 0.49 E6FT3 - MILLION CUBIC FEET 8_4 - EPA Emission Factor (pre-control)0.00708295
Overall Control Efficiency: 0.0%
Emission Unit ID Unit Process ID Throughput Operations
10/11
176834
Touch Up paint
1
Spray Painting -
Touch Up
Annual Throughput: 309.0 GALLONS (Coating) (Output)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 260.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Emission Unit ID Unit Process ID Throughput Operations
Comment: 3.5 lb/ gal w eighted VOC includes HAPS (none above threshholds)
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.0
Emission Comment: emissions are negligible due to low throughput
PM25-PRI - PM2.5 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.0
Emission Comment: emissions are negligible due to low throughput
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)0.54
100414 - Ethyl Benzene 3_0 - Material Balance (no EF)0.012
108101 - Methyl Isobutyl Ketone 3_0 - Material Balance (no EF)0.001
108883 - Toluene 3_0 - Material Balance (no EF)0.15
1330207 - Xylenes (Mixed Isomers) 3_0 - Material Balance (no EF)0.12
11/11
2022 Emissions Inventory Report
Utility Trailer Manufacturing Company: Trailer Manufacturing Facility (10156)
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)0.79316 0.19422 0.98738
PM10-FIL PM10 Filterable 0.02829 <.00001 0.02829
PM25-PRI PM2.5 Primary (Filt + Cond)0.79316 0.18848 0.98165
PM25-FIL PM2.5 Filterable 0.02829 <.00001 0.02829
PM-CON PM Condensible 0.08487 <.00001 0.08487
SO2 Sulfur Dioxide 0.00893 0.00206 0.01099
NOX Nitrogen Oxides 1.39966 1.33982 2.73948
VOC Volatile Organic Compounds 38.24189 0.25739 38.49929
CO Carbon Monoxide 0.5956 1.62694 2.22254
7439921 Lead 0.00001 <.00001 0.00001
NH3 Ammonia 0.0073 <.00001 0.0073

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
100414 Ethyl Benzene (HAP)VOC 0.002
108101 Methyl Isobutyl Ketone (HAP)VOC 0.0001
108883 Toluene (HAP)VOC 0.09
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.03

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/11
2022 Emissions Inventory Report
Utility Trailer Manufacturing Company: Trailer Manufacturing Facility (10156)
FACILITY
Facility Identifier:10156 Facility Name:Utility Trailer Manufacturing Company: Trailer Manufacturing Facility
Description:
Status:OP - Operating Status Year:2014
NAICS:336212 (Primary) - Truck Trailer Manufacturing
Comments:All permitted conditions are listed in units and processes. Other equipment are listed as informational purposes (DAQ Edit 08/17/2022: informational purposes only equipment includes "Foam
Application Stations")
Review Comments:

CONTACTS
Emissions Contact:Mr. Dennis Wilson
Phone [phone]
Email [e-mail]

ADDRESS
Location Address:1111 South 1000 West.
Clearfield, UT 84016 Mailing Address:1111 South 1000 West.
Clearfield, UT 84016

LOCATION
Latitude (decimal degress):41.098731 Longitude (decimal degress):-112.042337
UTM X (meters):412468.137739 UTM Y (meters):4550240.652781 UTM Zone:12

REPORTING REQUIREMENTS
Minor (State Requirement)
Ozone SIP (Annual Ozone Emission Statement) (SIP Requirement)

ADDITIONAL INFORMATION
Field Name Field Value
Customer ID P000008327A
Owner Name Utility Trailer Manufacturing Company

2/11
RELEASE POINTS
ID Type Description Status Details Location
3677 Vertical Main Stack OP Height: 38.0 FEET, Shape: Circular, Diameter: 3.0 FEET, Temperature:
68.0 F, Flow Rate: 426.23558 ACFS, Velocity: 60.3 FPS Uses Facility Site Location
182854 Vertical Emergency Generator OP Height: 10.0 FEET, Shape: Circular, Diameter: 1.0 FEET, Temperature:
72.0 F, Flow Rate: 12.0 ACFS, Velocity: 15.27887 FPS Uses Facility Site Location
927602 Fugitive Area Forklif t Fugitive OP Fugitive Height: , Fugitive Width: , Fugitive Length: , Fugitive Angle:Uses Facility Site Location
927838 Fugitive Area Yard Tractors & Emergency OP Fugitive Height: , Fugitive Width: , Fugitive Length: , Fugitive Angle:Uses Facility Site Location
939015 Fugitive Area Sw eeper & Rental Forklifts OP Fugitive Height: , Fugitive Width: , Fugitive Length: , Fugitive Angle:Uses Facility Site Location
3/11
CONTROL DEVICES
ID Description Status Control Measure Controlled Pollutants
4/11
EMISSION UNITS
ID Type Description Status Details
996 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Forklift OP Operation Start: , Design Capacity:
1232 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Yard Tractors & Emergency OP Operation Start: , Design Capacity:
13496 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Sw eeper & Rental Forklif ts OP Operation Start: , Design Capacity:
14552 490 - Other evaporative sources Spray Painting OP Operation Start: , Design Capacity:
Comment: Paint Booths
14568 490 - Other evaporative sources Wipe Dow n Cleaning OP Operation Start: , Design Capacity:
17399 490 - Other evaporative sources Caulking OP Operation Start: , Design Capacity:
19960 290 - Other combustion - Fuel Comb. Equipment (includes
space heaters, asphalt kettle heaters, etc.)Space Heating OP Operation Start: , Design Capacity:
176834 490 - Other evaporative sources Touch Up paint OP Operation Start: , Design Capacity:
5/11
UNIT PROCESSES
Emission Unit ID Unit Process ID SCC Description Status Details
996
Forklift 1 2268003020 Forklift OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
927602 - Forklift Fugitive: 100.0%
1232
Yard Tractors &
Emergency
1 2270002066 Yard Tractors & Emergency OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
927838 - Yard Tractors & Emergency: 100.0%
13496
Sw eeper & Rental
Forklifts
1 2267003030 Sw eeper & Rental Forklif ts OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
939015 - Sw eeper & Rental Forklif ts: 100.0%
14552
Spray Painting 1 40201625 Spray Painting OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
14568
Wipe Dow n Cleaning 1 40200101 Wipe Dow n Cleaning OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
17399
Caulking 1 40200701 Caulking OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
19960
Space Heating 1 10500106 Space Heating OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
176834
Touch Up paint 1 40201625 Spray Painting - Touch Up OP
Control Approach
Controlled?: No
Description: No Process Controls
Release Point Apportionment:
3677 - Main Stack: 100.0%
6/11
PROCESS EMISSIONS
Emission Unit ID Unit Process ID Throughput Operations
996
Forklift
1
Forklift
Annual Throughput: 16,117.0 GALLONS (Natural Gas) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: My throughput is in dekatherms
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)0.000002041723049 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00001645322519
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)0.000002041723049 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00001645322519
Overall Control Efficiency: 0.0%
SO2 - Sulf ur Dioxide 0.000000371714473 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.00000299546108
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 0.000064203160191 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000517381166399
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 0.000000901668804 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000007266098057
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 0.00043526505474 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.003507583443622
Overall Control Efficiency: 0.0%
Emission Unit ID Unit Process ID Throughput Operations
1232
Yard Tractors &
Emergency
1
Yard Tractors &
Emergency
Annual Throughput: 15,011.0 GALLONS (Distillate Oil (Diesel)) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: I have included Emergency generator diesel (104.4 gallons) in the 2022 total
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)0.025470254899 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.191166998144444
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)0.024706147252 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.185431988199886
Overall Control Efficiency: 0.0%
7/11
SO2 - Sulf ur Dioxide 0.00019917707357 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.001494923525679
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 0.16936608426 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)1.27117714541343
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 0.032441444193 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.243489259390561
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 0.15916689116 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)1.19462710160138
Overall Control Efficiency: 0.0%
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
Emission Unit ID Unit Process ID Throughput Operations
13496
Sw eeper & Rental
Forklifts
1
Sw eeper & Rental
Forklifts
Annual Throughput: 3,960.0 GALLONS (Liquif ied Petroleum Gas (LPG)) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)0.0015329563559 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.003035253584682
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)0.0015329563559 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.003035253584682
Overall Control Efficiency: 0.0%
SO2 - Sulf ur Dioxide 0.00028326326919 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.000560861272996
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 0.03440454416 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.0681209974368
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 0.0070182585921 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.013896152012358
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 0.21656810413 GAL - GALLONS 8_2 - EPA WebFIRE Emission Factor (pre-control)0.4288048461774
Overall Control Efficiency: 0.0%
Emission Unit ID Unit Process ID Throughput Operations
14552
Spray Painting
1
Spray Painting
Annual Throughput: 26,521.0 GALLONS (Coating) (Output)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
8/11
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.68
Emission Comment: Assume same as PM2.5
PM25-PRI - PM2.5 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.68
Emission Comment: Assume same as PM10
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)33.3
100414 - Ethyl Benzene 3_0 - Material Balance (no EF)0.0
Emission Comment: total for all coatings
108101 - Methyl Isobutyl Ketone 3_0 - Material Balance (no EF)0.0
Emission Comment: total for all coatings
1330207 - Xylenes (Mixed Isomers) 3_0 - Material Balance (no EF)0.02
Emission Comment: total for all coatings
Emission Unit ID Unit Process ID Throughput Operations
14568
Wipe Dow n
Cleaning
1
Wipe Dow n
Cleaning
Annual Throughput: 2,126.0 GALLONS (Coating) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 260.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)2.9
Emission Unit ID Unit Process ID Throughput Operations
17399
Caulking
1
Caulking
Annual Throughput: 13,242.0 GALLONS (Coating) (Input)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 50.0
Actual Days/Year: 250.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Comment: 0.09 lb/gal VOC w eighted
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)0.26
Emission Unit ID Unit Process ID Throughput Operations
9/11
19960
Space Heating
1
Space Heating
Annual Throughput: 29.78 MILLION CUBIC FEET (Natural Gas) (Input)
Start Time: 06:30 AM, Stop Time: 02:30 PM
Average Hours/Day: 8.0, Days/Week: 5.0, Weeks/Year: 16.0
Actual Days/Year: 80.0
Actual Hours/Year: 640.0
Monthly Operations: Jan: 26.0%, Feb: 30.0%, Mar: 16.0%, Apr: 6.7%, May: 3.4%, Jun: 0.0%, Jul: 0.0%, Aug:
0.0%, Sep: 0.0%, Oct: 2.3%, Nov: 5.3%, Dec: 10.3%
Emission Unit ID Unit Process ID Throughput Operations
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond)7.6 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.113164
Overall Control Efficiency: 0.0%
PM10-FIL - PM10 Filterable 1.9 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.028291
Overall Control Efficiency: 0.0%
PM25-PRI - PM2.5 Primary (Filt + Cond)7.6 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.113164
Overall Control Efficiency: 0.0%
PM25-FIL - PM2.5 Filterable 1.9 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.028291
Overall Control Efficiency: 0.0%
PM-CON - PM Condensible 5.7 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.084873
Overall Control Efficiency: 0.0%
SO2 - Sulf ur Dioxide 0.6 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.008934
Overall Control Efficiency: 0.0%
NOX - Nitrogen Oxides 94.0 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)1.39966
Overall Control Efficiency: 0.0%
VOC - Volatile Organic Compounds 5.5 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.081895
Overall Control Efficiency: 0.0%
CO - Carbon Monoxide 40.0 E6FT3 - MILLION CUBIC FEET 8_2 - EPA WebFIRE Emission Factor (pre-control)0.5956
Overall Control Efficiency: 0.0%
7439921 - Lead 0.0005 E6FT3 - MILLION CUBIC FEET 8_4 - EPA Emission Factor (pre-control)0.000007445
Overall Control Efficiency: 0.0%
NH3 - Ammonia 0.49 E6FT3 - MILLION CUBIC FEET 8_4 - EPA Emission Factor (pre-control)0.0072961
Overall Control Efficiency: 0.0%
Emission Unit ID Unit Process ID Throughput Operations
10/11
176834
Touch Up paint
1
Spray Painting -
Touch Up
Annual Throughput: 542.0 GALLONS (Coating) (Output)
Start Time: 06:30 AM, Stop Time: 02:00 AM
Average Hours/Day: 18.0, Days/Week: 5.0, Weeks/Year: 52.0
Actual Days/Year: 260.0
Actual Hours/Year: 4,500.0
Monthly Operations: Jan: 8.5%, Feb: 7.77%, Mar: 8.5%, Apr: 8.2%, May: 8.5%, Jun: 8.2%, Jul: 8.5%, Aug:
8.5%, Sep: 8.2%, Oct: 8.5%, Nov: 8.2%, Dec: 8.5%
Emission Unit ID Unit Process ID Throughput Operations
Pollutant Emis. Factor (Lbs/UOM)Emis. Factor UOM Calculation Method Estimated Emis. (Tons)
PM10-PRI - PM10 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.0
Emission Comment: emissions are negligible due to low throughput
PM25-PRI - PM2.5 Primary (Filt + Cond) 2_0 - Engineering Judgement (no EF)0.0
Emission Comment: emissions are negligible due to low throughput
VOC - Volatile Organic Compounds 3_0 - Material Balance (no EF)1.7
100414 - Ethyl Benzene 3_0 - Material Balance (no EF)0.002
108101 - Methyl Isobutyl Ketone 3_0 - Material Balance (no EF)0.0001
108883 - Toluene 3_0 - Material Balance (no EF)0.09
1330207 - Xylenes (Mixed Isomers) 3_0 - Material Balance (no EF)0.01
11/11
2023 Emissions Inventory Report
Utility Trailer Manufacturing Company: Trailer Manufacturing Facility (10156)
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)0.48624 0.23548 0.72172
PM10-FIL PM10 Filterable 0.02906 <.00001 0.02906
PM25-PRI PM2.5 Primary (Filt + Cond)0.48624 0.22849 0.71474
PM25-FIL PM2.5 Filterable 0.02906 <.00001 0.02906
PM-CON PM Condensible 0.08718 <.00001 0.08718
SO2 Sulfur Dioxide 0.00918 0.00231 0.01149
NOX Nitrogen Oxides 1.43773 1.60773 3.04546
VOC Volatile Organic Compounds 28.70412 0.30859 29.01272
CO Carbon Monoxide 0.6118 1.82961 2.44141
7439921 Lead 0.00001 <.00001 0.00001
NH3 Ammonia 0.00749 <.00001 0.00749

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
108101 Methyl Isobutyl Ketone (HAP)VOC 0.0001
108883 Toluene (HAP)VOC 0.06
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.02

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
2/2
Source:Utility Trailer
Site:Trailer Manufacture Facility
Project #:N10156-0019
AN101560017-17 permit new
change AO
TPY TPY TPY
PM10 Total 21.48 0.00 238.66
PM10 point 21.48 0.00 0.00
PM10 fugtive 0.00 0.00 0.00
PM2.5 Total 21.48 0.00 202.28
NOx 26.83 0.00 222.73
CO 5.47 0.00 13.23
SOx 0.22 0.00 49.60 HAP Summary Sheet
VOC Total 69.00 -20.00 49.00 Existing Change New
VOC point 0.00 0.00 168.44 TPY TPY TPY
VOC Fugtive 0.00 0.00 0.00 24.5 0 24.5
HAPs 24.50 0.00 612.60
GHGs ???
Emissions inventory
VOC Actual
Year TPY
2021 33.64
2022 38.5
2023 29.02
Aveage actual 33.72
Source:Utility Trailer
Site:Trailer manufacture facility
Project #:N10156-0019
Existing Change New
TPY TPY TPY
HAPs Totals 8.93483 2.66480 0.00000
Existing Change New Existing Change
HAP TPY TPY TPY lb/yr lb/yr
Acetaldehyde 0.771 0.02480 1542.00
Acrolein 0.680 1360.00
Benzene 1.200 2.64000 2400.00
1,3-Butadiene 0.001 2.65
Ethyl Benzene 0.020 40.00
Formaldehyde 3.800 7600.00
Methanol 0.617 1234.00
Hexane 1.140 2280.00
2,2,4-Trimethylpentane 0.030 60.00
Toluene 0.440 880.00
Xylene 0.160 320.00
Generic 0.076 151.00Total8.93483 2.66480
HAP's Modeling Existing Increase New
Source Source Source
HAP lb/hr lb/hr lb/hr <20m 20-50 50-100
2,2,4-Trimethylpentane
Acetaldehyde 0.00000 1.71155 2.29709 4.14376
Acrolein 0.00000 0.00871 0.01169 0.02109
Benzene 0.00000 0.02720 0.03510 0.06550
Cobalt 0.00000 0.00100 0.00130 0.00250
Ethylbenzene 0.00000 22.14000 28.66000 53.41000
Formaldehyde 0.00000 0.01400 0.01880 0.03390
Hex. Chromium 0.00000 0.00020 0.00020 0.00040
n-Hexane 0.00000 8.98810 11.63166 21.67718
Methanol 0.00000 14.20074 18.37742 34.24883
Naphthalene 0.00000 2.67000 3.46000 6.45000
Nickel 0.00000 0.00170 0.00220 0.00410
Toluene 0.00000 3.84000 4.97000 9.27000
Xylene 0.00000 22.14000 28.66000 53.41000
Vert. Restricted (lb/hr)
New Change hr/yr=
lb/yr lb/hr
Modeling
>100 <50 50-100 >100 Required
8.10736 6.93630 10.08916 13.96268
0.04127 0.03531 0.05136 0.07108
0.14380 0.10540 0.12940 0.19650
0.00540 0.00400 0.00450 0.00740
116.80000 85.97000 97.26000 159.78000
0.06630 0.05670 0.08250 0.11420
0.00090 0.00070 0.00080 0.00120
47.40781 34.89497 39.47714 64.85530
74.90192 55.13227 62.37186 102.46806
14.10000 10.38000 11.74000 19.29000
0.00900 0.00660 0.00810 0.01230
20.27000 14.92000 16.88000 27.73000
116.80000 85.97000 97.26000 159.78000
Vert. Unrestricted (lb/hr)