DAQ-2024-011067

DAQE-AN141770005-24

{{$d1 }}

Gene Chrisenbery
Mountain States Asphalt, Inc.
PO Box 1268
Tooele, UT 84074
[e-mail]

Dear Mr. Chrisenbery:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN141770004-21 to
Update VOC Emissions from the Plant
Project Number: N141770005

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on May 15,
2024. Mountain States Asphalt, Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Tim DeJulis, 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:TD:jg

cc: Tooele County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [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

September 10, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN141770005-24
Administrative Amendment to Approval order
DAQE-AN141770004-21 to Update
VOC Emissions from the Plant

Prepared By
Mr. Tim DeJulis, Engineer
[phone]
[e-mail]

Issued to
Mountain States Asphalt, Inc. - Liquid Asphalt, ATB's, and Crude Oil
Terminal

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 10, 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 ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-AN141770005-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Mountain States Asphalt, Inc. Mountain States Asphalt, Inc. - Liquid Asphalt, ATB's, and Crude Oil Terminal

Mailing Address Physical Address
PO Box 1268 205 South Emerald Road
Tooele, UT 84074 Tooele, UT 84074

Source Contact UTM Coordinates
Name: Gene Chrisenbery 386,886 m Easting
Phone: [phone],487,155 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2951 (Asphalt Paving Mixtures & Blocks)

SOURCE INFORMATION
General Description
Mountain States Asphalt, Inc. (MSA) receives asphalt, atmospheric tower bottoms (ATB), and other
assorted crude oils (ACO) at the plant, located in Tooele, Tooele County, by train or truck. Thirty-six (36)
vertical fixed roof (VFR) tanks will store the asphalt, ATBs, or ACO. Thirty-one (31) train/truck
unloading/loading stations are in the plant. The emissions from the asphalt, ATB, or ACO
unloading/loading and storage tanks will be controlled by a submerged filling system, a vapor balancing
system, and an enclosed flare device.

The asphalt is sold to third-party customers to make asphalt paving materials at various locations
throughout the area. The local petroleum refineries will use this terminal to store ATBs and ACO until
they are ready to process it in their separate plants.

The ATBs and ACO terminal will be capable of a throughput of 3,266,750 barrels (137,203,500 gallons)
per rolling 12-month period. The production of asphalt will be capable of a throughput of 1,095,238
barrels (46,000,000 gallons) per rolling 12-month period.

NSR Classification
Administrative Amendment

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Tooele County
Airs Source Size: SM

DAQE-AN141770005-24
Page 4

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units
NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984

Project Description
MSA has requested permission to update AO DAQE-AN141770004-21, dated February 18, 2021. MSA
will use the latest EPA Tanks 5.0 to estimate the emissions of VOC. Using EPA Tanks 5.0, the emissions
from the source will be reduced from 60.24 tpy to 31.18 tpy. This methodology will make the source a
synthetic minor source under serious ozone nonattainment area thresholds. No other changes are being
made to the plant. This change is done under R307-401-12, Reduction in Air Pollutants.

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)
CO2 Equivalent 0 6544.00
Carbon Monoxide 0 22.84
Nitrogen Oxides 0 15.21
Particulate Matter - PM10 0 1.26
Particulate Matter - PM2.5 0 0.12
Sulfur Dioxide 0 0.12
Sulfur Oxides 0.12
Volatile Organic Compounds -29.06 31.18

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 660
Ethyl Benzene (CAS #100414) 0 1300
Generic HAPs (CAS #GHAPS) 0 340
PAH, Total (CAS #234) 0 3260
Toluene (CAS #108883) 0 6500
Xylenes (Isomers And Mixture) (CAS #1330207) 0 6500
Change (TPY) Total (TPY)
Total HAPs 0 9.28

DAQE-AN141770005-24
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 Distribution Terminal Asphalt, ATBs, and Crude Oil Distribution Terminal
II.A.2 Primary Storage Tanks
Four (4) VFR tanks Capacity: 120,861 barrels each
Service: asphalt
Three (3) VFR tanks
Capacity: 83,932 barrels each
Service: ATBs or ACO NSPS Subpart Kb

DAQE-AN141770005-24
Page 6

II.A.3 Asphalt Blending Tanks Fifteen (15) vertical, fixed roof storage tanks Capacity: 38,000 barrels each Three (3) vertical, fixed roof storage tanks Capacity: 20,144 barrels each Four (4) vertical, fixed roof storage tanks Capacity: 6,855 barrels each Four (4) vertical, fixed roof storage tanks Capacity: 5,036 barrels each Ten (10) vertical, fixed roof storage tanks Capacity: 1,095 barrels each Twelve (12) vertical, fixed roof storage tanks Capacity: 895 barrels each
II.A.4 Water or Latex Storage Tanks
Seven (7) vertical, fixed roof storage tanks Capacity: 476 barrels each

For information purposes only.
II.A.5 Boilers Three (3) boilers Capacity: 10 MMBtu/hr each Fuel: natural gas NSPS Subpart Dc
II.A.6 Asphalt/Crude Oil Product Loading Racks
Thirty-one (31) Unloading/Loading Racks

Ten (10) rail car asphalt unloading/loading racks One (1) truck asphalt unloading rack
Three (3) truck asphalt loading racks
Two (2) truck asphalt emulsion loading racks Thirteen (13) rail car unloading/loading racks
Two (2) truck unloading/loading racks
Attached equipment: submerged filling and vapor capture system
II.A.7 Flare Device Capacity: 9 MMBtu/hr Pilot light fuel is natural gas

DAQE-AN141770005-24
Page 7

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Requirements
II.B.1.a Unless otherwise stated in this AO, the owner/operator shall not allow visible emissions to
exceed the following:

A. All boilers - 10% opacity.

B. Flare device - 0% opacity.

C. Haul roads and mobile equipment operating areas - 20% opacity.

D. At the property boundary - 10% opacity.

[R307-309-5, R307-401-8]

II.B.1.a.1 Unless otherwise stated, 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.a.2 Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas
shall not exceed the above opacity limit at any point. Visible emission determinations shall use
procedures similar to Method 9.

The normal requirement for observations to be made at 15-second intervals over a six-minute
period, however, shall not apply. Visible emissions shall be measured at the densest point of the
plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the
height of the vehicle.

[R307-309-9]

II.B.2 Roads and Fugitive Dust
II.B.2.a An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit
Application Website. If a written FDCP is completed, it shall be submitted to the Director,
Attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP
for control of all fugitive dust sources associated with the asphalt, ATBs, or black wax crude oil
terminal. [R307-309-6]

II.B.2.b The owner/operator shall pave in-plant haul roads. The paved in-plant haul roads shall not be less than 0.50 miles in combined length. [R307-401-8]
II.B.2.b.1 Compliance shall be determined through Global Positioning System (GPS) measurements or
aerial photographs. [R307-401-8]

II.B.2.c The owner/operator shall sweep, or spray clean the paved in-plant haul roads to maintain the opacity limits in this AO. [R307-309-6, R307-401-8]
II.B.2.c.1 Records of cleaning paved roads shall be kept for all periods the plant is in operation. The
records shall include the following items:
1. Date of cleaning(s).
2. Time of day cleaning(s) were performed.

[R307-309-6, R307-401-8]
DAQE-AN141770005-24
Page 8

II.B.3 Loading Rack and Storage Tank Requirements II.B.3.a The owner/operator shall not exceed the following limits:
A. 1,095,238 barrels (46,000,000 gallons) of asphalt product throughput per rolling 12-month period.
B. 3,266,750 barrels (137,203,500 gallons) of ATBs, or ACO throughput per rolling 12-month period.
[R307-401-8]
II.B.3.a.1 The owner/operator shall: A. Determine the asphalt product, ATB, and ACO throughput by examination of company and/or customer billing records. B. Record production on a daily basis. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the asphalt product, ATB, and ACO throughput records for all periods the plant is in operation. [R307-401-8]
II.B.3.b The owner/operator shall not store any crude oil with an RVP greater than 11.2 psi.
[R307-401-8]
II.B.3.b.1 The owner/operator shall: A. Record the RVP of the ACO each time the owner/operator changes to a new crude oil. B. Determine the RVP by the SDS records accompanying each rail car or tanker truck that arrives at the plant. C. Record the RVP for all periods when the plant is in operation. D. Record the RVP in a supervisor's log book. [R307-401-8]
II.B.3.c The owner/operator shall load the tanker trucks and rail cars on site by the use of submerged
loading. [R307-401-8]
II.B.3.d The owner/operator shall control emissions from the loading racks and storage tanks that process the ATB or ACO with a vapor capture system and flare device at all times. [R307-401-8]
II.B.4 Flare and Fuel Requirements
II.B.4.a The owner/operator shall only use natural gas as fuel in the boilers. [R307-401-8]
II.B.4.b The owner/operator shall operate each flare device with a continuous pilot flame and be equipped
with an auto-igniter. [R307-503-4]

II.B.4.c The owner/operator shall operate each flare device with no visible emissions. [R307-401-8]
DAQE-AN141770005-24
Page 9

II.B.4.c.1 Visual determination of emissions from each flare shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] II.B.4.d The owner/operator shall install a flare device that has a certified control efficiency of 99%. [R307-401-8]

II.B.4.d.1 To demonstrate compliance with the control efficiency, the owner/operator shall keep a record of the manufacturer's certification of the control efficiency. The record shall be kept for the life of the equipment. [R307-401-8] II.B.5 LDAR Requirements
II.B.5.a The owner/operator shall develop a fugitive emissions monitoring plan for the storage tanks and flare operations. At a minimum, the plan shall include: A. Monitoring frequency. B. Monitoring technique and equipment. C. Procedures and timeframes for identifying and repairing leaks. D. Recordkeeping practices. E. Calibration and maintenance procedures. [R307-401-8] II.B.5.b The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

II.B.5.c Monitoring surveys shall be conducted according to the following schedule: A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a. B. Semiannually after the initial monitoring survey. Consecutive semiannual monitoring surveys shall be conducted at least 4 months apart. C. Annually after the initial monitoring survey for "difficult to monitor" components. D. As required by the owner/operator's monitoring plan for "unsafe to monitor" components. [R307-401-8]
II.B.5.c.1 Monitoring surveys shall be conducted using one or both of the following to detect fugitive
emissions:

A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of imaging
gases in the spectral range for the compound of highest concentration in the potential
fugitive emissions.

B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A.

[R307-401-8]

II.B.5.c.2 If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive emissions component as soon as possible but no later than 30 calendar days after detection. [R307-401-8]
DAQE-AN141770005-24
Page 10

II.B.5.c.3 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8] II.B.5.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring surveys, repairs, and resurveys. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN141770004-21 dated February 18, 2021 Is Derived From NOI dated May 15, 2024
DAQE-AN141770005-24
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 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-

RN141770005 August 7, 2024 Gene Chrisenbery Mountain States Asphalt, Inc. PO Box 1268
Tooele, UT 84074 [e-mail]
Dear Gene Chrisenbery, Re: Engineer Review - Administrative Amendment to DAQE-AN141770004-21 to Update
VOC Emissions from the Plant Project Number: N141770005 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. Mountain States Asphalt, Inc. should complete this review within 10 business days of receipt. Mountain States Asphalt, Inc. should contact Mr. Tim DeJulis at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Tim DeJulis 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 Mountain States Asphalt, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Mountain States Asphalt, Inc. has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.
Approval Signature __Robert E. Chrisenbery________________9/4/2024_______________________
(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 N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal August 7, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N141770005 Owner Name Mountain States Asphalt, Inc. Mailing Address PO Box 1268
Tooele, UT, 84074 Source Name Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and
Crude Oil Terminal Source Location 205 S. Emerald Rd. Tooele, UT 84074
UTM Projection 386,886 m Easting, 4,487,155 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2951 (Asphalt Paving Mixtures & Blocks) Source Contact Gene Chrisenbery Phone Number [phone] Email [e-mail] Billing Contact Gene Chrisenbery
Phone Number 435-659-1984 Email [e-mail]
Project Engineer Mr. Tim DeJulis, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted May 15, 2024 Date of Accepted Application May 15, 2024

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal August 7, 2024 Page 2
SOURCE DESCRIPTION General Description
Mountain States Asphalt, Inc. (MSA) receives asphalt, atmospheric tower bottoms (ATB), and other assorted crude oils (ACO) at the plant, located in Tooele, Tooele County, by train or truck. Thirty-six vertical fixed roof (VFR) tanks will store the asphalt, ATBs, or ACO. Thirty-one
train/truck unloading/loading stations are in the plant. The emissions from the asphalt, ATB, or ACO unloading/loading and storage tanks will be controlled by a submerged filling system; vapor balancing system; and enclosed flare device. The asphalt is sold to third party customers to make asphalt paving materials at various locations throughout the area. The local petroleum refineries will use this terminal to store ATBs and ACO until they are ready to process it in their separate plants. The ATBs and ACO terminal will be capable of a throughput of 3,266,750 barrels (137,203,500 gallons) per rolling 12-month period. The production of asphalt will be capable of a throughput of 1,095,238 barrels (46,000,000 gallons) per rolling 12-month period.
NSR Classification: Administrative Amendment
Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Tooele County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 Project Proposal Administrative Amendment to DAQE-AN141770004-21 to Update VOC Emissions from the Plant
Project Description MSA has requested permission to update DAQE-AN141770004-21, dated February 18, 2021.
MSA will use the latest EPA Tanks 5.0 to estimate the emissions of VOC. Using EPA Tanks 5.0, the emissions from the source will be reduced from 60.24 tpy to 31.18 tpy. This methodology will make the source a synthetic minor source under serious ozone nonattainment area thresholds. No
other changes are being made to the plant. This change is done under R307-401-12, Reduction in Air Pollutants. EMISSION IMPACT ANALYSIS This is an administrative amendment for an update of VOC emissions using Tanks 5.0. There is no increase in emissions associated with this update. Therefore, this amendment does not trigger the modeling requirements
in R307-410-4 or R307-410-5. [Last updated July 29, 2024]

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal August 7, 2024 Page 3
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) CO2 Equivalent 0 6544.00 Carbon Monoxide 0 22.84
Nitrogen Oxides 0 15.21
Particulate Matter - PM10 0 1.26
Particulate Matter - PM2.5 0 0.12
Sulfur Dioxide 0 0.12
Sulfur Oxides 0.12 Volatile Organic Compounds -29.06 31.18 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 660
Ethyl Benzene (CAS #100414) 0 1300
Generic HAPs (CAS #GHAPS) 0 340
PAH, Total (CAS #234) 0 3260 Toluene (CAS #108883) 0 6500 Xylenes (Isomers And Mixture) (CAS #1330207) 0 6500
Change (TPY) Total (TPY)
Total HAPs 0 9.28

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

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal August 7, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Process Equipment
This is an administrative amendment for an update of VOC emissions using the EPA Tanks 5.0. A BACT analysis is not required for these administrative amendments. [Last updated July 29, 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 N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal August 7, 2024 Page 5
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 Distribution Terminal Asphalt, ATBs, and Crude Oil Distribution Terminal II.A.2 Primary Storage Tanks Four (4) vertical fixed roof tanks Capacity: 120,861 barrels each Service: asphalt Three (3) vertical fixed roof tanks Capacity: 83,932 barrels each Service: ATBs or assorted crude oils NSPS Subpart Kb
II.A.3 Asphalt Blending Tanks
Fifteen (15) vertical, fixed roof storage tanks Capacity: 38,000 barrels each Three (3) vertical, fixed roof storage tanks Capacity: 20,144 barrels each Four (4) vertical, fixed roof storage tanks Capacity: 6,855 barrels each
Four (4) vertical, fixed roof storage tanks
Capacity: 5,036 barrels each
Ten (10) vertical, fixed roof storage tanks Capacity: 1,095 barrels each Twelve (12) vertical, fixed roof storage tanks Capacity: 895 barrels each
II.A.4 Water or Latex Storage Tanks Seven (7) vertical, fixed roof storage tanks Capacity: 476 barrels each For information purpose only.

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal August 7, 2024 Page 6
II.A.5 Boilers Three (3) boilers Capacity: 10 MMBtu/hr each
Fuel: natural gas
NSPS Subpart Dc
II.A.6 Asphalt/Crude Oil Product Loading Racks Thirty-one (31) Unloading/Loading Racks Ten (10) rail car asphalt unloading/loading racks One (1) truck asphalt unloading rack Three (3) truck asphalt loading racks Two (2) truck asphalt emulsion loading racks Thirteen (13) rail car unloading/loading racks
Two (2) truck unloading/loading racks Attached equipment: submerged filling and vapor capture system
II.A.7 Flare Device Capacity: 9 MMBtu/hr Pilot light fuel is natural gas
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 Site Requirements
II.B.1.a NEW Unless otherwise stated in this AO, the owner/operator shall not allow visible emissions to exceed the following:
A. Haul roads and mobile equipment operating areas - 20% opacity
B. At the property boundary - 10% opacity. [R307-309-5, R307-401-8] II.B.1.a.1 Unless otherwise stated, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]

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II.B.1.a.2 NEW Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed the above opacity limit at any point. Visible emission determinations shall use procedures similar to Method 9.
The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-9]
II.B.2 Roads and Fugitive Dust
II.B.2.a NEW An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with the asphalt, ATBs or black wax
crude oil terminal. [R307-309-6] II.B.2.b The owner/operator shall pave in-plant haul roads. The paved in-plant haul roads shall not be less than 0.50 miles in combined length. [R307-401-8]
II.B.2.b.1 Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] II.B.2.c The owner/operator shall sweep, or spray clean the paved in-plant haul roads to maintain the opacity limits in this AO. [R307-309-6, R307-401-8]

II.B.2.c.1 NEW Records of cleaning paved roads shall be kept for all periods the plant is in operation. The records shall include the following items: 1. Date of cleaning(s)
2. Time of day cleaning(s) were performed. [R307-309-6, R307-401-8]

II.B.3 Loading Rack and Storage Tank Requirements
II.B.3.a
NEW
The owner/operator shall not exceed the following limits:
A. 1,095,238 barrels (46,000,000 gallons) of asphalt product throughput per rolling 12- month period B. 3,266,750 barrels (137,203,500 gallons) of ATBs, or ACO throughput per rolling 12-
month period. [R307-401-8]

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II.B.3.a.1 NEW The owner/operator shall:
A. Determine the asphalt product, ATB and ACO throughput by examination of
company and/or customer billing records B. Record production on a daily basis
C. Use the production data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months D. Keep the asphalt product, ATB, and ACO throughput records for all periods the plant is in operation.
[R307-401-8] II.B.3.b NEW The owner/operator shall not store any crude oil with an RVP greater than 11.2 psi. [R307-401-8]
II.B.3.b.1 NEW The owner/operator shall:
A. Record the RVP of the ACO each time the owner/operator changes to a new crude oil.
B. Determine the RVP by the SDS records accompanying each rail car or tanker truck that arrives at the plant.
C. Record the RVP for all periods when the plant is in operation.
D. Record the RVP in a supervisor's log book. [R307-401-8]
II.B.3.c The owner/operator shall load the tanker trucks and rail cars on site by the use of submerged loading. [R307-401-8]
II.B.3.d The owner/operator shall control emissions from the loading racks and storage tanks that process the ATB or ACO, with a vapor capture system and flare device at all times. [R307-401-8]
II.B.4 Flare and Fuel Requirements
II.B.4.a The owner/operator shall only use natural gas as fuel in the boilers. [R307-401-8]
II.B.4.b The owner/operator shall operate each flare device with a continuous pilot flame and be equipped with an auto-igniter. [R307-503-4]
II.B.4.c The owner/operator shall operate each flare device with no visible emissions. [R307-401-8]
II.B.4.c.1 Visual determination of emissions from each flare shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8]

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II.B.4.d The owner/operator shall install a flare device that has a certified control efficiency of 99%. [R307-401-8]
II.B.4.d.1 To demonstrate compliance with the control efficiency, the owner/operator shall keep a record of the manufacturer's certification of the control efficiency. The record shall be kept for the life of the equipment. [R307-401-8] II.B.5 LDAR Requirements II.B.5.a The owner/operator shall develop a fugitive emissions monitoring plan for the storage tanks and flare operations. At a minimum, the plan shall include:
A. Monitoring frequency B. Monitoring technique and equipment C. Procedures and timeframes for identifying and repairing leaks D. Recordkeeping practices
E. Calibration and maintenance procedures. [R307-401-8]
II.B.5.b The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8] II.B.5.c Monitoring surveys shall be conducted according to the following schedule: A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a.
B. Semiannually after the initial monitoring survey. Consecutive semiannual monitoring surveys shall be conducted at least 4 months apart.
C. Annually after the initial monitoring survey for "difficult-to-monitor" components.
D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor" components. [R307-401-8] II.B.5.c.1 Monitoring surveys shall be conducted using one or both of the following to detect fugitive emissions:
A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of imaging gases in the spectral range for the compound of highest concentration in the potential fugitive emissions. B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A. [R307-401-8]

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II.B.5.c.2 If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive emissions component as soon as possible but no later than 30 calendar days after detection. [R307-401-8]

II.B.5.c.3 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8] II.B.5.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring surveys, repairs, and resurveys. [R307-401-8]

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PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN141770004-21 dated February 18, 2021
Is Derived From NOI dated May 15, 2024
REVIEWER COMMENTS

1. Comment regarding Emissions Estimates: The emissions estimates were calculated as follows: Unloading/loading of oil products by AP-42 Section 5.2 Storing asphalt, ATBs, and ACO in tanks by EPA Tanks version 5.0 (ACO is represented by the highest Reid vapor pressure crude oil in the emission calculations due it having a higher emissions potential, compared to ATB's or asphalt.) Flare device by AP-42 Section 13.5 Boiler operation by AP-42 Section 1.4 Equipment leaks by EPA-435/R-95-017 CO2e by AP-42 Table 1.4-2; and Part 98, Subpart A, Table A-1. [Last updated July 29, 2024]
2. Comment regarding NSPS and MACT: 40 CFR 60 (NSPS) 40 CFR 60 Subpart Dc applies to owners and operators of small industrial-commercial-institutional
steam generating units (boilers) between 100 MMBtu/hr and 10 MMBtu/hr. This steam generating unit or boiler uses NG and the reporting is to document how much NG is used. Since this source will have three steam generators or boilers at 10 MMBtu/hr, NSPS Subpart Dc will apply to this plant.
40 CFR 60 Subpart Kb applies to owners and operators of organic liquid storage vessels greater than
75 m3 (with a vapor pressure greater than 15 kPa) and 151 m3 (with a vapor pressure greater than 3.5 kPa). This site has three storage tanks with 19,215 m3; therefore, Subpart Kb applies to this source.
40 CFR 60 Subpart VVa applies to owners and operators of equipment leaks in the synthetic organic chemicals manufacturing industry (SOCMI). The source does not manufacture any SOCMI with the asphalt or black wax crude oil it receives; therefore, this subpart doesn't apply to this source. 40 CFR 63 (MACT) 40 CFR 63 Subpart LLLLL applies to the asphalt processing and asphalt roofing manufacturing plants (at major sources of HAPs). This is an area source and therefore, Subpart LLLLL doesn't apply to this source. 40 CFR 63 Subpart JJJJJJ applies to industrial, commercial and institutional boilers at area sources. This subpart is for coal or fuel oil-firing of the boilers and the plant uses natural gas. Therefore, Subpart JJJJJJ doesn't apply to this source.
40 CFR 63 Subpart AAAAAAA applies to asphalt processing and asphalt roofing manufacturing plants (at minor sources of HAPs). This is an area source, but does not blow air through the asphalt; therefore, Subpart AAAAAAA does not apply to this source. [Last updated May 15, 2024]

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3. Comment regarding Title V Requirments: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) and 40 CFR 63 (MACT) regulations. The facility is not subject to 40 CFR 61 (NESHAP)
regulations. NSPS Subpart Dc, when natural gas is used, requires the maintenance of consumption records that support no consumption limit. NSPS Subpart Kb requires the source to maintain storage tank dimensions for the life of the tank. Title V does not apply because NSPS Subpart Dc and Kb have record keeping-only requirements. Recordkeeping requirements are not considered standards or limitations. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility.
[Last updated May 15, 2024] 4. Comment regarding Use of EPA Tanks 5.0:
In the existing AO, MSA used EPA Tanks 4.0b tool for the estimation of the VOC emissions from the Tooele asphalt, ATB, and ACO plant, with the result of 60.24 tpy. MSA has proposed to use EPA Tanks 5.0 tool for the estimation of the VOC emissions in the future AO. Use of EPA Tanks 5.0 will result in a VOC emissions rate of 31.18 tpy. [Last updated June 14, 2024]

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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
DAQE-

RN141770005 July 29, 2024 Gene Chrisenbery Mountain States Asphalt, Inc. PO Box 1268
Tooele, UT 84074 [e-mail]
Dear Gene Chrisenbery, Re: Engineer Review - Administrative Amendment to DAQE-AN141770004-21 to Update
VOC Emissions from the Plant Project Number: N141770005 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. Mountain States Asphalt, Inc. should complete this review within 10 business days of receipt. Mountain States Asphalt, Inc. should contact Mr. Tim DeJulis at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Tim DeJulis 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 Mountain States Asphalt, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Mountain States Asphalt, Inc. 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 N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal July 29, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N141770005 Owner Name Mountain States Asphalt, Inc. Mailing Address PO Box 1268
Tooele, UT, 84074 Source Name Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and
Crude Oil Terminal Source Location 205 S. Emerald Rd. Tooele, UT 84074
UTM Projection 386,886 m Easting, 4,487,155 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2951 (Asphalt Paving Mixtures & Blocks) Source Contact Gene Chrisenbery Phone Number [phone] Email [e-mail] Billing Contact Gene Chrisenbery
Phone Number 435-659-1984 Email [e-mail]
Project Engineer Mr. Tim DeJulis, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted May 15, 2024 Date of Accepted Application May 15, 2024

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SOURCE DESCRIPTION General Description
Mountain States Asphalt, Inc. (MSA) receives asphalt, atmospheric tower bottoms (ATB), and other assorted crude oils (ACO) at the plant, located in Tooele, Tooele County, by train or truck. Thirty-six vertical fixed roof (VFR) tanks will store the asphalt, ATBs, or ACO. Thirty-one
train/truck unloading/loading stations are in the plant. The emissions from the asphalt, ATB, or ACO unloading/loading and storage tanks will be controlled by a submerged filling system; vapor balancing system; and enclosed flare device. The asphalt is sold to third party customers to make asphalt paving materials at various locations throughout the area. The local petroleum refineries will use this terminal to store ATBs and ACO until they are ready to process it in their separate plants. The ATBs and ACO terminal will be capable of a throughput of 3,266,750 barrels (137,203,500 gallons) per rolling 12-month period. The production of asphalt will be capable of a throughput of 1,095,238 barrels (46,000,000 gallons) per rolling 12-month period.
NSR Classification: Administrative Amendment
Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Tooele County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 Project Proposal Administrative Amendment to DAQE-AN141770004-21 to Update VOC Emissions from the Plant
Project Description MSA has requested permission to update DAQE-AN141770004-21, dated February 18, 2021.
MSA will use the latest EPA Tanks 5.0 to reduce the emissions of VOC to 31.18 tpy making it a minor ozone source. No other changes are being made to the plant. EMISSION IMPACT ANALYSIS This is an administrative amendment for an update of VOC emissions using Tanks 5.0. There is no increase in emissions associated with this update. Therefore, this amendment does not trigger the modeling requirements in R307-410-4 or R307-410-5. [Last updated July 29, 2024]

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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) CO2 Equivalent 0 6544.00 Carbon Monoxide 0 22.84
Nitrogen Oxides 0 15.21
Particulate Matter - PM10 0 1.26
Particulate Matter - PM2.5 0 0.12
Sulfur Dioxide 0 0.12
Sulfur Oxides 0.12 Volatile Organic Compounds -29.06 31.18 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 660
Ethyl Benzene (CAS #100414) 0 1300
Generic HAPs (CAS #GHAPS) 0 340
PAH, Total (CAS #234) 0 3260 Toluene (CAS #108883) 0 6500 Xylenes (Isomers And Mixture) (CAS #1330207) 0 6500
Change (TPY) Total (TPY)
Total HAPs 0 9.28

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

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Review of BACT for New/Modified Emission Units 1. BACT review regarding Process Equipment
This is an administrative amendment for an update of VOC emissions using the EPA Tanks 5.0. A BACT analysis is not required for these administrative amendments. [Last updated July 29, 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]

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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 Distribution Terminal Asphalt, ATB's, and Crude Oil Distribution Terminal II.A.2 Primary Storage Tanks Four (4) vertical fixed roof tanks Capacity: 120,861 barrels each Service: asphalt Three (3) vertical fixed roof tanks Capacity: 83,932 barrels each Service: ATBs or assorted crude oils NSPS Subpart Kb
II.A.3 Asphalt Blending Tanks
Fifteen (15) vertical, fixed roof storage tanks Capacity: 38,000 barrels each Three (3) vertical, fixed roof storage tanks Capacity: 20,144 barrels each Four (4) vertical, fixed roof storage tanks Capacity: 6,855 barrels each
Four (4) vertical, fixed roof storage tanks
Capacity: 5,036 barrels each
Ten (10) vertical, fixed roof storage tanks Capacity: 1,095 barrels each Twelve (12) vertical, fixed roof storage tanks Capacity: 895 barrels each II.A.4 Water or Latex Storage Tanks Seven (7) vertical, fixed roof storage tanks Capacity: 476 barrels each
For information purpose only.

II.A.5 Boilers Three (3) boilers Capacity: 10 MMBtu/hr each
Fuel: natural gas
NSPS Subpart Dc

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II.A.6 Asphalt/Crude Oil Product Loading Racks Thirty-one (31) Unloading/Loading Racks Ten (10) rail car asphalt unloading/loading racks One (1) truck asphalt unloading rack Three (3) truck asphalt loading racks Two (2) truck asphalt emulsion loading racks Thirteen (13) rail car unloading/loading racks Two (2) truck unloading/loading racks Attached equipment: submerged filling and vapor capture system II.A.7 Flare Device Capacity: 9 MMBtu/hr Pilot light fuel is natural gas
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 Site Requirements II.B.1.a NEW Unless otherwise stated in this AO, the owner/operator shall not allow visible emissions to exceed the following:
A. Haul roads and mobile equipment areas - 20% opacity B. Off property boundary - 10% opacity. [R307-401-8, R307-309-5] II.B.1.a.1 Unless otherwise stated, 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.a.2 NEW Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed the above opacity limit at any point. Visible emission determinations shall use procedures similar to Method 9.
The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-9]

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II.B.2 Roads and Fugitive Dust
II.B.2.a NEW An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with the asphalt, ATBs or black wax crude oil terminal. [R307-309-6] II.B.2.b The owner/operator shall pave in-plant haul roads. The paved in-plant haul roads shall not be less than 0.50 miles in combined length. [R307-401-8]

II.B.2.b.1 Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] II.B.2.c The owner/operator shall sweep, or spray clean the paved in-plant haul roads to maintain the opacity limits in this AO. [R307-309-6, R307-401-8]
II.B.2.c.1 NEW Records of cleaning paved roads shall be kept for all periods the plant is in operation. The records shall include the following items: 1. Date of cleaning(s) 2. Time of day cleaning(s) were performed. [R307-309-6, R307-401-8]

II.B.3 Loading Rack and Storage Tank Requirements
II.B.3.a NEW The owner/operator shall not exceed the following limits:
A. 1,095,238 barrels (46,000,000 gallons) of asphalt product throughput per rolling 12-
month period B. 3,266,750 barrels (137,203,500 gallons) of ATBs, or ACO throughput per rolling 12-
month period. [R307-401-8]
II.B.3.a.1 NEW The owner/operator shall:
A. Determine the asphalt product, ATB and ACO throughput by examination of company and/or customer billing records B. Record production on a daily basis
C. Use the production data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months D. Keep the asphalt product, ATB, and ACO throughput records for all periods the plant is in operation. [R307-401-8]

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II.B.3.b NEW The owner/operator shall not store any crude oil with an RVP greater than 11.2 psi. [R307-401-8]
II.B.3.b.1 NEW The owner/operator shall: A. Record the RVP of the ACO each time the owner/operator changes to a new crude oil. B. Determine the RVP by the SDS records accompanying each rail car or tanker truck that arrives at the plant. C. Record the RVP for all periods when the plant is in operation. D. Record the RVP in a supervisor's log book.
[R307-401-8]
II.B.3.c The owner/operator shall load the tanker trucks and rail cars on site by the use of submerged loading. [R307-401-8]
II.B.3.d The owner/operator shall control emissions from the loading racks and storage tanks that
process the ATB or ACO, with a vapor capture system and flare device at all times. [R307-401-8]
II.B.4 Flare and Fuel Requirements II.B.4.a The owner/operator shall only use natural gas as fuel in the boilers. [R307-401-8]
II.B.4.b The owner/operator shall operate each flare device with a continuous pilot flame and be
equipped with an auto-igniter. [R307-503-4] II.B.4.c The owner/operator shall operate each flare device with no visible emissions. [R307-401-8] II.B.4.c.1 Visual determination of emissions from each flare shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8]

II.B.4.d The owner/operator shall install a flare device that has a certified control efficiency of 99%. [R307-401-8]
II.B.4.d.1 To demonstrate compliance with the control efficiency, the owner/operator shall keep a record of the manufacturer's certification of the control efficiency. The record shall be kept for the life of the equipment. [R307-401-8]

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal July 29, 2024 Page 9
II.B.5 LDAR Requirements
II.B.5.a The owner/operator shall develop a fugitive emissions monitoring plan for the storage tanks and flare operations. At a minimum, the plan shall include: A. Monitoring frequency
B. Monitoring technique and equipment
C. Procedures and timeframes for identifying and repairing leaks
D. Recordkeeping practices E. Calibration and maintenance procedures.
[R307-401-8] II.B.5.b The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor" components. [R307-401-8]
II.B.5.c Monitoring surveys shall be conducted according to the following schedule:
A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a.
B. Semiannually after the initial monitoring survey. Consecutive semiannual monitoring surveys shall be conducted at least 4 months apart. C. Annually after the initial monitoring survey for "difficult-to-monitor" components.
D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor" components. [R307-401-8] II.B.5.c.1 Monitoring surveys shall be conducted using one or both of the following to detect fugitive emissions:
A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of imaging
gases in the spectral range for the compound of highest concentration in the potential fugitive emissions. B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A. [R307-401-8]
II.B.5.c.2 If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive emissions component as soon as possible but no later than 30 calendar days after detection. [R307-401-8]

II.B.5.c.3 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8]

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal July 29, 2024 Page 10
II.B.5.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring surveys, repairs, and resurveys. [R307-401-8]

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal July 29, 2024 Page 11
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN141770004-21 dated February 18, 2021
Is Derived From NOI dated May 15, 2024
REVIEWER COMMENTS

1. Comment regarding Emissions Estimates: The emissions estimates were calculated as follows: Unloading/loading of oil products by AP-42 Section 5.2 Storing asphalt, ATBs, and ACO in tanks by EPA Tanks version 5.0 (ACO is represented by the highest Reid vapor pressure crude oil in the emission calculations due it having a higher emissions potential, compared to ATB's or asphalt.) Flare device by AP-42 Section 13.5 Boiler operation by AP-42 Section 1.4 Equipment leaks by EPA-435/R-95-017 CO2e by AP-42 Table 1.4-2; and Part 98, Subpart A, Table A-1. [Last updated July 29, 2024]
2. Comment regarding NSPS and MACT: 40 CFR 60 (NSPS) 40 CFR 60 Subpart Dc applies to owners and operators of small industrial-commercial-institutional
steam generating units (boilers) between 100 MMBtu/hr and 10 MMBtu/hr. This steam generating unit or boiler uses NG and the reporting is to document how much NG is used. Since this source will have three steam generators or boilers at 10 MMBtu/hr, NSPS Subpart Dc will apply to this plant.
40 CFR 60 Subpart Kb applies to owners and operators of organic liquid storage vessels greater than
75 m3 (with a vapor pressure greater than 15 kPa) and 151 m3 (with a vapor pressure greater than 3.5 kPa). This site has three storage tanks with 19,215 m3; therefore, Subpart Kb applies to this source.
40 CFR 60 Subpart VVa applies to owners and operators of equipment leaks in the synthetic organic chemicals manufacturing industry (SOCMI). The source does not manufacture any SOCMI with the asphalt or black wax crude oil it receives; therefore, this subpart doesn't apply to this source. 40 CFR 63 (MACT) 40 CFR 63 Subpart LLLLL applies to the asphalt processing and asphalt roofing manufacturing plants (at major sources of HAPs). This is an area source and therefore, Subpart LLLLL doesn't apply to this source. 40 CFR 63 Subpart JJJJJJ applies to industrial, commercial and institutional boilers at area sources. This subpart is for coal or fuel oil-firing of the boilers and the plant uses natural gas. Therefore, Subpart JJJJJJ doesn't apply to this source.
40 CFR 63 Subpart AAAAAAA applies to asphalt processing and asphalt roofing manufacturing plants (at minor sources of HAPs). This is an area source, but does not blow air through the asphalt; therefore, Subpart AAAAAAA does not apply to this source. [Last updated May 15, 2024]

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal July 29, 2024 Page 12
3. Comment regarding Title V Requirments: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) and 40 CFR 63 (MACT) regulations. The facility is not subject to 40 CFR 61 (NESHAP)
regulations. NSPS Subpart Dc, when natural gas is used, requires the maintenance of consumption records that support no consumption limit. NSPS Subpart Kb requires the source to maintain storage tank dimensions for the life of the tank. Title V does not apply because NSPS Subpart Dc and Kb have record keeping-only requirements. Recordkeeping requirements are not considered standards or limitations. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility.
[Last updated May 15, 2024] 4. Comment regarding Use of EPA Tanks 5.0:
In the existing AO, MSA used EPA Tanks 4.0b tool for the estimation of the VOC emissions from the Tooele asphalt, ATB, and ACO plant, with the result of 60.24 tpy. MSA has proposed to use EPA Tanks 5.0 tool for the estimation of the VOC emissions in the future AO. Use of EPA Tanks 5.0 will result in a VOC emissions rate of 31.18 tpy. [Last updated June 14, 2024]

Engineer Review N141770005: Mountain States Asphalt, Inc.- Liquid Asphalt, ATB's, and Crude Oil Terminal July 29, 2024 Page 13
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
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Tank ID Tank Type Description City, State Company Emissions
Type
Annual
Standing
Losses
(lb/yr)
Tanks 1-4
Vertical
Fixed Roof
Tank
Four (4)
5,000,000-
Gallon Bulk
Receiving
Tanks - 2
Turnovers
Per Year
Tooele,
Active
Mountain
States
Asphalt
Total VOC 1
Annual
Working
Losses (lb/yr)
Annual Total
Losses (lb/yr)
740 741
Notes
Bulk Asphalt Cement Sorage Tanks 1-4. Each having 5-million gallons capacity. This assumes 2
turnovers of each tank annually for total thuput of 40,000,000 gallons.
January
Standing
Losses
(lb/yr)
January
Working
Losses
(lb/yr)
January
Total Losses
(lb/yr)
February
Standing
Losses
(lb/yr)
February
Working
Losses
(lb/yr)
February
Total Losses
(lb/yr)
March
Standing
Losses
(lb/yr)
0.07689995 61.6770691 61.7539691 0.07689995 61.6770691 61.7539691 0.07689995
March
Working
Losses
(lb/yr)
March Total
Losses
(lb/yr)
April
Standing
Losses
(lb/yr)
April
Working
Losses
(lb/yr)
April Total
Losses
(lb/yr)
May
Standing
Losses
(lb/yr)
May
Working
Losses
(lb/yr)
61.6770691 61.7539691 0.07689995 61.6770691 61.7539691 0.07689995 61.6770691
May Total
Losses
(lb/yr)
June
Standing
Losses
(lb/yr)
June
Working
Losses
(lb/yr)
June Total
Losses
(lb/yr)
July
Standing
Losses
(lb/yr)
July
Working
Losses
(lb/yr)
July Total
Losses
(lb/yr)
61.7539691 0.07689995 61.6770691 61.7539691 0.07689995 61.6770691 61.7539691
August
Standing
Losses
(lb/yr)
August
Working
Losses
(lb/yr)
August
Total Losses
(lb/yr)
September
Standing
Losses
(lb/yr)
September
Working
Losses
(lb/yr)
September
Total Losses
(lb/yr)
October
Standing
Losses
(lb/yr)
0.07689995 61.6770691 61.7539691 0.07689995 61.6770691 61.7539691 0.07689995
October
Working
Losses
(lb/yr)
October
Total Losses
(lb/yr)
November
Standing
Losses
(lb/yr)
November
Working
Losses
(lb/yr)
November
Total Losses
(lb/yr)
December
Standing
Losses
(lb/yr)
December
Working
Losses
(lb/yr)
61.6770691 61.7539691 0.07689995 61.6770691 61.7539691 0.07689995 61.6770691
December
Total Losses
(lb/yr)
61.7539691
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Tank ID Tank Type
MSA Tank Type 5 Vertical Fixed Roof Tank
Description City, State
46,061-Gallon Insulated
Tank_Asphalt Emulsion Tank
Throughput = 4,800,000 Gallons
Tooele, Active
Company Emissions Type
Mountain States Asphalt Total VOC
Annual Standing Losses (lb/yr)Annual Working Losses (lb/yr)
5.412732919 413.1339005
Annual Total Losses (lb/yr)
418.5466334
Tank ID Tank Type
MSA Tank Type 3 Vertical Fixed Roof Tank
Description City, State
287,884-Gallon Insulated Tank_Asphalt Sales Tank
Throughput = 19,627,807 gallons Tooele, Active
Company Emissions Type
Mountain States Asphalt Total VOC
Annual Standing Losses (lb/yr)Annual Working Losses (lb/yr)
31.06469831 2443.884115
Annual Total Losses (lb/yr)
2474.948813
Tank ID Tank Type
MSA Tank Type 4 Vertical Fixed Roof Tank
MSA Tank Type 5 Vertical Fixed Roof Tank
Description City, State
211,507-Gallon Insulated Tank_Mill
Feed Tank Throughput = 6,283,466
Gallons
Tooele, Active
46,061-Gallon Insulated Tank_Mill
Feed Tank Throughput = 1,567,657
Gallons
Tooele, Active
Company Emissions Type
Mountain States Asphalt Total VOC
Mountain States Asphalt Total VOC
Annual Standing Losses (lb/yr)Annual Working Losses (lb/yr)
22.7859523 1338.00311
5.412732919 298.4178879
Annual Total Losses (lb/yr)
1360.789063
303.8306208
1664.619684
Tank ID Tank Type
MSA Tank Type 1 Vertical Fixed Roof Tank
Description City, State
One (1) Insulated 5,076157-Gallon
Tank Tooele, Active
Company Emissions Type
Mountain States Asphalt Total VOC
Annual Standing Losses (lb/yr)Annual Working Losses (lb/yr)
27.89451743 1080.524097
Annual Total Losses (lb/yr)
1108.501634
Tank ID Tank Type
MSA Tank Type 4 Vertical Fixed Roof Tank
MSA Tank Type 5 Vertical Fixed Roof Tank
Description City, State
211,507-Gallon Insulated
Tank_Reaction Tank Throughput =
16,534,013 Gallons
Tooele, Active
46,061-Gallon Insulated
Tank_Reaction Tank Throughput =
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Tooele, Active
Company Emissions Type
Mountain States Asphalt Total VOC
Mountain States Asphalt Total VOC
Annual Standing Losses (lb/yr)Annual Working Losses (lb/yr)
22.7859523 1870.517875
5.412732919 352.5805653
Annual Total Losses (lb/yr)
1893.303827
357.9932983
2251.297125
Tank ID Tank Type
MSA Tank Type 2 Vertical Fixed Roof Tank
MSA Tank Type 4 Vertical Fixed Roof Tank
MSA Tank Type 5 Vertical Fixed Roof Tank
Description City, State
Tank_Secondary Asphalt Storage Tank Tooele, Active
k_Secondary Asphalt Storage Tank_Th Tooele, Active
nk_Secondary Asphalt Storage Tank_Th Tooele, Active
Company Emissions Type
Mountain States Asphalt Total VOC
Mountain States Asphalt Total VOC
Mountain States Asphalt Total VOC
Annual Standing Losses (lb/yr)Annual Working Losses (lb/yr)
92.03252506 5251.559774
22.7859523 1312.889997
5.412732919 122.8320545
Annual Total Losses (lb/yr)
5343.592299
1335.675949
128.2447874
6807.513035
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Estimates of Air Emissions from Asphalt
Storage Tanks and Truck Loading
David C. Trumbore
Asphalt Technology Laboratory. Owens Corning, Summit, IL 60501
Title V of the 1990 Clean Air Act requires the accurate
estimation of emissions
processes, and places theburden
rom all U.S. manufacturing
of proof for that estimate
on the process owner. This paper is published as a tool to
assist in the estimation of air emissions from hot asphalt
storage tanks and asphalt truck Loading operations. Data
are presented on asphalt vapor pressure, vapor molecular
weight, and the emission split between volatile organic
compounds and particulate emissions that can be used
with AP-42 calculation techniques to estimate air
emissions from asphalt storage tanks and truck loading
operations.Since current AP-42 techniques are not valid
in asphalt tanks with active fume removal, a different
technique for estimation of air emissions in those tanks,
based on direct measurement of vapor space combustible
gas content, is proposed. Likewise, since AP-42 does not
address carbon monoxide or hydrogen sulfide emissions
that are known to be present in asphalt operations, this
paper proposes
Finally,
techniques for estimation of those emissions.
data are presented on the effectiveness of fiber bed
jilters in reducing air emissions in asphalt operations.
INTRODUCTION
The use of asphalt is prevalent throughout recorded
history. It is produced in refinery distillation towers and
solvent extraction units. Asphalt is modified by several
means: reacting with oxygen in blowing operations to
produce roofing asphalts, emulsifying to produce an
aqueous liquid at ambient temperature, blending with
solvents to make asphalt cutback, or blending or even
reacting with polymers to make polymer modified asphalt.
In all these cases the asphalt is stored in tanks, usually
fixed roof tanks, and is loaded into trucks to ship to
customers.
Title V of the 1990 Clean Air Act required the accurate
estimation of emissions from all U.S. manufacturing
processes, and placed the burden of proof for that estimate
on the process owner. In response to Title V, Owens
Corning analyzed options for estimating emissions from
250

Winter 1999
asphalt tanks and loading operations and this paper is the
result of that study. In particular, attempts have been made
to develop data to be used with existing calculation
methods to estimate air emissions in asphalt operations, to
develop calculation schemes that work when existing
methods cannot be used, and to expand the number of
pollutants estimated. The techniques described in this
paper have been used by Owens Corning to estimate
asphalt emissions from their asphalt plants for many Title V
permit applications.
Owens Corning also evaluated appropriate emission
factors for the asphalt blowing process and that analysis has
been published [I].
The Emission Factor and Inventory Group in the U. S.
Environmental Protection Agency’s (EPA) Office of Air
Quality Planning and Standards develops and maintains a
database of emission factors and a series of calculation
methods for estimating air emissions from manufacturing
processes. These emission factors are published in a series
known as AP-42 [2]. One technique published in AP-42
calculates hydrocarbon emissions from a fixed roof tank
storing petroleum products [3], and another calculates
emissions for loading trucks with petroleum products [4].
These techniques require data on asphalt vapor pressure
and the molecular weight of the -asphalt vapor. The
calculations result in an estimate of the amount of
hydrocarbons emitted from the process. To complete the
emission estimate, these hydrocarbons need to be split into
particulate emissions (PM) and volatile organic compounds
(VOC), and any control device collection or destruction
efficiencies need to be applied.
In the AP-42 calculation of emissions from fixed roof
tanks it is assumed that the motive force pushing vapor out
of the tank comes from either the pumping of liquid into
the tank or the expansion of tank contents due to
temperature changes. For tanks with an active ventilation
system this assumption is invalid and a different method of
emission estimation is required. This is especially true if an
air sweep is used to control the vapor space composition to
Environmental Progress (Vol.18,

No.4)
No.4)
prevent explosive conditions [5,6]. A technique to estimate
emissions from these actively controlled tanks is described
in the section of this paper on non AP-42 estimates.
AP-42 EMISSION ESTIMATING TECHNIQUES FOR ASPHALT EQUIPMENT
Passive vented hot asphalt tanks: AP-42 for fixed roof
petroleum tanks can be used to calculate total hydrocarbon
emissions from asphalt and oil tanks that are passively
vented to the atmosphere. This AP-42 calculation, simply
stated, determines the amount of hydrocarbon in the tank
vapor space from the vapor pressure of the material in the
tank at the liquid surface temperature, and then calculates
the amount of vapor forced out of the tank due to liquid
being actively pumped into the tank (working losses), or
due to thermal expansion or contraction of tank contents
driven by ambient temperature changes (breathing losses).
The result is an actual weight of hydrocarbon emissions in
a specified time period. A detailed description of the tank
calculations is available from th e EPA web site [3]. The AP-
42 calculation requires a vapor pressure versus temperature
curve for the asphalt, and also estimates of the vapor phase
molecular weight and partition of hydrocarbons into VOC
and particulate, in addition to process data like asphalt
throughput. temperature. and tank level. If the tank
passively breathes through a control device, then the
appropriate control efficiency is applied to the VOC and
particulate emissions calculated from AP-42.
Hot Asphalt Loading: The AP-42 calculation for
hydrocarbon emissions from truck or rail tank car loading
of asphalt is done by estimating the amount of evaporation
during the loading process. The estimate takes into account
the turbulence and vapor liquid contact induced by the
method of loading, i.e . submerged versus splash loading.
The calculation result is an emission related to the number
of tons of material loaded into the truck. Vapor pressure
versus temperature c urve s,, temperature of loading, and
throughputs are key variables in this calculation. Again, the
hydrocarbon emission resulting from this calculation needs
to be split into pa rticu latess and VOC s and control device
collection and destruction efficiencies need to be applied. A
detailed description of the loading calculations is available
from the EPA web site [4].
DATA NEEDED FOR APPLICATION OF AP-42 TO ASPHALT EQUIPMENT
Vapor Pressure: Information on asphalt vapor pressure as a
function of temperature is not readily available in the
literature and its measurement is not common. However,
these data are essential to use AP-42 calculations for
estimating asphalt tank and loading emissions. Asphalts
from different crude oil sources and from different
processes will differ in composition and vapor pressure. In
the extreme, every residual material used in asphalt
processing would need to be measured for vapor pressure
at multiple temperatures. This would entail a prohibitive
estimates. To provide a cost effective solution to this
problem for its emission calculations, Owens Corning has
Environmental Progress (Vol.18 , No.4)
characterized the vapor pressure of three basic classes of
asphalt materials. chosen by their processing history. An
estimate of the vapor pressure of each asphalt class was
made by measuring asphalts from multiple crude oil
source s in each class and using the average vapor pressure
at each temperature in a regression to generate one vapor
pressure equation for tha t class. The three classes of asphalt
chosen for this analysis follow.
Flux asphalts. or vacuum tower bottoms that can be
in the asphalt blowing process to make
specification roofing asphalts. These materials generally
have a higher vapor pressure than paving asphalts.
Paving asphalts, or vacuum tower bottoms that meet
paving specifications.
Oxidized asphalt, or vacuum tower bottoms that have
been reacted with oxygen in the asphalt blowing process
to increase their softening point and viscosity. Typical
softening points are greater than 190°F (88°C) These
materials are also called air blown asphalts and are used
extensively in the roofing industry. They generally have
lower vapor pressure than the other two classes.
Va por pressure measurements described in this paper were
clone by the Phoenix Chemical Lab in Chicago using the
Isoteniscope (ASTM D2879).
To facilitate computer calculations it is desirable to develop
an equation that accurately describes the relationship of vapor
pressure and temperature. Thermodynamic treatment of the
dependence of vapor pressure on temperature has led to the
Clausius modification of the Clapeyron equation [7].
Clausius Clapeyron Treatment of Vapor Pressure Data
In P = a + b/T
Where: P is the equilibrium vapor pressure
of the liquid in question,
a & b are constants. and
T is the absolute temperature of the liquid
in question.
Values of a & b depend on the choice of
pressure and temperature units.
Table 1 and Figure 1 give an example of the agreement of
this equation with vapor pressure data for oxidized asphalts
from 13 sources around the country. In Figure 1 , vapor
pressure of each asphalt is plotted versus temperature to show
each individual asphalt’s data to the Clausius Clapeyron
rela tio ns hip .. The correlation coefficients in Table 1 indicate
that the agreement of this equation to all individual asphalt
vapor pressure ve rsus temperature data is excellent, with
correlation coefficients for the individual asphalts greater than
0.9999. The agreement is also excellent for the individual
asphalts making up the other two asphalt classes. Table 1 also
presents the methodology to choose constants to use with the
Winter 1999 251
amount of testing for minimal gain in accuracy of emission
the differences between asphalt's data to the Clausius Clapeyron
used
Table l.Vapor Pressure Data for Oxidized Asphalts
Temperature (°F1)All Data in mm Hg2
200 250 350 400 450 500 600 r value3
Plant A 0.39 2 7.9 26 77 550
Plant C 0.42 2 7.9 26 670
H 0.43 2 7.7 25
z: 180
165 410 590
Plant I 0.44 1.9 7.2 22 59 140 340 680
PlantK 0.43 1.7 6.1 18.5 50 115 205 510 680
PlantM 0.28 1.2 4.6 15 41 97 210 640
PlantN 0.19 0.88 3.5 12 34 85 190 430 590
PlantP 0.46 1.8 6 44 96 195 410 710
Plant0 0.11 0.47 1.7 13.2 34 74 142
Plant J 0.16 0.64 2.2 6.2 14.8 36 72 135
PlantS 0.28 1.05 3.3 9.4 23 50 105 200 350
PlantS 0.28 1 3.2 10 25 58
PlantX 0.1 0.4 1.5 4.7 12.5 33 75 152
Class Standard 0.22 0.91 3.2 9.5 24.9 58.8 127 254 351 477
Average 0.33 0.75 2.6 7.9 22.3 54.7 122 284 634 347
13459 b in Clausius Clapeyron curve for average vapor pressure data
1. 1 °C = (°F - 32) * 5/9
2. 1 Pa = 0.0075 mm Hg
the r value is for the fit of the vapor pressure data to the Clausius Clapeyron Equation
-0.999922929
-0.999934558
-0.999939281
-0.999945804
-0.999660554
-0.999948167
-0.999965421
-0.999948079
-0.999916578
-0.999838114
-0.999986213
-0.999875798
-0.999930649
-0.994026635
1000
100
FIGURE 1.Oxidized Asphalt Vapor Pressure Data in Clausius Clapeyron Format
9 10 11 12 13 14 16
Asphalt 300 550 575
225
400
460
5.2
17.5
Plant
Vp
18.86 a in Clausius Clapeyron curve for average vapor pressure data
10,000 * 1/T (°R)2
15
0.1
Environmental Progress (Vol.18, No.4)252 Winter 1999
I II I
A Plant A t
I w-e I IIII
I I
A Plant H
0 Plant I
x Plant K
0 Plant M
+ Plant N
- Plant P
- Plant 0
l Plant J
m Plant S
1
0.1
2. 1 ° C = (° F-32)*5/9
I/I
I A
I .
Temperature (°F2)
1000
FIGURE 2. Oxidized Asphalt Vapor Pressure Data in Double Log Format
Clausius Clapeyron equation to calculate 3 representative
vapor pressure at any temperature for the class of oxidized
asphalts. Essentially the technique consists of averaging the
vapor pressures of the 13 asphalts at each temperature and
then using those averages to curve fit the data to the desired
equation. This gives higher values and is more conservative
than averaging the vapor pressures after the log transformation
is made. The standard curve is developed by using this
regression equation to calculate vapor pressures at different
temperatures. and for the oxidized class that data is indicated
in Table 1 and also by the straight line in Figure 1.
The form of the Clausius Clapeyron equation is somewhat
cumbersome to use, especially in graphical form, and so an
alternative equation was developed which used a log/log
relationship to characterize the data.
Log Log Treatment of Vapor Pressure Data
log Vp = A * log(T) + B
Vp is the vapor pressure.
T is the temperature (not absolute
A & B are constants
Analyses of oxidized asphalts using this equation to
establish the standard curve are presented in Figure 2. The
agreement is also very good. w ith correlation coefficients for
the individual asphalts greater than 0.999. Again all three
Class of
Asphalt a
Average
n correlation
coefficient
Flux
Paving
Oxidized
18.2891 12725.60 10 -0.99976
20.7962 15032.54 8 -0.99985
18.8642 -0.99991
For a log log Equation
log Vp (mm Hg) = A * log T (°F 3) + B
Class of
Asphalt a
Average
n correlation
coefficient
Flux 7.0850 -16.8999 10 0.99736
Paving 7.8871 -19.0600 8 0.99965
Oxidized 7.0607 -16.9570 13 0.99981
Table 2. Vapor Pressure Correlations for Asphalts
For the Clausius Clapeyron Equation
In Vp (mm Hg1) = a - b/T( R2
Environmental Progress (Vol.18, No.4)Winter 1999 253
13458.56 13
where
100
5
5
classes of asphalts show similar agreement,
Pressure Summary: Table 2 gives a summary of the
regression constants to be used in either of the equations
discussed above to calculate the vapor pressure for the three
classes of asphalt at any temperature. Also indicated are the
number of asphalts that were used to develop the equation
for each class. and the average correlation coefficient
characterizing the agreement of the data to the form of the
equation for each individual asphalt in the class.
In AP-42 for tanks, the correct temperature to use in the
Table 2 equations is the asphalt surface temperature in the
tank. Since the surface temperature is rarely. if ever, known
with certainty, the bulk temperature should be used to
estimate emissions. In a well mixed tank the bulk
temperature will be a good approximation of the surface
temperature. Where mixing is not effective the surface will be
lower in temperature than the bulk and the use of the bulk
temperature will give a conservative estimate of emissions. In
for loading trucks, the bulk temperature of the tank
from which material is being loaded provides a good estimate
of the actual loading temperature.
Asphalt Vapor Molecular Weight: Asphalt vapor molecular
weight was determined by separation and analysis of the
organic species in the vapor spaces of 12 tanks storing
different types of asphalt. These profiles were obtained by
drawing known volumes of the tank vapor space through a
charcoal tube, sealing and freezing the tube to limit loss of
the sample, and then desorbing the organic material from the
charcoal with carbon disulfide and analyzing with gas
chromatography using packed columns and flame ionization
detectors. Analyses were performed by CHEMIR Laboratory
in St. Louis. Quantitative standards were used to identify the
amount of individual normal alkanes from n-pentane to n-
pentadecane. Peaks eluting between the normal alkanes were
assumed to he isomers of the hordering alkanes, especially
cyclic isomers of the lower carbon number alkane, and
branched or unsaturated isomers of the higher carbon
number alkane. The molecular weights for the n-alkane
species and molecular weight estimates for the intermediate
species were used with the amount of that material measured
to calculate a weighted average vapor molecular weight for
each tank, and then the twelve tanks were averaged together
to get the molecular weight used for hot asphalt vapors in the
AP-42 calculations. The result was a molecular weight of 84,
which is used with all three classes of asphalts. This analysis
is detailed in Table 3. Not enough data were available to
assign different values to the three asphalt classes,
however, from the table the unblown flux material in two
tanks gave molecular weights which bracketed the
average. as did the two paving blend stocks.
This analysis gave a lower molecular weight for the
vapor space of asphalt tanks than for several petroleum
solvents and fuel oils. This seems like a contradiction
considering the nature of asphalt as the residuum material
collected upon distillation. This contradiction is resolved
by considering that asphalt is not a uniform material
chemically and that the lower molecular weight materials

AP-42
Vapor
Environmental Progress (Vol.18, No.4)254 Winter 1999
Table 4. PM/VOC Partition Data from
Owens Corning Testing
Asphalt
Plant 0
Tank A Tank B Tank c
VOC Test 0.73
PM Test 0.21
VOC Fraction 0.78
1.16 0.98
0.38 0.30
0.75 0.77
lb/hr1
lb/hr
Koofing Plant S Coater Results:
Measured at different points. Data indicated 22% of total
emission (VOC + PM) was PM and 78% was VOC
1. 1 kg/sec = 0.0076 * lb/hr
are preferentially evaporated More importantly. it has also
been established that thermal cracking of asphalt in hot
storage tanks creates low molecular weight materials which
accumulate in the tank vapor spaces [5,6].
Asphalt Liquid Molecular Weight: The actual bulk asphalt
molecular weight is not needed for AP-42 calculations of
emissions from tanks or loading racks. but is useful in some
calculations that are beyond the scope of this paper, for
example using Raoult's law for crude estimates of emissions
from mixtures of asphalt and other materials. Molecular
weight of bulk asphalt is not a well defined material
property, both because asphalt is such a complex mixture
and because intermolecular interactions in the asphalt
create the appearance of high molecular weight in many
measurement techniques. The measured molecular weight
is usually not truly representative of the covalently bonded
molecules, The difficulty in getting accurate asphalt
molecular weight measurements is extensively discussed in
the literature [8, 9, 10]. The use of Gel Permeation
Chromatography[8], Field-Ionization Mass Spectrometry [8].
Vapor Pressure Osmometry [8,9,10], and Freezing Point
Depression [10] have all been evaluated as methods for
measuring the molecular weight of asphalt or its
components. The topic is further complicated for emission
calculations by the fact that many of the measurements
have been made on fractions of the asphalt and not on the
neat asphalt. In general. for very rough estimates, a value
of 1000 [8] can be used for the molecular weight of bulk
asphalt. This value should be used with the understanding
that there is much variation in the true molecular weight
and in the tendency for intermolecular interaction due to
petroleum crude source and processing conditions.
Partition of hydrocarbon emissions that are particulate and VOC:
Because of its heterogeneous nature, asphalt fumes are
varied and may have components that are classified as
condensed particulates (PM) or as volatile organic
compounds (VOCs). It m-as evident in analyzing asphalt
fume results that the difference between these two classes
of criteria pollutants is really defined by the method used to
test for the pollutants. Estimation schemes described in this
paper calculate the sum of both (AP-42) or just the VOC
component (non-AP-42 technique described below), and
the partition needs to be understood to provide the best
estimated values of the two pollutants. To that end. tests
have been done on both asphalt tank exhausts in an
Owens Corning asphalt plant and on the asphalt shingle
coater exhausts in an Owens Corning roofing plant using
EPA Methods 5 & 25A sampling protocols which define
VOC and PM emissions in hydrocarbon fumes. Under
conditions specified by the test method some fraction of
the fume is captured on a filter and this is defined as a
particulate emission, while a fraction of the hydrocarbon
emission passes through the filter and this is defined as a
VOC emission. The results of the split in the total
hydrocarbon fume between VOC and particulate were
approximately 78% VOC and 22% particulate in the asphalt
equipment. in spite of the basic difference between a
shingle coater and a storage tank. Data from these tests are
given in Table 4.
NON AP-42 CALCULATIONS TECHNIQUES:
Estimation of VOC and particulate emissions from tanks with
fume control: Many asphalt tanks have their fumes actively
collected and treated in a control device, either a fiber bed
filter or an incinerator. In these tanks it is common at
Owens Corning to allow some air to pass through the tank
vapor spaces to create an air sweep that controls
combustible fumes well below the lower explosion limit
(LEL) in order to prevent explosions. Because of the active
removal of fumes in these systems, and the bleeding of air
into the vapor space. the assumptions underlying the AP-42
tank calculations no longer apply. Specifically the driving
force for the flow of fumes out of the tank is no longer just
the working and breathing losses. and an alternative
method of emission calculation is needed.
Several years ago safety concerns with asphalt tanks
prompted Owens Corning to institute the periodic
measurement of the combustible gas concentration in all
asphalt tank vapor spaces [5]. With the advent of Title V it
was recognized that these measurements could be used to
estimate VOC emissions. As part of the safety program.
techniques were developed to make this routine
measurement simple and easy. and the result was the use
of Mine Safety Appliance (MSA) combustion meters to
quantify the hydrocarbon concentration in terms of the
fraction (or %) of the LEL. This technique and the validation
of its accuracy has been described in detail in a separate
publication [6]. In addition to the combustible gas
measurement, a slightly more complicated technique is also
described and validated that gives the concentration of
ethane, methane. and other light combustible gases
separate from propane and larger hydrocarbons. This
technique involves using a charcoal tube in the line
between the tank and the MSA meter. The charcoal tube
adsorbs all propane and higher hydrocarbons [6], with the
resultant reading at the MSA meter due only to the lighter
Environmental Progress (Vol.18, No.4)Winter 1999 255
Table 5. Fraction of Measured Combustible Gas
that is not VOC or Particulate
Asphalt Type
Number tanks measured
Oxidized Unoxidized
109 47
Fraction combustible gas that is non-VOC/PM
Average 0.52 0.23
Standard Deviation 0.12 0.23
materials. The charcoal tube technique was developed to
troubleshoot excessive thermal cracking in asphalt tanks as
a cause of high combustible gas levels in tank vapor
spaces, and it is not routinely performed. It is important for
emission calculations since the smaller combustibles found
in the tank vapor spaces and measured with the charcoal
tube in place (ethane, methane. hydrogen sulfide. and
carbon monoxide) are not classified asVOCs because they
do not react with ozone in the atmosphere. Nor are they
particulate. The other hydrocarbons trapped by the tube
and only measured when the charcoal tube is not present.
are VOCs or particulate. Table 5 gives the results of testing
of vapor spaces of oxidized and unoxidized asphalts for
these two types of combustible gas measurements. This
analysis was done to see if the routine combustible gas
numbers should be adjusted for significant and predictable
non-VOC/PM components. For the average tank storing
oxidized asphalt. 52% of the combustible gas is non-
VOC/PM anti this value n-as used for this class of asphalt.
For unoxidized asphalts, both paving and flux,the non-
VOC/PM % LEL varied widely and was not nearly as large a
fraction of the total. For these asphalts, all of the
combustible gas measurement was considered to be either
VOC or particulate.
Calculation of VOC & PM fromcombustible gas readings: Given
this background the actual calculation of VOC emissions
from combustion meter measurements is as follows:
Combustion meter measurements from tank vapor
spaces read in %LEL are adjusted for the fraction of that
reading that is non-VOC/PM. This value depends on the
type of asphalt in the tank.
The adjusted %LEL is then turned into a weight per
volume concentration. Hydrocarbons have a relatively
constant actual LEL concentration. 45 mg/liter, when
expressed on 3 weight per volume basis [11], and this
constant is used to make this calculation.
The weight per volume concentration from step 2 is
multiplied by the fume removal flow (in volume/time) in
the tank to get the VOC emission (n-eight/time) going to
Calc CO = 142 l LEL + 800
8000 -II II
6000 --
0 20 40 60 80 100 120
% LEL
256

Winter 1999
FIGURE 3. Relation of CO with % LEL Data for Oxidized Asphalts
Environmental Progress (Vol.18, No.4)
2500
2000
1500
1000
500
0
I
I
I I

0 20 40 60 80 100 120
% LEL
FIGURE 4. Relation of H2S with % LEL Data for Oxidized Asphalts
a control device. It is consistent that the %LEL method
measures VOC and not total hydrocarbon since the fume
is drawn through a cotton filter prior to entering the
combustion meter, and particulate will be filtered out.
The particulate emission going to the control device is
estimated from the constant ratio of 22%PM/78%VOC
outlined in Table 4.
The control device destruction efficiency is applied to
both VOC and particulate emissions separately to get the
final hydrocarbon based emissions from the tank. This is
done after the calculation of PM emissions since the
control efficiency for particulate and VOCs can be
different depending on the control device.
This methodology’s accuracy has been confirmed by
tests in an Owens Corning asphalt plant on several
Table 6. Owens Corning Tank Fume
Sampling Results - VOC Emissions
Tank A Tank B Tank C
VOC Method 2jA Test 0.73 1.16 0.98
LEL Based Estimate 0.72 0.91 0.83
AP-42 Based Estimate 3.17 4.5 3.39
= 0.0076 *lb/hr
passively vented tanks while material was pumped into the
tank and vapors forced out by the known pumping rate.
Emissions calculated with the method outlined above were
compared to tank emissions calculated using AP-42 (valid
in theory in this case due to the lack of a ventilation
system), and to emissions measured using EPA Method 25A.
As can be seen in Table 6 the method based on actual
combustion meter tests is similar to the measured VOCs
while AP-42 estimates are 3 to 5 times higher.
Estimation of CO and H2S emissions from asphalt tanks: As part
of the safety monitoring program mentioned above. Owens
Corning has also used detector tubes in asphalt tanks to
measure the vapor space concentration of carbon
monoxide and hydrogen sulfide [6]. These emissions are
usually ignored in asphalt tanks, however. the data Owens
Corning has taken clearly indicates their presence in tank
vapor spaces and therefore their emission [il. These gases
are not routinely measured in Owens Corning asphalt
tanks. unlike combustible gas measurements, and thus fresh
data are not available for current calculation. nor are data
available for every one of our tanks. To apply these data to
all tanks. a surrogate measurement is necessary. Since the
same mechanism, thermal cracking, that produces light
hydrocarbons in asphalt tank vapor spaces also produces
carbon monoxide and hydrogen sulfide, the periodic
combustion meter measurement of tank vapor spaces was
4.
5.
%
1. 1 kg/sec
H2S
(
p
p
m
)
3000
H2S
Calc H2S
Calc H2S = 12.43 * LEL + 400.5
Environmental Progress (Vol.18, No.4) Winter 1999 257
Table 7. Asphalt Plant 0:
Tank Emissions of H2S and CO
Tank A Tank B Tank C
Data
Actual Test
% LEL based estimate
0.06 0.12 0.15 lb/hr1
0.19 0.18 0.20 lb/hr
CO Data
Actual Test
% LEL based estimate
0.20 0.17 0.23 lb/hr
0.74 0.85 0.83
1. 1 kg/sec = 0.0076 * lb/hr
investigated as a surrogate for CO and Data for CO
and are plotted in Figures 3 and 4. Because of the
scatter of data in the correlations a representative line was
chosen for each material that was more conservative than
nearly all of the data, in other words a line that defined a
maximum concentration of CO and that could be
expected in an asphalt tank from the combustion meter
measurement. The equations used in the calculation of CO
and concentrations from combustion meter results
CO (ppm) = 142 *%LEL + 800 for oxidized asphalt
= 12.43 *%LEL + 400.5 for oxidized asphalt
In unoxidized asphalt no such correlation was seen and
values of 500 ppm are used for both species.
To estimate an emission from this correlation the CO and
concentrations are multiplied by the flow out of the tank
to get emissions. and conversion factors are used to transform
this into a weight per time emission. Any control device
destruction efficiency is then applied. The emissions using
these techniques can be significant. Limited direct
measurement in an Owens Corning asphalt plant was
consistent with this approach. at least in so far as that the
approach was conservative. was the closer of the
two estimates. Data are presented in Table 7.
One consequence of fume incineration is that one mole of
in the fumes is oxidized to one mole of The amount
of oxidized to SO, is the amount of generated minus
both the amount that escapes at the source and the amount
that is not incinerated at the control device. or in effect the
total uncontrolled H2S emissions minus the emissions
g after control. Because of the reaction with oxygen
and the molecular weight differences between H2S and SO2,
every pound (2.2 kg) of H2S emission is oxidized to 1.88
pounds (4.14 kg) of SO2 emission.
LoadingRack emissions of CO and H2S: As in the tanks. %LEL
versus CO and H2S correlations are used to estimate these
components in loading rack emissions. Again, with
incineration, the H2S is oxidized to SO2. Flow out of the
tank truck during loading is needed for CO and H2S
calculations. When fumes are collected, that flow can be
either the more conservative flow induced by the fume fan,
or the lower and more realistic displacement of air by the
asphalt being loaded. When no collection takes place that
flow is the displacement of air by asphalt being loaded.
Combustion meter measurements of %LELs from the tanks
for loading are used for these calculations.
EFFECTIVENESS OF FIBER BED FILTERS FOR ASPHALT FUME EMISSION
CONTROL
One device used extensively to control asphalt fumes is
a fiber bed filter. Fumes are actively pulled through these
filters or passively hreathe through these filters. Their first
use at Owens Corning was to control opacity to comply
NSPS regulations, and for this application they have
proven to he quite effective.
Testing was done on both asphalt tanks and on a
roofing line center to determine the control efficiency of
fiber bed filters for both VOC and particulate emissions.
Data from the testing are summarized in Table 8. In all
cases. the particulate collection in the filter exceeded 90%
of the emissions in the input stream. This value agrees well
manufacturer’s estimate of 95% and with the
observation that these devices can eliminate opacity.
However, VOC removal varied widely in the tests. With the
average removal near zero, and a very large variation, it
decided that no removal of VOC by these filters could
assumed. Although organic oil is collected. this oil is
considered part of the particulate fraction of the
hydrocarbons in the fumes and not the VOC fraction.
Indeed the lack of removal of VOCs by these filters is
consistent with the method of partitioning hydrocarbons
into VOC and particulate described above -- namely VOCs
pass through a testing filter and particulate do not. Based
on the effectiveness of these control devices to eliminate
opacity it is assumed that particulate greater than 10 micron
is captured by the fiber bed filter so that the total
particulate emissions from the fiber bed filter are
to be PM10 emissions.
Fiber bed filters are not considered to he a control
device for CO and H2S in tank or loading rack fume
streams.
Table 8. Effectiveness of Fiber Bed Filters
for Emission Control from Asphalt Tanks
Equipment Pollutant Control Efficiency
0 Tank 1
Tank 57
Tank 1

Asphalt 0
0 Tank 1
0 57
Roofing I Coater
0
Asphalt 0
Asphalt 0
Asphalt 0
Tank 1 Total Particulate
Tank 57 Total Particulate 90.7%
Tank 1 Filterable Particulate 100.0%
Filterable 100.0%
H2S
lb/br
with
used
was
with
considered
be
Plant
Asphalt
Asphalt
Asphalt
Asphalt
Tank
VOC
VOC
VOC
VOC
VOC
-35.7%
5.7%
43.4%
5.3%
0.0%
95.7%
remaining
H2S
H2S
H2S
H2S
H2S
H2S
H2S
H2S
H2S
H2S SO2
%LEL
conservative
(ppm)
258 Winter 1999 Environmental Progress (Vol.18, No.4)
Table 9. Summary of Data for Calculating Asphalt Tank Emissions
Data Type Flux Asphalt Paving Asphalt Oxidized Asphalt
Clausius Clapeyron constant a for vapor pressure 1 18.2891 20.7962 18.8642
Clausius Clapeyron constant b for vapor pressure 1 12725.6 15032.54 13458.56
Log Log constant A for vapor pressure 2 7.085 7.8871 7.0607
Log Log constant B for vapor pressure 2 -16.8999 -19.06 -16.957
Asphalt vapor molecular weight use 84 for all types of asphalt
Asphalt liquid molecular weight very rough estimate - 1000
Partition of hydrocarbon fumes into particulate and VOC use 22% particulate, 78% VOC for all types
% fumes that are VOC or particulate, versus non VOC/PM 100% 100% 48%
Vapor space carbon monoxide (conservative estimate)ppm 500 500 142* % LEL + 800
Vapor space hydrogen sulfide (conservative estimate) ppm 500 500 12.43*%LEL + 400.5
Fiber bed filter control of VOC use 0% for all asphalt types
Fibe4r bed filter control of particulate use 90% for all asphalt types
1.In Vp(mm Hg) = a + b/T(°R) 1 Pa = 0.0075mm Hg, 1 °K = (°R-492)*5/9 +273
2.log Vp (mm Hg) = A*log T(°F) + B 1 °C = (°F - 32)* 5/9
CONCLUSIONS
Estimation of air emissions for asphalt tanks and loading
racks can be done using AP-42 calculation methods given
appropriate data on asphalt properties. More precise
estimates of emissions, or estimates for tanks using
ventilation schemes that compromise the AP-42
assumptions, can be done using a simple measurement of
the combustible gas in the vapor space. Methods to do this
are outlined in the paper. Data that is useful with all these
methods are summarized in Table 9. These data are given
for three major classes of asphalt: paving, flux and
oxidized
LITERATURE CITED
1. Trumbore, D.C., "The magnitude and source of air
emissions from asphalt blowing operations,"
Environmental Progress,17, (1), pp. 53-59 (Spring 1998).
2. U.S.Environmental Protection Agency, "Introduction to
5th edition of AP-42 Emission Factors," U. S. EPA,
January,1995,from the Internet at http://www.epa.gov/
ttn/chief/ap42.html (accessed May 14, 1998).
3. U.S Environmental Protection Agency, Chapter 7.1 of the
5th edition of AP-42 Emission Factors, U.S.EPA,
"Organic Liquid Storage Tanks," September, 1997, from
the Internet at http://www.epa.gov/ttn/chief/ap42.html
(accessed May 14, 1998).
4. U.S.Envoironmental Protection Agency, Chapter 5.2 of the
5th edition of AP-42 Emission Factors, U.S. EPA,
"Transportation and Marketing of Petroleum Liquids,"
January, 1995, from the Internet at http://www.epa.gov/
ttn/chief/ap42.html (accessed May 14, 1998).
5. Trumbore, D.C. and C.R.Wilkinson, "Better
understanding needed for asphalt tank-explosion
hazards," Oil Gas J., 87, pp.38-41 (September 18, 1989).
6. Trumbore, D.C., C.R.Wilkinson, and S.Wolfersberger,
"Evaluation of techniques for in situ determination of
explosion hazards in asphalt tanks," J.Loss Prev. Process
Ind., 4, pp. 230-235 (July,1991).
7. Schmidt, A.X. and H.L. List, "Material and Energy
Balance," Prentice Hall, Inc., Englewood Cliffs, New
Jersey, pp. 40-41 (1962).
8. Boduszynski, M.M., "Asphaltenes in petroleum Asphalt:
Composition and Formation," Chapter 7, in "The
Chemistry of Asphaltenes," American Chemical Society,
Washington, D.C., pp. 119-135 (1981).
9. Storm, D.A., et al., "Upper bound on number average
molecular weight of asphaltenes," Fuel, 69, pp. 735-738
(June, 1990).
10. Speight, J.G., and S.E.Moschopedis, "Asphaltene
molecular weights by a cryoscopic method," Fuel, 56,
pp 344-345 (July, 1977).
11. Bodurtha, F.T., "Industrial Explosion Prevention and
Protection," McGraw Hill, Inc, New york, New York,
page 11 (1980).
Environmental Progress (Vol.18, No.4) Winter 1999 259

RMEC PJ23E-4681

May 15, 2024

Bryce Bird
Director
Utah Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820

SUBJECT: ADMINISTRATIVE AMENDMENT REQUEST

RE: MOUNTAIN STATES ASPHALT, INC. – LIQUID ASPHALT, ATBS, AND CRUDE
OIL TERMINAL (UDAQ Approval Order: DAQE-AN141770004-21)
205 South Emerald Road
Tooele, UT 84074
Dear Mr. Bird:
On behalf of Mountain States Asphalt, Inc. (MSA), RMEC Environmental, Inc. (RMEC) is hereby
providing you with the following request for an administrative amendment of the above-referenced
Approval Order (AO) with the Utah Division of Air Quality (UDAQ). The basis for this request is due to a
recalculation of volatile organic compound (VOC) emissions associated with the facility’s asphalt cement
(AC) storage operations. The outcome of these recalculations results in a significant reduction in facility-
wide VOC emissions.
RECALCULATION OF VOC EMISSIONS FROM AC STORAGE OPERATIONS
Recently, the EPA released the final version of the TANKS 5.0 web program, which is a browser-based
application that estimates volatile organic compound (VOC) and hazardous air pollutant (HAP) emissions
from fixed- and floating-roof storage tanks. TANKS 5.0 is based on the most recent emission estimation
procedures from Chapter 7 of EPA's Compilation of Air Pollutant Emission Factors (AP-42). An older,
outdated version of the TANKS program was used for the initial NOI back in 2009.
The facility’s current asphalt storage tanks and associated processing operations were the subject of the
initial Notice of Intent (NOI) in 2009. As presented in the excerpts from the initial Notice of Intent (NOI)
in 2009, provided herein as Attachment A, a total of 36.42 tons of VOC were attributed to the facility’s
AC storage operations. While the facility has expanded operations to include storage of atmospheric tank
bottoms (ATB) and assorted crude oils (ACO), the AC storage operations have remained unchanged since
the 2009 NOI.
A summary of the parameters used in the recalculation of the VOC emission in the TANKS 5.0 program
are detailed in the following sections.
Asphalt Cement Custom Petroleum Liquid Parameters
Since AC is not one of the standard chemical inputs in the TANKS 5.0, AC emissions can be calculated by
setting up a custom petroleum liquid using the following chemical properties as prescribed in AP-42,
Chapter 11 Section 1.2.5:
IDEQ-AQD RMEC PJ23E-4681
Page 2 of 3 May 15, 2024

▪ Liquid Density (lb/gal): 8.0
▪ Vapor Molecular Weight (lb/lb-mole): 105
▪ Liquid Molecular Weight (lb/lb-mole): 1,000
▪ Antoine’s Vapor Pressure Equation Constant A: 75,350.06
▪ Antoine’s Vapor Pressure Equation Constant B (°R): 9.00346
Tank Data and AC Throughput
MSA operates five (5) different types of AC storage tanks. Summaries of the characteristics of each tank
type are provided in Attachment B. Information from the tank profile summary for each tank type was
entered into the TANKS 5.0 program. A copy of the TANKS 5.0 base file containing MSA’s Tank Data is
being transmitted with this email submission.
A mix of these standard tank types are utilized within the following six (6) categories of AC product storage
or processing:
▪ Primary Asphalt Storage Tanks
▪ Secondary Asphalt Storage Tanks
▪ Asphalt Sales Tanks
▪ Mill Feed Tanks
▪ Reaction Tanks
▪ Asphalt Emulsion Tanks
Each category of AC storage along with tank dimensions, annual throughput and specific operational
parameters, such as maximum fill height and target heating temperatures, are presented in the AC Storage
Tank Profiles Summaries provided in the attached Table 1. This summary also includes the standing and
working losses of VOCs for each tank type within each storage category. The VOC emissions were obtained
by performing a loss run for each individual stage of AC product storage using the customized AC profile
as the throughput for each tank type within the respective category.
A copy of the TANKS 5.0 loss run output file and tank data file for each category is being transmitted with
this email submission.
SUMMARY OF NET CHANGE IN VOC EMISSIONS
As previously discussed, the initial NOI allocated 36.42 tons of VOC emissions towards the AC storage
operations. As indicated in Table 1, the recalculation of VOC emissions for AC storage operations yields a
total of 7.36 tons of VOC emissions, resulting in a 29.06-ton reduction in the facility-wide VOC emissions.
The proposed amendment of the AO would reduce the current AO limits for VOC emissions from
60.24 tons per year, to 31.18 tons per year.

IDEQ-AQD RMEC PJ23E-4681
Page 3 of 3 May 15, 2024

CLOSING
Please feel free to contact me or Gene Chrisenbery if you have any questions or concerns regarding this
request. Gene can be reached at 435.659.1984 or by email at [e-mail]. I can be reached at
801.467.3661 or by email at [e-mail].
Sincerely,

Daryl Hancock, CHMM, CEM
Principal Scientist
RMEC ENVIRONMENTAL, INC.

ATTACHMENTS:

Attachment A – Excerpts from 2009 NOI
Attachment B – Tank Characteristics Summaries
Table 1 – Summary of AC Storage and Associated VOC Emissions

TABLE 1 –
SUMMARY OF AC STORAGE AND ASSOCIATED
VOC EMISSIONS
Shell
Diameter Shell Height Max Fill
Height
Tank Working
Volume
Turnovers Per
Year
Annual
Throughput
Annual
Standing
Losses
Annual
Working
Losses
(feet)(feet)(gallons)(gallons)(lbs)(lbs)(lbs)(tons)
1 1 Primary Asphalt Storage Tank 120 60 58 4,906,952 2.00 9,813,904
2 1 Primary Asphalt Storage Tank 120 60 58 4,906,952 2.00 9,813,904
3 1 Primary Asphalt Storage Tank 120 60 58 4,906,952 2.00 9,813,904
4 1 Primary Asphalt Storage Tank 120 60 58 4,906,952 2.00 9,813,904
19,627,807 8 39,255,614 28 1,081 1,109 0.55
5 2 Secondary Asphalt Storage Tank 60 40 38 803,725 15.34 12,331,061
6 2 Secondary Asphalt Storage Tank 60 40 38 803,725 15.34 12,331,061
7 4 Secondary Asphalt Storage Tank 30 40 38 200,931 15.34 3,082,765
8 4 Secondary Asphalt Storage Tank 30 40 38 200,931 15.34 3,082,765
17 5 Secondary Asphalt Storage Tank 14 35 33 37,598 15.34 576,838 5 123 128 0.06
2,046,910 76.71 31,404,491 120 6,688 6,808 3.40
11 3 Asphalt Sales Tank 35 40 38 273,490 17.94 4,906,952
12 3 Asphalt Sales Tank 35 40 38 273,490 17.94 4,906,952
13 3 Asphalt Sales Tank 35 40 38 273,490 17.94 4,906,952
14 3 Asphalt Sales Tank 35 40 38 273,490 17.94 4,906,952
1,093,959 71.77 19,627,807 31 2,444 2,475 1.24
20 4 Mill Feed Tank 30 40 38 200,931 10.42 2,094,489
20 4 Mill Feed Tank 30 40 38 200,931 10.42 2,094,489
21 4 Mill Feed Tank 30 40 38 200,931 10.42 2,094,489
22 5 Mill Feed Tank 14 35 33 37,598 10.42 391,914
23 5 Mill Feed Tank 14 35 33 37,598 10.42 391,914
24 5 Mill Feed Tank 14 35 33 37,598 10.42 391,914
25 5 Mill Feed Tank 14 35 33 37,598 10.42 391,914
753,184 72.97 7,851,123 28 1,636 1,664 0.832
9 4 Reaction Tank 30 40 38 200,931 82.29 16,534,013 23 1,871 1,894 0.947
10 5 Reaction Tank 14 40 33 37,598 82.29 3,093,794 5 353 358 0.179
238,529 164.57 19,627,807 28 2,224 2,252 1.126
30 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
31 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
32 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
33 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
34 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
35 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
36 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
37 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
38 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
39 5 Asphalt Emulsion Tank 14 40 33 37,598 12.77 480,000
375,976 127.67 4,800,000 5 413 418 0.209
24,136,365 522 122,566,842 240 14,486 14,726 7.36
72,840 36.42
-58,114 -29.06
1 VOC emissions are based on EPA TANKS 5.0 ouput files for each tank type.
TOTAL:
28 1,081 1,109 0.55
Asphalt Emulsion Tank Total:
92 5,252 5,344 2.67
23 1,313 1,336
Tank Type Tank Type Description
VOC EMISSIONS1
Mill Feed Tank Total:
23
298
1,338
STORAGE TANKS
Tank #
0.67
31 2,444 2,475 1.24
0.6805
303 0.1515
5
Total Annual Losses
413 418 0.209
NET CHANGE IN VOC EMISSIONS:
TABLE 1: SUMMARY OF AC STORAGE AND ASSOCIATED VOC EMISSIONS
MOUNTAIN STATE ASPHALT - TOOELE, UTAH FACILITY
PRIOR VOC EMISSIONS FROM AC STORAGE OPERATIONS (2009 NOI):
Primary Asphalt Storage Tank Total:
Secondary Asphalt Storage Tank Total:
Asphalt Sales Tank Total:
Reaction Tank Total:
5
1,361

ATTACHMENT A –
EXCERPTS FROM 2009 NOI

Projected Emission Calculations
Source: UNCONTROLLED EMISSION SUMMARY
Company: Mountain States Asphalt
Site: Tooele, Utah
Date: April 2009
Uncontrolled in tons per year
SOURCE PM10 PM2.s SO2 NOx co voe HAP
Boilers 0.651 ND 0.08 12.51 10.51 0.69 0.24
Tanks 0.000 ND 0 0 0 36.425 0
Truck Loading 0.000 ND 0 0 0 7.24 0
Fugitive Emissions ND ND ND ND ND ND ND
Unpaved Road Dust 2.762 0.000 0 0 0 0 0
Paved Road Dust ND ND 0 0 0 0 0
Total 3.413 0.000 0.080 12.510 10.510 44.355 0.240
Projected Emission Calculations
Source: CONTROLLED EMISSION SUMMARY
Company: Mountain States Asphalt
Site: Tooele, Utah
Date: April 2009
Controlled in tons per year
SOURCE PM10 PM2s SO2 NOx co voe HAP
Boilers 0.651 ND 0.080 12.510 10.510 0.690 0.240
Tanks 0.000 ND 0 0 0 36.425 0
Truck Loading 0.000 ND 0 0 0 7.240 0
Fugitive Emissions ND ND ND ND ND ND ND
Unpaved Road Dust ND 0.000 0 0 0 0 0
Paved Road Dust 0.276 ND 0 0 0 0 0
Total 0.927 0.000 0.080 12.510 10.510 44.355 0.240
Petroleum Product Distribution Terminal Emissions
(Fuel, Crude Oil, Asphalt)
Mountain States Asphalt
Tooele, Utah
April 2009
46,000,000
0.6
0.43
84.25
860
0.3149265
=
=
=
=
=
=
or
Annual throughput, tanker capacity in gallons
s
p
M
T
Eff
0.000315 pounds per gallon
VOC emissions from Tanker Loading
14486.6 pounds per year 7.24 tons per year
Loading Losses
LL
s
p
M
T
Eff
loading losses in pounds VOC per 1000 gallons
saturation factor, AP-42 Chapter 5.2, Table 5.2
Reid vapor pressure of material, psia
vapor molecular weight of material
temperature of material in Rankine
average control efficiency

ATTACHMENT B –
TANK CHARACTERSTICS SUMMARIES

MSA Tank Type 1 Primary Asphalt Storage Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:60 feet
Shell Diameter:120 feet
Shell Capacity:5,076,157 gallons
Tank Count 4
Combined Shell Capacity:20,304,628 gallons
Maximum Liquid Height:58 feet
Average Liquid Level Height:29 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:690 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:635 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 2 Asphalt Blending Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:40 feet
Shell Diameter:60 feet
Shell Capacity:846,026 gallons
Tank Count 3
Combined Shell Capacity:2,538,078 gallons
Maximum Liquid Height:38 feet
Average Liquid Level Height:19 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 3 Asphalt Blending Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:40 feet
Shell Diameter:35 feet
Shell Capacity:287,884 gallons
Tank Count 4
Combined Shell Capacity:1,151,536 gallons
Maximum Liquid Height:38 feet
Average Liquid Level Height:19 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 4 Primary Asphalt Storage Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:40 feet
Shell Diameter:30 feet
Shell Capacity:211,507 gallons
Tank Count 4
Combined Shell Capacity:846,026 gallons
Maximum Liquid Height:38 feet
Average Liquid Level Height:19 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 5 Asphalt Blending Tanks
Tank Shape Cylinder
Height:40 feet
Diameter:14 feet
Shell Capacity:46,061 gallons
Tank Count 12
Combined Shell Capacity:552,737 gallons
Tank Count 4
Combined Shell Capacity:2,210,948 gallons
Maximum Liquid Height:32.65 feet
Average Liquid Level Height:16.325 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 1 Primary Asphalt Storage Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:60 feet
Shell Diameter:120 feet
Shell Capacity:5,076,157 gallons
Tank Count 4
Combined Shell Capacity:20,304,628 gallons
Maximum Liquid Height:58 feet
Average Liquid Level Height:29 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:690 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:635 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 2 Asphalt Blending Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:40 feet
Shell Diameter:60 feet
Shell Capacity:846,026 gallons
Tank Count 3
Combined Shell Capacity:2,538,078 gallons
Maximum Liquid Height:38 feet
Average Liquid Level Height:19 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 3 Asphalt Blending Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:40 feet
Shell Diameter:35 feet
Shell Capacity:287,884 gallons
Tank Count 4
Combined Shell Capacity:1,151,536 gallons
Maximum Liquid Height:38 feet
Average Liquid Level Height:19 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 4 Primary Asphalt Storage Tanks
Tank Characteristics
Tank Shape Cylinder
Shell Height:40 feet
Shell Diameter:30 feet
Shell Capacity:211,507 gallons
Tank Count 4
Combined Shell Capacity:846,026 gallons
Maximum Liquid Height:38 feet
Average Liquid Level Height:19 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
MSA Tank Type 5 Asphalt Blending Tanks
Tank Shape Cylinder
Height:40 feet
Diameter:14 feet
Shell Capacity:46,061 gallons
Tank Count 12
Combined Shell Capacity:552,737 gallons
Tank Count 4
Combined Shell Capacity:2,210,948 gallons
Maximum Liquid Height:32.65 feet
Average Liquid Level Height:16.325 feet
Tank Bottom Type:Flat
Liquid Heel Type at Tank Minimum:None
Vapor Space Pressure at Normal Operating Conditions:12.64 default
Insulated:Fully Insulated
Heated:Yes
Typical Max Liquid Bulk Temperature in Heating Cycle:790 degrees R
Typical Avg. Liquid Bulk Temperature in Heating Cycle:668 degrees R
Typical Minimum Liquid Bulk Temperature in Heating Cycle:530 degrees R
Number of Heat Cycles per Year:1
Shell Characteristics
Shell Color/Shade:Aluminum - Mill finish, unpainted
Shell Condition:Average
Roof Characteristics
Roof Color/Shade:Aluminum - Specular
Roof Condition:Average
Roof Type:Cone
Tank Cone Roof Slope (ft/ft)0.05
Breather Vent Settings
Vaccum Setting:0.00 (atmospheric)psig
Pressure Setting:0.00 (atmospheric)psig
Control Device Settings
Is Tank Equiped with a Control Device?:No Control Device
AC Storage Tank Profile Summary
TANK Type 11
March April May June July August
(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(tons)
Standing Losses 174 187 212 214 221 211
Working Losses 4989 4989 4989 4989 4989 4989
Total Losses 5163 5176 5201 5203 5210 5200 31,153 15.6
TANK Type 2
March April May June July August
(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(tons)
Standing Losses 71 77.3 88 89 92 87
Working Losses 3563 3563 3563 3563 3563 3563
Total Losses 3634 3640.3 3651 3652 3655 3650 21,882 10.9
TANK Type 3
March April May June July August
(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(tons)
Standing Losses 12 13 15 15 15 15
Working Losses 1511 1511 1511 1511 1511 1511Total Losses 1523 1524 1526 1526 1526 1526 9,151 4.6
TANK Type 4
March April May June July August
(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(lbs)(tons)
Standing Losses 16 18 20 20 21 20
Working Losses 1758 1758 1758 1758 1758 1758Total Losses 1774 1776 1778 1778 1779 1778 10,663 5.3
(lbs)(tons)
72,849 36.42
Total:
GRAND TOTAL:
SUMMARY OF ASPHALT EMISSIONS - MOUNTAIN STATES INITIAL NOI (2009)
Total:
Total:
Total:
Total: