DAQ-2024-007434

1
DAQC-CI121450001-24
Site ID 12145 (B1)
MEMORANDUM

TO: FILE – PEAK ASPHALT LLC – Cowboy Asphalt Terminal

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: April 1, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County

INSPECTION DATE: February 29, 2024

SOURCE LOCATION: 1710 West 2600 South
Woods Cross, UT 84087
SOURCE CONTACTS: Matt Church, EHS Director
208-821-7039 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection

PROCESS DESCRIPTION: Peak Asphalt operates an asphalt storage and blending source at
this location. The pre-heated asphalt is trucked to the source,
were it is received at the truck unloading rack. Once the asphalt
has been received, it is pumped from the transport vessel (truck)
to different storage tanks. The on-site storage tanks are either
heated by one of three natural gas fired tank heaters or one of
two hot oil heaters. From the storage tanks, some of the asphalt
is sent through processing mills that either mixes the asphalt with
water or a polymer. This produces asphalt with different physical
properties, which is used for different applications.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN121450011-15, dated February
13, 2015
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Peak Asphalt LLC
Cowboy Asphalt Terminal

1710 West 2600 South 1710 West 2600 South
Woods Cross, UT 84087 Woods Cross, UT 84087

SIC Code: 2951: (Asphalt Paving Mixtures & Blocks)

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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]

Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. An emissions
inventory was submitted for 2020, and emissions data are reported below.

Section II: SPECIAL PROVISIONS

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

II.A.1 Cowboy Asphalt Terminal
Permitted Source

II.A.2 Asphalt tank heaters
Three (3) natural gas-fired tank heaters

II.A.3 Hot oil heaters
Three (3) hot oil heaters (First Thermal Systems 600, CEI-5000, CEI-6300)

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II.A.4 Asphalt loading racks
Six (6) asphalt loading racks

II.A.5 Biological water treatment tanks
Two (2) horizontal tanks for water treatment process

II.A.6 Storage tanks
39 Vertical fixed roof storage tanks

II.A.7 Asphalt blending mills
Two (2) asphalt blending mills

II.A.8 Dalworth Colloid Blending Mill
Asphalt blending mill

II.A.9 Oil separator system
Open-top feed tank and separation vat

II.A.10 Quench tank - carbon filter train
Odor control system

II.A.11 Miscellaneous
Fugitive dust from roads, etc.

Status: In Compliance. No unpermitted equipment was observed at the time of inspection.
The source plans to replace one of the hot oil heaters, and the NOI submission
process was explained at the time of inspection.

II.B Requirements and Limitations

II.B.1 Conditions on permitted source

II.B.1.a Visible emissions from all stationary sources shall not exceed 15% opacity. Opacity observations
of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A,
Method 9. [R307-401-8]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

II.B.1.b Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas
shall not exceed 20% opacity. [R307-309-5]

Status: In Compliance. There were no visible fugitive dust emissions observed at the time of
inspection. The source takes steps to minimize fugitive dust by watering roads during
summer months and restricting the speed of vehicles involved in the operation.

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II.B.1.c The owner/operator shall not exceed 100,000 tons of asphalt received per rolling 12-month
period.

To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total each month using data from the previous 12 months. Records of consumption
shall be kept for all periods when the plant is in operation. Consumption shall be determined by
shipping records. The records of consumption shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from February 2023 - January
2024, a total of 51,290.41 total tons of asphalt throughput was processed at this facility. See
the attached summary.

II.B.1.d The owner/operator shall use only natural gas as fuel in the hot oil and tank heaters.
[R307-401-8]

Status: In Compliance. Only natural gas is used as fuel in the hot oil and tank heaters.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible emissions were observed from any point at the time of inspection.
See attached VEO Form for additional information.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Peak Asphalt LLC – Cowboy Asphalt
Terminal from the 2020 submission year. A comparison of the estimated total potential emissions (PTE)
on AO DAQE-AN121450011-15, dated February 13, 2015 is provided. PTE are supplied for
supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 5273.50 N/A
Carbon Monoxide 8.54 0.01365
Nitrogen Dioxide 10.20 0.01855
Particulate Matter - PM10 1.12 0.22141
Particulate Matter - PM2.5 1.12 0.02341
Sulfur Dioxide 0.06 0.00011
Volatile Organic Compounds 3.52 3.35742

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Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 600 478
Organic HAPs (CAS #OHAPS) 1420 N/A

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years. An odor
complaint was received in 2020 – see DAQC-1540-20 for more
information.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN121450011-15,
dated February 13, 2015: in Compliance at the time of
inspection. Check in with Davis County Health Department for
potential accompaniment on next inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The source is planning to replace their First Thermal Systems
600 hot oil heater. Ensure that the AO has been modified to
show the update in the equipment.

NSR RECOMMENDATIONS: Expect NOI for replacement hot oil heater

ATTACHMENTS: VEO form, email correspondence, asphalt throughput summary
3/11/24, 11:07 AM State of Utah Mail - 12145 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r2941316969603193410&simpl=msg-a:r-77493256444507…1/2
Daniel Riddle <[e-mail]>
12145 - follow up to air quality inspection
3 messages
Daniel Riddle <[e-mail]>Fri, Mar 1, 2024 at 9:50 AM
To: [e-mail]
Aubrey,
Thanks for meeting yesterday for your air quality inspection. As a reminder, here is the record I need to complete my inspection report:
From AO DAQE-AN121450011-15, Condition II.B.1.c:
tons of asphalt received from February 2023 - January 2024.
Please provide this record by March 8, 2024. Let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Matthew Church <[e-mail]>Mon, Mar 4, 2024 at 10:46 AM
To: "[e-mail]" <[e-mail]>
Hi Daniel,
Please find the Woods Cross Facility throughput report as requested and in compliance with the requirements from Condition II.B.1.c of our AO.
Please let me know if you need anything else. Thank you.
Matt

Matt Church, PWS
EHS Director
Idaho Asphalt Supply, Inc. and Subsidiaries
M: 208.821.7039

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From: Daniel Riddle <[e-mail]>
Sent: Friday, March 1, 2024 9:51 AM
3/11/24, 11:07 AM State of Utah Mail - 12145 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r2941316969603193410&simpl=msg-a:r-77493256444507…2/2
To: Aubrey Acosta <[e-mail]>
Subject: [E]12145 - follow up to air quality inspecon

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.

Aubrey,

Thanks for meeting yesterday for your air quality inspection. As a reminder, here is the record I need to complete my inspection report:

From AO DAQE-AN121450011-15,:
tons of asphalt received from February 2023 - January 2024.

Please provide this record by March 8, 2024. Let me know if you have any questions.

Best,
Daniel

--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: (385) 222-
1357
airquality.utah.gov

Woods Cross Shipping Report.pdf
90K
Daniel Riddle <[e-mail]>Mon, Mar 11, 2024 at 11:07 AM
Draft To: Matthew Church <[e-mail]>
Thank you - I will let you know if I need anything else.
[Quoted text hidden]
Shipping Report
Material shiped between February 01, 2023 and January 31, 2024
W1 - Woods Cross Asphalt Warehouse Tons Shipped
AC - Asphalt Cement
PG58-28 3,117.24
PG64-22 619.58
Total AC Shipped 3,736.82
Dilute Emuls - Dilute Emulsion
CQS-1H 2:1 Dilute 579.08
Total Dilute Emuls
Shipped
579.08
Emulsion - Emulsion
PMCSS-1NV 1,012.30
CQS-1H 2,476.80
CQS-1HLM_3% 3,677.77
CQS-1P (SLR) 3,866.58
CQS-1P (Natural Latex) 392.06
Total Emulsion Shipped 11,425.51
PMA - Polymer Modified Asphalt
PG64-28 3,426.80
PG64-28NV 5,912.78
PG64-34UT 16,545.07
PG70-28UT 11,646.66
PG70-28WY 780.15
PG76-34UTHP 838.92
Total PMA Shipped 39,150.38
W1 Product Summary
3,736.82AC
579.08Dilute Emuls
11,425.51Emulsion
39,150.38PMA
54,891.79
51,290.41
Total Shipped:
Total Asphalt Throughput
Business Date: 2/29/2024
9:44:37 AM2/29/2024Run Date:
WC1 - Customer Owned Inventory Tons Shipped
AC - Asphalt Cement
PG58-28 37.47
Total AC Shipped 37.47
PMA - Polymer Modified Asphalt
PG52-34 32.74
PG64-34UT 239.20
PG64-34UT 2,259.04
Total PMA Shipped 2,530.98
WC1 Product Summary
37.47AC
2,530.98PMA
2,568.45
2,568.45
Total Shipped:
Total Asphalt Throughput
Business Date: 2/29/2024
9:44:37 AM2/29/2024Run Date: