DAQ-2024-011859

DAQE-AN124690014-24

{{$d1 }}

Marc Greeley
Western Emulsions, Inc.
PO Box 50538
Idaho Falls, ID 83405
[e-mail]

Dear Mr. Greeley:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN124690012-14 for a
10-Year Review and Permit Updates
Project Number: N124690014

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a
10-year administrative review of this source and its respective AO. Western Emulsions, Inc. must
comply with the requirements of this AO, all applicable state requirements (R307), and Federal
Standards.

The project engineer for this action is Katie Andersen, 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:KA:jg

cc: Salt Lake 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

November 26, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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

APPROVAL ORDER
DAQE-AN124690014-24
Administrative Amendment to Approval Order
DAQE-AN124690012-14 for a 10-Year Review
and Permit Updates

Prepared By
Katie Andersen, Engineer
[phone]
[e-mail]

Issued to
Western Emulsions, Inc. - Woods Cross North Asphalt Terminal

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

November 26, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN124690014-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Western Emulsions, Inc. Western Emulsions, Inc. - Woods Cross North Asphalt Terminal

Mailing Address Physical Address
PO Box 50538 991 West 1500 South
Idaho Falls, ID 83405 Woods Cross, UT 84087

Source Contact UTM Coordinates
Name: Marc Greeley 423,423 m Easting
Phone: [phone],525,004 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2951 (Asphalt Paving Mixtures & Blocks)

SOURCE INFORMATION
General Description
Western Emulsions, Inc. operates an asphalt blending and storage facility in Woods Cross, Davis County.
Raw asphalt materials are shipped by railcar to the site where the railcars are heated, and the materials are
piped to the storage tanks as the asphalt is needed. Boilers provide steam for heating the asphalt in the
railcars. Hot oil heaters keep the asphalt material warm enough to flow to and from the storage tanks.
Materials are piped to different tanks for blending and adding additives such as rubber, polymers, and
chemicals. The blended materials are piped to a truck terminal for loading into distribution haul trucks.

NSR Classification
10-Year Review

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

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units
DAQE-AN124690014-24
Page 4

Project Description
This is a 10-year review to update the language, format, and layout of the permit to match current DAQ
permitting standards. The two asphalt tanks that were listed under Equipment Item II.A.8 in the current
AO have been removed from the permit because they have not been constructed and the source has no
plans to install the tanks at this time.

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 24119.00
Carbon Monoxide 0 17.46
Nitrogen Oxides 0 19.98
Particulate Matter - PM10 0 4.75
Particulate Matter - PM2.5 0 4.75
Sulfur Oxides 0 0.13
Volatile Organic Compounds 0 45.93

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 2980
Change (TPY) Total (TPY)
Total HAPs 0 1.49

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]
DAQE-AN124690014-24
Page 5

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 Woods Cross Asphalt and Emulsion Plant
II.A.2 Medium Cure Asphalt Tanks Six (6) tanks Item numbers 1 through 6 Capacity: 12'x30' each Service: medium cure asphalt II.A.3 Asphalt Emulsion Tanks Nine (9) tanks in total Item numbers 7 through 13, 15, and 16 Three (3) tanks Capacity: 11'x28' each One (1) tank Capacity: 11'x30' One (1) tank Capacity: 12'x28' One (1) tank Capacity: 12'x30' One (1) tank Capacity: 11'x16' Two (2) tanks Capacity: 12'x30' Service: asphalt emulsion
DAQE-AN124690014-24
Page 6

II.A.4 Asphalt Cement Tanks Sixteen tanks in total Item numbers 103 through 109, and 201, 202, 206 through 210, 211, and 212 Two (2) tanks Capacity: 67'x40' each Two (2) tanks Capacity: 16.5'x30' each Two (2) tanks Capacity: 50.7'x28' each One (1) tank Capacity: 25.6'x30' One (1) tank Capacity: 22'x16' One (1) tank Capacity: 16.5'x28' Two (2) tanks Capacity: 36.6'x40' each Three (3) tanks Capacity: 25.7'x30' each Two (2) tanks Capacity: 10'x10' Service: asphalt cement II.A.5 Distillate Tanks
Three (3) tanks in total
Item numbers 14, H2, and H3
One (1) tank
Capacity: 12'x30'
Two (2) tanks
Capacity: 7.8'x27.4' each
Service: distillate

II.A.6 Extender Tanks Three (3) tanks in total Item numbers H4, H5, and H8 Two (2) tanks Capacity: 12'x36' each One (1) tank Capacity: 8'x10' Service: extenders
DAQE-AN124690014-24
Page 7

II.A.7 Miscellaneous Tanks Six (6) tanks in total Item numbers C1, C2, 204, H6, and HCL One (1) tank Capacity: 9'x15' Service: chemical One (1) tank Capacity: 6'x19' Service: chemical One (1) tank Capacity: 7'x21' Service: anti-strip agent One (1) tank Capacity: 10'x14' Service: sulfur One (1) tank Capacity: 11'x28' Service: water One (1) tank Capacity: 6'x19' Service: HCl
II.A.8 Heaters
Two (2) heaters Ratings:
One (1) 14.5 MMBtu/hr
One (1) 10 MMBtu/hr Fuel: Natural Gas
NSPS Applicability: Subpart Dc

II.A.9 Boilers Two (2) boilers Ratings: One (1) 16.5 MMBtu/hr One (1) 5.2 MMBtu/hr Fuel: Natural Gas NSPS Applicability: Subpart Dc
II.A.10 Truck Loading Racks

II.A.11 Railcar Heating
II.A.12 Overhead Loading Rack

II.A.13 Furnace One (1) controlled pyrolysis cleaning furnace Rating: 0.325 MMBtu/hr
DAQE-AN124690014-24
Page 8

II.A.14 Miscellaneous Equipment Small storage tanks Small generators Asphalt reclamation tanks Propane heating torches Miscellaneous maintenance equipment Odor control devices (do not control emissions) Laboratory equipment Emulsion mills Polymer grinders Parts washers Maintenance equipment

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 The Woods Cross Asphalt Terminal shall comply with the following conditions:
II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits: A. Heaters - 10% opacity B. Furnaces - 10% opacity C. Boilers - 10% opacity D. All other emission points except for periods of start-up, shut-down, or malfunction - 20% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not exceed a throughput of 260,000,000 gallons of asphalt per rolling 12-month period. [R307-401-8]
II.B.1.b.1 The owner/operator shall:

A. Determine throughput by examination of company and/or customer billing records
B. Record asphalt throughput on a daily basis
C. Use the throughput 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 throughput records for all periods when the plant is in operation.
[R307-401-8]
II.B.1.c The owner/operator shall not allow visible emissions from haul-road traffic and mobile equipment in operational areas to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5, R307-401-8]
DAQE-AN124690014-24
Page 9

II.B.1.c.1 Opacity observations from haulroads and mobile vehicles shall be conducted according to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. For fugitive dust generated by mobile sources, 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. [R307-401-8] II.B.1.d The owner/operator shall apply water or chemical treatment to fugitive dust sources, all unpaved
operational areas that are used by mobile equipment, to prevent visible emissions from exceeding the opacity limits listed in this AO. The owner/operator may stop applying water to fugitive dust sources when the temperature is below freezing but shall apply other controls as necessary to
prevent visible emissions from exceeding the opacity limits listed in this AO. Treatment shall be of sufficient frequency, intensity, and duration to maintain the surface material in a damp/moist condition unless it is below freezing. [R307-401-8]

II.B.1.d.1 The owner/operator shall keep records of water application and fugitive dust control for all periods when the plant is in operation. If chemical treatment is to be used, the plan must be approved by the Director. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made, dilution ratio, and quantity of water applied C. Rainfall amount received, if any, and approximate amount D. Records of temperature, if the temperature is below freezing. [R307-401-8]
II.B.1.e The owner/operator shall not exceed a paved in-plant haul road length of 0.40 miles.
[R307-401-8]
II.B.1.f The owner/operator shall not exceed a haul road speed limit of 10 miles per hour. [R307-401-8]
II.B.1.g The owner/operator shall comply with the applicable requirements of R307-304 Solvent Cleaning and R307-335 Degreasing. [R307-304, R307-335]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN124690012-14 dated August 4, 2014
DAQE-AN124690014-24
Page 10

ACRONYMS

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

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

DAQE-
RN124690014 October 29, 2024 Marc Greeley Western Emulsions, Inc. PO Box 50538 Idaho Falls, ID 83405 [e-mail] Dear Marc Greeley, Re: Engineer Review: Administrative Amendment to Approval Order DAQE-AN124690012-14 for a 10-Year Review and Permit Updates Project Number: N124690014 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. Western Emulsions, Inc. should complete this review within 10 business days of receipt. Western Emulsions, Inc. should contact Katie Andersen at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen 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 Western Emulsions, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Western Emulsions, 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 N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 1
UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW
SOURCE INFORMATION Project Number N124690014 Owner Name Western Emulsions, Inc. Mailing Address PO Box 50538 Idaho Falls, ID, 83405 Source Name Western Emulsions, Inc.- Woods Cross North Asphalt Terminal Source Location 991 West 1500 South Woods Cross, UT 84087 UTM Projection 423,423 m Easting, 4,525,004 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2951 (Asphalt Paving Mixtures & Blocks) Source Contact Marc Greeley Phone Number [phone] Email [e-mail] Billing Contact Matt Church Phone Number [phone] Email [e-mail] Project Engineer Katie Andersen, Engineer Phone Number [phone] Email [e-mail] Notice of Intent (NOI) Submitted July 8, 2024 Date of Accepted Application August 1, 2024

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 2
SOURCE DESCRIPTION General Description Western Emulsions, Inc. operates an asphalt blending and storage facility in Woods Cross, Davis County. Raw asphalt materials are shipped by railcar to the site where the railcars are heated and the materials are piped to the storage tanks as the asphalt is needed. Boilers provide steam for heating the asphalt in the railcars. Hot oil heaters keep the asphalt material warm enough to flow to and from the storage tanks. Materials are piped to different tanks for blending and adding additives such as rubber, polymers, and chemicals. The blended materials are piped to a truck terminal for loading into distribution haul trucks. NSR Classification: 10 Year Review Source Classification Located in the Northern Wasatch Front O3 NAA and Salt Lake City UT PM2.5 NAA Davis County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Project Proposal Administrative Amendment to Approval Order DAQE-AN124690012-14 for a 10-Year Review and Permit Updates Project Description This is a 10-year review to update the language, format, and layout of the permit to match current DAQ permitting standards. The two asphalt tanks that were listed under Equipment Item II.A.8 in the current AO have been removed from the permit because they have not been constructed and the source has no plans to install the tanks at this time. EMISSION IMPACT ANALYSIS This is a 10-year review. There are no changes to emissions or equipment. Therefore, modeling is not required at this time. [Last updated August 6, 2024]

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 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 24119.00
Carbon Monoxide 0 17.46 Nitrogen Oxides 0 19.98 Particulate Matter - PM10 0 4.75 Particulate Matter - PM2.5 0 4.75
Sulfur Oxides 0 0.13 Volatile Organic Compounds 0 45.93 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 2980
Change (TPY) Total (TPY) Total HAPs 0 1.49 Note: Change in emissions indicates the difference between previous AO and proposed modification.
Commented [KA1]: All Changes should be zero because there are no change to emissions.

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review This is a 10-year review. There are no changes to emissions or equipment at this time. Therefore, a BACT analysis is not required. [Last updated August 6, 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 N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 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 Woods Cross Asphalt and Emulsion Plant II.A.2 Medium Cure Asphalt Tanks Six (6) Tanks Item numbers 1 through 6 Capacity: 12'x30' each Service: medium cure asphalt II.A.3 Asphalt Emulsion Tanks Nine (9) Tanks in total Item numbers 7 through 13, 15, and 16 Three (3) tanks Capacity: 11'x28' each One (1) tank Capacity: 11'x30' One (1) tank Capacity: 12'x28'
One (1) tank Capacity: 12'x30' One (1) tank Capacity: 11'x16' Two (2) tanks Capacity: 12'x30' Service: asphalt emulsion

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 6
II.A.4 Asphalt Cement Tanks Sixteen Tanks in total Item numbers 103 through 109, and 201, 202, 206 through 210, 211, and 212 Two (2) tanks Capacity: 67'x40' each Two (2) tanks Capacity: 16.5'x30' each Two (2) tanks Capacity: 50.7'x28' each One (1) tank Capacity: 25.6'x30' One (1) tank Capacity: 22'x16' One (1) tank Capacity: 16.5'x28'
Two (2) tanks Capacity: 36.6'x40' each Three (3) tanks Capacity: 25.7'x30' each Two (2) tanks Capacity: 10'x10' Service: asphalt cement II.A.5 Distillate Tanks Three (3) Tanks in total Item numbers 14, H2, and H3 One (1) tank Capacity: 12'x30' Two (2) tanks Capacity: 7.8'x27.4' each Service: distillate

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 7
II.A.6 Extender Tanks Three (3) Tanks in total Item numbers H4, H5, and H8 Two (2) tanks Capacity: 12'x36' each One (1) tank Capacity: 8'x10' Service: extenders II.A.7 Miscellaneous Tanks Six (6) Tanks in total Item numbers C1, C2, 204, 204, H6, and HCL One (1) tank Capacity: 9'x15' Service: chemical One (1) tank Capacity: 6'x19' Service: chemical One (1) tank Capacity: 7'x21' Service: anti-strip agent One (1) tank Capacity: 10'x14' Service: sulfur One (1) tank Capacity: 11'x28' Service: water One (1) tank Capacity: 6'x19' Service: HCl II.A.8 Heaters Two (2) heaters Ratings: One (1) 14.5 MMBtu/hr One (1) 10 MMBtu/hr Fuel: Natural Gas NSPS Applicability: Subpart Dc

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 8
II.A.9 Boilers Two (2) Boilers Ratings: One (1) 16.5 MMBtu/hr
One (1) 5.2 MMBtu/hr Fuel: Natural Gas NSPS Applicability: Subpart Dc
II.A.10 Truck Loading Racks
II.A.11 Railcar Heating
II.A.12 Overhead Loading Rack
II.A.13 Furnace One (1) controlled pyrolysis cleaning furnace
Rating: 0.325 MMBtu/hr II.A.14 Miscellaneous Equipment Small storage tanks Small generators Asphalt reclamation tanks Propane heating torches Miscellaneous maintenance equipment Odor control devices (do not control emissions) Laboratory equipment Emulsion mills Polymer grinders Parts washers Maintenance equipment
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 NEW The Woods Cross Asphalt Terminal shall comply with the following conditions:

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 9
II.B.1.a NEW The owner/operator shall not allow visible emissions to exceed the following limits: A. Heaters - 10% opacity B. Furnaces - 10% opacity C. Boilers - 10% opacity D. All other emission points except for periods of start-up, shut-down, or malfunction -
20% opacity. [R307-401-8] II.B.1.a.1 NEW Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b NEW The owner/operator shall not exceed a throughput of 260,000,000 gallons of asphalt per rolling 12-month period. [R307-401-8] II.B.1.b.1 NEW The owner/operator shall: A. Determine throughput by examination of company and/or customer billing records. B. Record asphalt throughput on a daily basis
C. Use the throughput 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 throughput records for all periods when the plant is in operation. [R307-401-8] II.B.1.c NEW The owner/operator shall not allow visible emissions from haul-road traffic and mobile equipment in operational areas to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5, R307-401-8]
II.B.1.c.1 NEW Opacity observations from haul-roads and mobile vehicles shall be conducted according to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. For fugitive dust generated by mobile sources, 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. [R307-401-8]
II.B.1.d NEW The owner/operator shall apply water or chemical treatment to fugitive dust sources, all unpaved operational areas that are used by mobile equipment, to prevent visible emissions from exceeding the opacity limits listed in this AO. The owner/operator may stop applying water to fugitive dust sources when the temperature is below freezing but shall apply other controls as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. Treatment shall be of sufficient frequency, intensity, and duration to maintain the surface material in a damp/moist condition unless it is below freezing. [R307-401-8]

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 10
II.B.1.d.1 NEW The owner/operator shall keep records of water application and fugitive dust control for all periods when the plant is in operation. If chemical treatment is to be used, the plan must be approved by the Director. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made, dilution ratio, and quantity of water applied
C. Rainfall amount received, if any, and approximate amount D. Records of temperature, if the temperature is below freezing. [R307-401-8] II.B.1.e NEW The owner/operator shall not exceed a paved in-plant haul road length of 0.40 miles. [R307-401-8] II.B.1.f NEW The owner/operator shall not exceed a haul road speed limit of 10 miles per hour. [R307-401-8]
II.B.1.g NEW The owner/operator shall comply with the applicable requirements of R307-304 Solvent Cleaning and R307-335 Degreasing. [R307-304, R307-335]

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 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-AN124690012-14 dated August 4, 2014
REVIEWER COMMENTS 1. Comment regarding 10-Year Review: This is a 10-year review to update the language, format, and layout of the AO to match current DAQ permitting standards. The source contact information has been updated and each condition in the Requirements and Limitations section has been split into multiple conditions.
Some of the equipment was noted to not be in use in the Compliance Inspection dated May 7, 2024. The source would like to leave the equipment listed on the Approval Order in order to keep their options open in regards to the products that are produced at the plant. The two asphalt tanks that were listed under Equipment Item II.A.8 in the current AO have been removed from the permit because they have not been constructed and the source has no plans to install the tanks at this time.
Conditions II.B.1.b. and II.B.1.b.1 have been updated to reflect the actual materials used at the source. The new Approval Order reads "asphalt" instead of "crude oil". The source has always tracked and reported asphalt throughput and finds no reason for the Approval Order to track crude oil. The DAQ has determined that the list of crude oil was in error and should have been stated as asphalt. [Last updated October 17, 2024] 2. Comment regarding Federal Rule Applicability: 40 CFR 60 Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units 40 CFR 60 Subpart Dc applies to each steam generating unit at an affected facility for which construction, modification, or reconstruction commenced after June 9, 1989, and that has a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. The source has two boilers in operation with heat ratings of 14.5 and 16.5 MMBtu/hr. Therefore, this subpart applies to the source. 40 CFR 60 Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, of Modification Commenced After July 23, 1984 40 CFR 60 Subpart Kb applies to each storage vessel with a capacity greater than or equal to 75 m3 that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification commenced after July 23, 1984. This subpart does not apply to storage vessels with a maximum true vapor pressure less than 3.5 kPa. The source has multiple storage tanks that have capacities larger than 75 m3. The source consistently calculates a true vapor pressure using AP-42 Antoine's Pressure Calculation Formula to be 0.063 kPa. Therefore, this subpart does not apply to the source. 40 CFR 63 Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 40 CFR 63 Subpart ZZZZ applies to owners and operators of stationary RICE at major or area

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 12
sources of HAP emissions. Western Emulsion Inc does not have stationary engines at their site. The small miscellaneous generators listed in the Approval Order under Equipment Item II.A.15 are small portable generators that are occasionally used during repairs but are not used regularly as a part of the normal operating procedures. These engines are not considered stationary engines. Therefore, this subpart does not apply to the source. 40 CFR 63 Subpart JJJJJJ: National Emission Standards for hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources 40 CFR 63 Subpart JJJJJJ applies to owners and operators of industrial, commercial, or institutional boilers that are located at or is part of an area source of HAP. Western Emulsion Inc. owns and operates two (2) industrial boilers on site. Therefore, this subpart applies to the source. [Last updated October 29, 2024] 3. Comment regarding State Rule Applicability: R307-304 Solvent Cleaning R307-304 applies to solvent cleaning operations within Box Elder, Cache, Davis, Salt Lake, Toole, Utah, or Weber Counties that before September 1, 2018, used 720 gallons or more a year of VOC containing solvent products for solvent cleaning operations, or after September 1, 2018, use 55 gallons or more a year of VOC containing solvent products for solvent cleaning operations. Western Emulsions uses Safety Kleen Premium Solvent; thus, is subject to this state rule. R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust R307-309 applies to all new or existing sources of fugitive dust in a PM10 or PM2.5 nonattainment or maintenance area. The Woods Cross Hot Asphalt Storage Terminal is in a PM2.5 nonattainment area, and thus is subject to this state rule. R307-325 Ozone Nonattainment and Maintenance Areas: General Requirements R307-325 applies to all sources located in any nonattainment or maintenance area for ozone. The Woods Cross Hot Asphalt Storage Terminal is located in an ozone nonattainment area; thus, is subject to this state rule. R307-335 Degreasing R307-335 applies to degreasing operations that use VOCs and that are located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, or Weber counties. The source has one parts washer and is located in Davis County. Thus, the source is subject to this state rule. [Last updated September 24, 2024] 4. Comment regarding Title V Applicability: 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 Source; 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 source is not a major source nor a Title IV affected source. The source is not subject to MACT or NESHAP regulations. This source is subject to 40 CFR 60 Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units thought there are no numerical standards within the standard that the source must comply with. Therefore, Title V does

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 13
not apply to this source. [Last updated September 24, 2024]

Engineer Review N124690014: Western Emulsions, Inc.- Woods Cross North Asphalt Terminal October 29, 2024 Page 14
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
Katie Andersen <[e-mail]>
Applicability of 40 CFR 63 Subpart Kb to the Woods Cross North Asphalt Terminal
2 messages
Katie Andersen <[e-mail]>Thu, Oct 17, 2024 at 11:30 AM
To: Marc Greeley <[e-mail]>
Hi Marc,
The 10-Year Review for DAQE-AN124690012-14 for the Woods Cross North Asphalt Terminal is in the last stages of the
DAQ internal review process. The next step will be your review of the engineering review document before the updated
approval order is finalized.
A question has been raised about the applicability of 40 CFR 63 (MACT) Subpart 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, and On or Before October 4, 2023. I've looked at the
sizes of the tanks on site and estimated that most of the tanks are larger than 75 cubic meters. I believe some are larger
than 151 cubic meters, though I do not have enough information to estimate the maximum true vapor pressure of the
liquids in the tanks.
Will you evaluate the subpart to determine its applicability to the Woods Cross North Asphalt Terminal? Please provide
justification as to why or why not the subpart applies.
I appreciate your assistance with this.
Cheers,
Katie Andersen
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Marc Greeley <[e-mail]>Mon, Oct 28, 2024 at 12:00 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Hey Katie, I hope this note finds you in good spirits and enjoying the falling
fall. Seems like winter might stop by a bit this week.

10/29/24, 9:12 AM State of Utah Mail - Applicability of 40 CFR 63 Subpart Kb to the Woods Cross North Asphalt Terminal
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1111045210229382679&simpl=msg-a:r-893999255536358…1/2
I’m not sure exactly what you need for backup, but the vapor pressure for our
stored asphalt consistently calculates (using the AP 42 Antoine’s pressure
calculation formula)at 0.063 kPa which is considerably below the 3.5 kPa limit
for applicability.

I hope that answers your question. Please don’t hesitate to contact me at your
convenience if you need anything further.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

From: Kae Andersen <[e-mail]>
Sent: Thursday, October 17, 2024 11:31 AM
To: Marc Greeley <[e-mail]>
Subject: [E]Applicability of 40 CFR 63 Subpart Kb to the Woods Cross North Asphalt Terminal

CAUTION: This email originated from outside the company. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
[Quoted text hidden]
10/29/24, 9:12 AM State of Utah Mail - Applicability of 40 CFR 63 Subpart Kb to the Woods Cross North Asphalt Terminal
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1111045210229382679&simpl=msg-a:r-893999255536358…2/2
Katie Andersen <[e-mail]>
Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
11 messages
Katie Andersen <[e-mail]>Wed, Jul 10, 2024 at 4:17 PM
To: [e-mail]
Hello Mr. Thorpe,
I'm reaching out to you regarding the Air Quality Permit (Approval Order) for the Western Emulsions, Inc Woods Cross
Hot Asphalt Storage Terminal. The current permit for the site is DAQE-AN124690012-14.
After about 10 years, the Division of Air Quality (DAQ) likes to perform a 10-Year Review on existing Approval Orders
(AO). The purpose of the 10-Year Reviews are to update contact information, formatting, language, and the general layout
of the permits to match current DAQ standards. The AO for the Woods Cross Hot Asphalt Storage Terminal is up for it's
10-Year Review.
I'd like to confirm contact information (source contact, billing contact/address, physical site address, business mailing
address) and the status of the equipment.
On the current permit, Blaine Totty is noted as the Source Contact, though you are noted as the source contact on the
most recent Compliance Inspection.
Should I direct my questions to you, or get in contact with Blaine Totty?
Thank you!
Cheers,
Katie Andersen
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Michael Thorpe <[e-mail]>Fri, Jul 12, 2024 at 12:20 PM
To: Katie Andersen <[e-mail]>
Cc: Marc Greeley <[e-mail]>
Hi Katie,
Sorry for the delay in the response, I wanted to check with our internal safety department. The local on site
contact would be myself at this address and numbers below. For permits, your contact would be Marc
Greeley whom I have attached as well on the email. He is out of our North Salt Lake office, and that number
is 801-397-7600.
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…1/8

If you need anything else, please let me know.

Thank you,

Mike Thorpe
Plant Manager
Woods Cross/North Woods Cross
Office: 801 296-0166
Cell: 385-566-7751
From: Kae Andersen <[e-mail]>
Sent: Wednesday, July 10, 2024 4:17 PM
To: Michael Thorpe <[e-mail]>
Subject: [E]Woods Cross Hot Asphalt Storage Terminal Air Quality Permit

CAUTION: This email originated from outside the company. Do not click links or open attachments unless you
recognize the sender and know the content is safe.

Hello Mr. Thorpe,

I'm reaching out to you regarding the Air Quality Permit (Approval Order) for the Western Emulsions, Inc Woods Cross
Hot Asphalt Storage Terminal. The current permit for the site is DAQE-AN124690012-14.

After about 10 years, the Division of Air Quality (DAQ) likes to perform a 10-Year Review on existing Approval Orders
(AO). The purpose of the 10-Year Reviews are to update contact information, formatting, language, and the general layout
of the permits to match current DAQ standards. The AO for the Woods Cross Hot Asphalt Storage Terminal is up for it's
10-Year Review.

I'd like to confirm contact information (source contact, billing contact/address, physical site address, business mailing
address) and the status of the equipment.

On the current permit, Blaine Totty is noted as the Source Contact, though you are noted as the source contact on the
most recent Compliance Inspection.

8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…2/8
Should I direct my questions to you, or get in contact with Blaine Totty?

Thank you!
Cheers,
Katie Andersen

--

[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Jul 15, 2024 at 3:28 PM
To: Marc Greeley <[e-mail]>
Hello Marc,
I'm not sure how much of my request Mike shared with you.
I reached out to Mike about the Air Quality Permit (Approval Order) for the Western Emulsions, Inc Woods Cross Hot
Asphalt Storage Terminal. The current permit for the site is DAQE-AN124690012-14.
After about 10 years, the Division of Air Quality (DAQ) likes to perform a 10-Year Review on existing Approval Orders
(AO). The purpose of the 10-Year Reviews are to update contact information, formatting, language, and the general layout
of the permits to match current DAQ standards. The AO for the Woods Cross Hot Asphalt Storage Terminal is up for it's
10-Year Review.
I'd like to confirm contact information (source contact, billing contact/address, physical site address, business mailing
address) and the status of the equipment. Mike indicated that you are the best source contact for permits.
Will you please provide the following information:
1. Your phone number/address
2. A billing contact: name, phone number, and billing address
3. The physical address for the site is listed as Woods Cross Hot Asphalt Storage Terminal 991 W 1500 S Woods Cross,
UT 84087. Is that correct?
4. A business mailing address
5. Attached is a copy of the current permit. Please review the equipment list and let me know what changes have been
made to the equipment on site. I have the following notes from the most recent Compliance Inspection about the
equipment, also attached, and want to confirm them.
I may have additional questions after this, but this should be sufficient for now.
Cheers,
Katie
[Quoted text hidden]
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…3/8
--

[Quoted text hidden]
2 attachments
DAQE-AN124690012-14.pdf
64K
DAQC-CI124690001-24.pdf
2051K
Marc Greeley <[e-mail]>Wed, Jul 17, 2024 at 9:50 AM
To: Katie Andersen <[e-mail]>
Hello Katie,
I just wanted to let you know that I received your email and I will review the
information and respond back by early next week as I am traveling this week
with a tight schedule.

Thanks for all you do, and I look forward to working with you on this project.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Jul 22, 2024 at 9:58 AM
To: Marc Greeley <[e-mail]>
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…4/8
Marc,
I look forward to working with you.
Cheers,
Katie
[Quoted text hidden]
Marc Greeley <[e-mail]>Mon, Jul 29, 2024 at 12:56 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Hello Katie,
Sorry for the delay. Please see information that you requested below:

1. Your phone number/address: Marc Greeley [phone]. 95 West 1100 North; Salt Lake City, UT 84054
2. A billing contact: name, phone number, and billing address: Matt Church; [phone]. PO Box 50538, Idaho Falls,
ID 83405
3. The physical address for the site is listed as Woods Cross Hot Asphalt Storage Terminal 991 W 1500 S Woods Cross,
UT 84087. Is that correct?: We now refer to the plant as “Woods Cross North Asphalt Terminal.” The address is correct.
4. A business mailing address: Use the physical address for mail directly to the terminal.

In terms of the equipment list verification, I will be visiting the site this
week and will forward the information after that. Thank you for your patience
and have a great week.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

From: Kae Andersen <[e-mail]>
Sent: Monday, July 15, 2024 3:28 PM
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…5/8
To: Marc Greeley <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
Marc Greeley <[e-mail]>Tue, Jul 30, 2024 at 12:11 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Hey Katie,
The Compliance Evaluation dated May 7, 2024 is correct in terms of the listed
permitted tanks and the current use status.

If you have any questions, or would like to discuss this matter further, please
don’t hesitate to contact me at your convenience.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

From: Kae Andersen <[e-mail]>
Sent: Monday, July 15, 2024 3:28 PM
To: Marc Greeley <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 31, 2024 at 3:03 PM
To: Marc Greeley <[e-mail]>
Cc: Matthew Church <[e-mail]>
Marc,
Thank you for the update and information.
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…6/8
Since some of the equipment is listed as not in use, would you like me to remove it from the AO? Do you plan on using
the equipment in the future?
Cheers,
Katie
[Quoted text hidden]
Marc Greeley <[e-mail]>Wed, Jul 31, 2024 at 5:05 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Katie,
If it’s all the same, I think we will leave the equipment on the AO for now so
we keep our options open in regards to the products we manufacture at that
plant. We have done a pretty good job of marking the items that are out of
service to avoid confusion, and we have no immediate plans for change.

Thanks for all you do, and please feel free to contact me at your convenience.
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Aug 6, 2024 at 9:22 AM
To: Marc Greeley <[e-mail]>
Cc: Matthew Church <[e-mail]>
Marc,
A few follow up questions for you.
In the permit, small miscellaneous generators are listed in II.A.15. I don't have enough information to determine the
applicability of 40 CFR 63 Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines. Will you determine if Subpart ZZZZ applies to the facility and provide the
reasoning for why it does or does not apply?
Requirements and LImitations Item II.B.1.b sets a limit for the throughput of crude oil. Since this is an asphalt blending
facility, I wondered if this should actually be for asphalt materials instead of crude oil. Would you be able to explain why
this limit is on crude oil and if it should stay that way?
I appreciate your assistance!
Cheers,
Katie Andersen
[Quoted text hidden]
Marc Greeley <[e-mail]>Thu, Aug 15, 2024 at 1:19 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Hello Katie,
Answers for the questions:

1. Because Subpart ZZZZ specifically applies to fixed generators and the WXN
facility does not have this equipment, we determined that the subpart does
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…7/8
not apply. Small portable generators are occasionally used during repairs,
but are not used regularly as a part of our operating procedures.

2. After researching this issue, I have not found a concrete reason that the
term crude oil is used in the throughput limitations. It seems to me that
the terms “crude oil” and “asphalt” are used interchangeably in the first
paragraph of the abstract, especially considering that there are no
references to crude oil storage tanks. Since we don’t use unprocessed crude
oil in any of our local operations, we have always tracked and reported
asphalt throughput.

I’m not sure it would be worth making a change to the document solely to
clarify the terms as we are reporting the product that was intended to be
tracked.

Thanks for all you do and please feel free to contact me at your convenience if
you have any other questions or require additional information.
[Quoted text hidden]
8/15/24, 3:05 PM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…8/8
Katie Andersen <[e-mail]>
Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
9 messages
Katie Andersen <[e-mail]>Wed, Jul 10, 2024 at 4:17 PM
To: [e-mail]
Hello Mr. Thorpe,
I'm reaching out to you regarding the Air Quality Permit (Approval Order) for the Western Emulsions, Inc Woods Cross
Hot Asphalt Storage Terminal. The current permit for the site is DAQE-AN124690012-14.
After about 10 years, the Division of Air Quality (DAQ) likes to perform a 10-Year Review on existing Approval Orders
(AO). The purpose of the 10-Year Reviews are to update contact information, formatting, language, and the general layout
of the permits to match current DAQ standards. The AO for the Woods Cross Hot Asphalt Storage Terminal is up for it's
10-Year Review.
I'd like to confirm contact information (source contact, billing contact/address, physical site address, business mailing
address) and the status of the equipment.
On the current permit, Blaine Totty is noted as the Source Contact, though you are noted as the source contact on the
most recent Compliance Inspection.
Should I direct my questions to you, or get in contact with Blaine Totty?
Thank you!
Cheers,
Katie Andersen
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Michael Thorpe <[e-mail]>Fri, Jul 12, 2024 at 12:20 PM
To: Katie Andersen <[e-mail]>
Cc: Marc Greeley <[e-mail]>
Hi Katie,
Sorry for the delay in the response, I wanted to check with our internal safety department. The local on site
contact would be myself at this address and numbers below. For permits, your contact would be Marc
Greeley whom I have attached as well on the email. He is out of our North Salt Lake office, and that number
is 801-397-7600.
8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…1/7

If you need anything else, please let me know.

Thank you,

Mike Thorpe
Plant Manager
Woods Cross/North Woods Cross
Office: 801 296-0166
Cell: 385-566-7751
From: Kae Andersen <[e-mail]>
Sent: Wednesday, July 10, 2024 4:17 PM
To: Michael Thorpe <[e-mail]>
Subject: [E]Woods Cross Hot Asphalt Storage Terminal Air Quality Permit

CAUTION: This email originated from outside the company. Do not click links or open attachments unless you
recognize the sender and know the content is safe.

Hello Mr. Thorpe,

I'm reaching out to you regarding the Air Quality Permit (Approval Order) for the Western Emulsions, Inc Woods Cross
Hot Asphalt Storage Terminal. The current permit for the site is DAQE-AN124690012-14.

After about 10 years, the Division of Air Quality (DAQ) likes to perform a 10-Year Review on existing Approval Orders
(AO). The purpose of the 10-Year Reviews are to update contact information, formatting, language, and the general layout
of the permits to match current DAQ standards. The AO for the Woods Cross Hot Asphalt Storage Terminal is up for it's
10-Year Review.

I'd like to confirm contact information (source contact, billing contact/address, physical site address, business mailing
address) and the status of the equipment.

On the current permit, Blaine Totty is noted as the Source Contact, though you are noted as the source contact on the
most recent Compliance Inspection.

8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…2/7
Should I direct my questions to you, or get in contact with Blaine Totty?

Thank you!
Cheers,
Katie Andersen

--

[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Jul 15, 2024 at 3:28 PM
To: Marc Greeley <[e-mail]>
Hello Marc,
I'm not sure how much of my request Mike shared with you.
I reached out to Mike about the Air Quality Permit (Approval Order) for the Western Emulsions, Inc Woods Cross Hot
Asphalt Storage Terminal. The current permit for the site is DAQE-AN124690012-14.
After about 10 years, the Division of Air Quality (DAQ) likes to perform a 10-Year Review on existing Approval Orders
(AO). The purpose of the 10-Year Reviews are to update contact information, formatting, language, and the general layout
of the permits to match current DAQ standards. The AO for the Woods Cross Hot Asphalt Storage Terminal is up for it's
10-Year Review.
I'd like to confirm contact information (source contact, billing contact/address, physical site address, business mailing
address) and the status of the equipment. Mike indicated that you are the best source contact for permits.
Will you please provide the following information:
1. Your phone number/address
2. A billing contact: name, phone number, and billing address
3. The physical address for the site is listed as Woods Cross Hot Asphalt Storage Terminal 991 W 1500 S Woods Cross,
UT 84087. Is that correct?
4. A business mailing address
5. Attached is a copy of the current permit. Please review the equipment list and let me know what changes have been
made to the equipment on site. I have the following notes from the most recent Compliance Inspection about the
equipment, also attached, and want to confirm them.
I may have additional questions after this, but this should be sufficient for now.
Cheers,
Katie
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8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…3/7
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2 attachments
DAQE-AN124690012-14.pdf
64K
DAQC-CI124690001-24.pdf
2051K
Marc Greeley <[e-mail]>Wed, Jul 17, 2024 at 9:50 AM
To: Katie Andersen <[e-mail]>
Hello Katie,
I just wanted to let you know that I received your email and I will review the
information and respond back by early next week as I am traveling this week
with a tight schedule.

Thanks for all you do, and I look forward to working with you on this project.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

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Katie Andersen <[e-mail]>Mon, Jul 22, 2024 at 9:58 AM
To: Marc Greeley <[e-mail]>
8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…4/7
Marc,
I look forward to working with you.
Cheers,
Katie
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Marc Greeley <[e-mail]>Mon, Jul 29, 2024 at 12:56 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Hello Katie,
Sorry for the delay. Please see information that you requested below:

1. Your phone number/address: Marc Greeley [phone]. 95 West 1100 North; Salt Lake City, UT 84054
2. A billing contact: name, phone number, and billing address: Matt Church; [phone]. PO Box 50538, Idaho Falls,
ID 83405
3. The physical address for the site is listed as Woods Cross Hot Asphalt Storage Terminal 991 W 1500 S Woods Cross,
UT 84087. Is that correct?: We now refer to the plant as “Woods Cross North Asphalt Terminal.” The address is correct.
4. A business mailing address: Use the physical address for mail directly to the terminal.

In terms of the equipment list verification, I will be visiting the site this
week and will forward the information after that. Thank you for your patience
and have a great week.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

From: Kae Andersen <[e-mail]>
Sent: Monday, July 15, 2024 3:28 PM
8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…5/7
To: Marc Greeley <[e-mail]>
[Quoted text hidden]
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Marc Greeley <[e-mail]>Tue, Jul 30, 2024 at 12:11 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Hey Katie,
The Compliance Evaluation dated May 7, 2024 is correct in terms of the listed
permitted tanks and the current use status.

If you have any questions, or would like to discuss this matter further, please
don’t hesitate to contact me at your convenience.
MSG

Marc Greeley
Environmental, Health, & Safety
Manager

Mobile: [phone]
Idaho Asphalt Supply, Inc.
95 West 1100 North
North Salt Lake, UT 84054

From: Kae Andersen <[e-mail]>
Sent: Monday, July 15, 2024 3:28 PM
To: Marc Greeley <[e-mail]>
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Katie Andersen <[e-mail]>Wed, Jul 31, 2024 at 3:03 PM
To: Marc Greeley <[e-mail]>
Cc: Matthew Church <[e-mail]>
Marc,
Thank you for the update and information.
8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…6/7
Since some of the equipment is listed as not in use, would you like me to remove it from the AO? Do you plan on using
the equipment in the future?
Cheers,
Katie
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Marc Greeley <[e-mail]>Wed, Jul 31, 2024 at 5:05 PM
To: Katie Andersen <[e-mail]>
Cc: Matthew Church <[e-mail]>
Katie,
If it’s all the same, I think we will leave the equipment on the AO for now so
we keep our options open in regards to the products we manufacture at that
plant. We have done a pretty good job of marking the items that are out of
service to avoid confusion, and we have no immediate plans for change.

Thanks for all you do, and please feel free to contact me at your convenience.
[Quoted text hidden]
8/1/24, 11:58 AM State of Utah Mail - Woods Cross Hot Asphalt Storage Terminal Air Quality Permit
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7382186399854122149&simpl=msg-a:r-61664051849286…7/7