DAQ-2024-004605

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DAQC-CI101020001-24
Site ID 10102 (B1)

MEMORANDUM

TO: FILE – UTAH STATE UNIVERSITY EASTERN – Price

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: December 21, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Carbon County

INSPECTION DATE: October 27, 2023

SOURCE LOCATION: 451 East 400 North
Price, UT 84501
SOURCE CONTACTS: Logan Bullough, Environmental Health and Safety Officer
435-613-5659; [e-mail]

OPERATING STATUS: Operating normally at the time of inspection

PROCESS DESCRIPTION: Utah State University Eastern Price (USU Eastern) is a college
located in Price, Carbon County. The university has several
natural gas-fired boilers, miscellaneous natural gas-fired small
boilers and heaters, and diesel-fired emergency generator
engines on site. The boilers are used to heat water and provide
steam for the university. The miscellaneous small boilers and
heaters are used to provide heat and hot water in various housing
and buildings. The emergency generator engines provide power
in the event of an emergency.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN10102002-21, dated April 15,
2021
NSPS (Part 60) -Dc : Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,
NSPS (Part 60) -IIII : Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Utah State University Eastern - Price
451 East 400 North 451 East 400 North
Price, UT 84501 Price, UT 84501

SIC Code: 8221: (Colleges, Universities, & Professional Schools)

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: Out of Compliance. The source submitted the 2020 Emission Inventory but did not
provide all the necessary information at the time of submission. Compliance assistance was
provided and the source is currently working with the emission inventory team to resolve
the issue and submit the missing items. The remaining conditions from Section I were
reviewed and determined to be in compliance.

Section II: SPECIAL PROVISIONS

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

II.A.1 Utah State University Eastern
Price Campus

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II.A.2 Boiler #1 - Kewanee Boiler
Maximum Rated Capacity: 16.76 MMBtu/hr
Fuel: Natural Gas
NSPS Applicability: Subpart Dc

II.A.3 Boiler #2 - Johnston Boiler
Maximum Rated Capacity: 20.9 MMBtu/hr
Fuel: Natural Gas
Control: Low-NOx Burner
NSPS Applicability: Subpart Dc

II.A.4 West Instructional Building Emergency Engine
Maximum Rated Capacity: 54 hp
Fuel: Diesel
MACT Applicability: Subpart ZZZZ

II.A.5 Student Center Emergency Engine
Maximum Rated Capacity: 80.5 hp
Fuel: Diesel
MACT Applicability: Subpart ZZZZ

II.A.6 Central Instructional Building Emergency Engine
Maximum Rated Capacity: 99 hp
Fuel: Diesel
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

II.A.7 Reeves Building Emergency Engine
Maximum Rated Capacity: 335 hp
Fuel: Diesel
MACT Applicability: Subpart ZZZZ

II.A.8 Miscellaneous Boilers and Heaters
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

Status: In Compliance. The listed equipment was observed during the inspection. No
unpermitted equipment was observed.

II.B Requirements and Limitations

II.B.1 Source-Wide Requirements.

II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Boilers - 10% opacity

B. Diesel-fired emergency generator engines - 20% opacity
C. All other points - 20% opacity

[R307-401-8]

II.B.1.a.1 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 of the permitted
equipment. Only steam was observed from the boilers and the emergency engines were not
operating.
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II.B.1.b The owner/operator shall only use natural gas as fuel in all boilers on site. [R307-401-8]

Status: In Compliance. Natural gas is the only fuel used for the boilers and provided by
Dominion Energy.

II.B.1.c The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.1.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

a. The date the emergency engine was used

b. The duration of operation in hours

c. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]

Status: In Compliance. Each emergency engine did not operate for more than 100 hours for
non-emergency usage for the rolling 12-month period ending in October 2023. A logbook
containing the date, duration, and reason for engine usage are stored in each housing unit.
The logs are digitally transferred to the main campus for recordkeeping. The usage logs for
2023 were viewed during the inspection. The 2022 usage logs are attached as an example of
how each engine is tracked.

II.B.1.c.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

Status: In Compliance. Each engine is equipped with a non-resettable hour meter. The
hour meters were viewed during the inspection.

II.B.1.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each emergency engine. [R307-401-8]

II.B.1.d.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.1.d.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

Status: In Compliance. The source only utilizes #1 ultra-low sulfur diesel (ULSD). This was
determined by the fuel purchase invoice provided by the supplier.

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.

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NSPS (Part 60) -Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam
Generating Units

Status: In Compliance. This requirement is satisfied through combustion of natural gas for the boilers.
Fuel is provided by Dominion Energy.

NSPS (Part 60) -IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. The applicable emergency engine (II.A.6) did not operate for more than 100
hours for the rolling 12-month period ending in October 2023. Usage logs are kept and include the date,
duration, and reason for usage. Annual maintenance is performed by a third-party vendor according to
manufacturer recommendations. A non-resettable hour meter is installed and operational.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. Each emergency engine did not operate for more than 100 hours for the rolling
12-month period ending in October 2023. Usage logs are kept and include the date, duration, and reason
for usage. Annual maintenance is performed by a third-party vendor according to manufacturer
recommendations. Non-resettable hour meters are installed and operational.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. A fuel purchase invoice provided by the fuel supplier indicated ULSD #1 is
utilized for the permitted equipment.

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. No fugitive emissions or dust were observed during the inspection. The area is
paved and landscaped.

Standards of Performance for New Stationary Sources [R307-210]

Status: In Compliance. This rule is satisfied by compliance with 40 CFR Part 60 Subpart IIII and
Subpart Dc. Refer to the Federal Requirements Section and Condition II.B.1.c for more details.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This rule is satisfied by compliance with 40 CFR Part 63 Subpart ZZZZ.
Refer to the Federal Requirements Section and Condition II.B.1.c for more details.

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EMISSION INVENTORY:

Listed before are the 2017 Actual Emissions Inventory provided from Utah State University Eastern -
Price. A comparison of the estimated total potential emissions (PTE) on Approval Order (AO)
DAQE-AN10102002-21, dated April 15, 2021, are listed below. The 2020 Emission Inventory values
were not properly submitted and not available for review. The source is working with emission inventory
personnel to resolve the issue. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 25177.00 N/A
Carbon Monoxide 30.46 1.48
Nitrogen Oxides 21.53 0.997
Particulate Matter - PM10 1.64 0.139
Particulate Matter - PM2.5 1.64 0.1
Sulfur Dioxide 0.12 0.018
Volatile Organic Compounds 1.22 0.107

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 32 N/A
Generic HAPs (CAS #GHAPS) 20 N/A
Hexane (CAS #110543) 752 N/A

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN10102002-21,
dated April 15, 2021: Out of Compliance. The source submitted
the 2020 Emission Inventory but did not provide all the
necessary information at the time of submission. Compliance
assistance was provided and the source is working to complete
the Emission Inventory. No action is recommended. Records
were current and provided during the site visit and after the
inspection via email.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the regular interval. Look for proper submission of the
2020 Emission Inventory. Notify source contact prior to travel as
the permitted equipment is spread across campus and locked for
security purposes.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, 2022 Emergency Engine Usage Logs
Date of Service:Hours Fuel Level Sulfur Content Notes, Service Done:
2/3/2022 207.4 X X Off for service
2/10/2022 207.4 X X Off for service
2/17/2022 207.4 X X Off for service
2/24/2022 207.4 X X Off for service
3/3/2022 207.4 X X Off for service
3/15/2022 207.4 X X Off for service
3/17/2022 207.4 X X Off for service
3/24/2022 207.4 X X Off for service
3/31/2022 207.4 X X Off for service
4/7/2022 208.6 X X Coolant Flushed 4/1/22
4/14/2022 209.2 X X
4/21/2022 209.5 X X
4/28/2022 209.8 X X
5/5/2022 214.9 X X Serviced/Power Outage
5/12/2022 215.3 X X
5/19/2022 215.7 X X
5/26/2022 216 X X
6/2/2022 216.4 X X
6/9/2022 216.7 X X
6/16/2022 217 X X
6/23/2022 217.4 X X
6/30/2022 217.7 X X
7/7/2022 218.1 X X
7/14/2022 218.4 X X
7/21/2022 218.7 X X
Utah State University Eastern
Building: Reeves
Note: Before starting the exercise check the battery voltage, coolant level, block heater operation, and inspect
belts. During the exercise check for any leaks, the voltage for charging system, the alignment of the pulley's and all
of the gages to verify that they are operating correctly. After shutdown check the oil level, fuel levels, and any signs
of leaks, and then collect the hours.
7/28/2022 226.7 X X Power Outage
8/4/2022 226.1 X X
8/11/2022 227.4 X X
8/18/2022 227.4 X X
8/25/2022 228.1 X X
9/1/2022 228.4 X X
9/8/2022 228.7 X X
9/15/2022 229.7 X X Power Outage
9/22/2022 230.1 X X
9/29/2022 230.4 X X
10/12/2022 231 X X Full Service/Blk heater/washed out radiator
11/30/2022 233.3 X X Started Monthly Checks
12/20/2022 234.1 X X