DAQ-2024-007972

1
DAQC-443-24
Site ID 10364 (B1)

MEMORANDUM

TO: FILE – GRANITE SCHOOL DISTRICT – Cottonwood High School

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: March 7, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: January 3, 2024 and April 4, 2024

SOURCE LOCATION: 5715 South 1300 East, Salt Lake City

SOURCE CONTACTS: Tim Hutchins, Head Custodian: 801-230-7544,
[e-mail]

Adam Sanderson, Assistant Custodian: 801-809-8941
[e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: The Granite School District operates five Weil-McClain 5M
Btu/hr natural gas fired boilers to provide steam, comfort heat,
and hot water for the school and to heat the swimming pool. One
of the five boilers serves as backup. There is a 347 hp Caterpillar
diesel emergency generator which provides electricity during
power outages. There is a paint booth equipped with fabric filters
in the wood shop. All the exhaust air from the paint booth is
routed through two dust collectors before being vented to the
atmosphere.

APPLICABLE REGULATIONS: AO DAQE-066-02, dated January 22, 2002

40 CFR Part 63 Subpart ZZZZ—National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines

40 CFR Part 63 Subpart JJJJJJ—National Emission Standards for
Hazardous Air Pollutants for Industrial, Commercial, and
Institutional Boilers Area Sources

/ :
2
SOURCE EVALUATION:

1. This AO applies to the following company:

Site Office Corporate Office Location
Cottonwood High School Granite School District
5715 South 1300 East 340 East 3545 South
Salt Lake City, Utah 84121 Salt Lake City, Utah 84115

Phone Number: [phone] [phone]
Fax Number: [phone] [phone]

The equipment listed in this AO shall be operated at the following location:

PLANT LOCATION:

5715 South 1300 East, Salt Lake City, Salt Lake County, Utah

Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27
4,449.7 km. Northing, 427.8 km. Easting, Zone 12

Status: In Compliance. The “corporate” office phone number is now [phone]
and the address is 2500 South State Street, Salt Lake City, Utah 84115. All other
information is correct.

2. All definitions, terms, abbreviations, and references used in this AO conform to those used in
the Utah Administrative Code (UAC) Rule 307 (R307), and Title 40 of the Code of Federal
Regulations (40 CFR). Unless noted otherwise, references cited in these AO conditions refer
to those rules.

Status: This is not a compliance issue.

3. The limits set forth in this AO shall not be exceeded without prior approval in accordance
with R307-401.

Status: In Compliance. Based on the records reviewed, the Granite School District
did not exceed the limits set forth in this AO.

4. Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be approved in accordance with R307-401-1.

Status: In Compliance. The Granite School District indicated that there were no
modifications to the equipment or the processes approved by this AO.

5. All records referenced in this AO which are required to be kept by the owner/operator, shall
be made available to the Executive Secretary or Executive Secretary’s representative upon
request, and the records shall include the two-year period prior to the date of the request.
Records shall be kept for the following minimum periods:

All other records Two years

Status: In Compliance. The Granite School District indicated that the records are
kept for at least two years.
3
6. Granite School District shall operate the five dual fuel boilers, each rated at 5 x 106 Btu/hr
and one 347 bhp diesel fired generator in accordance with the terms and conditions of this
AO, which was written pursuant to Granite School District’s Notice of Intent (NOI)
submitted to the Division of Air Quality (DAQ) on August 23, 2001, and additional
information submitted to the DAQ on November 16, 2001.

Status: In Compliance. The Granite School District indicated that all approved
boilers and generators were operated according to this AO Condition.

7. The approved installations shall consist of the following equipment or equivalent*:

A. Five (5) Boilers with the following characteristics each:
Fuel Type: Natural Gas with Diesel as a back-up
Type of Burner: 70 ppm NOx
Heating Capacity: 5.0 x 106 Btu/hr

B. One (1) Emergency Generator
Fuel Type: Diesel
Rating: 347 bhp

* Equivalency shall be determined by the Executive Secretary.

Status: In Compliance. There were no new and unapproved equipment identified
onsite. The five 5.124 MMBtu Weil-McClain boilers only use natural gas. See the
boiler information in the attachment.

8. Granite School District shall notify the Executive Secretary in writing when the installation
of the equipment listed in Condition #7 has been completed and is operational, as an initial
compliance inspection is required. To insure proper credit when notifying the Executive
Secretary, send your correspondence to the Executive Secretary, attn: Compliance Section.

Status: Out of Compliance. According to DAQC-541-17, the equipment was
installed and operational before notifying the DAQ. This AO was issued to include
the unapproved equipment in this AO. No further action required.

9. Visible emissions from the following emission points shall not exceed the following values:

A. All boilers when with natural gas fired - 10% opacity
B. All diesel engines and boilers when fired with diesel fuel - 20% opacity

Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9.

Status: In Compliance. There were no visible emissions observed from the Boilers or
the Emergency Generator. The opacity observations were conducted according to
40 CFR 60, Appendix A, Method 9. See the attachment for additional information.

4
10. The following hours of operation and consumption limits shall not be exceeded:

A. 109 x 106 standard cubic feet of natural gas per year (all boilers combined) per
rolling 12-month period

B. Operation (including periods for testing/maintenance) shall not exceed 500 hours
per boiler per rolling 12-month period when operated on the diesel fuel #2

To determine compliance with a rolling 12-month total the owner/operator shall calculate
a new 12-month total by the twentieth day of each month using data from the previous 12
months. Records of consumption and hours of operation shall be kept for all periods
when the plant is in operation. Consumption shall be determined by monthly billings.
Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log.

Status: In Compliance. The natural gas consumption from December 2022-
November 2023, indicated the following:

A. 50,469,949 standard cubic feet - See the attachment for additional information.
B. The Granite School District indicated that diesel is not used as fuel in the boilers.

See the natural gas specification on the plate of boiler in the attachment.

11. Emergency generators shall be used for electricity producing operation only during the
periods when electric power from the public utilities is interrupted, or maintenance of the
generators. Records documenting generator usage shall be kept in a log and they shall show
the date the generator was used, the duration in hours of the of generator usage, and the
reason for each generator usage.

Status: In compliance. The Granite School District indicated that the emergency
generator runs weekly for 30 minutes, and it is only used during power outages and
testing purposes. Records of Weekly Generator Run times from January to
December 2023, indicated 21.0 hours.

12. The owner/operator shall use only natural gas as a primary fuel and #2 diesel fuel oil as a
backup fuel in the four boilers. The owner/operator shall use only #2 fuel oil in the
emergency generator.

Status: In Compliance. Only natural gas is used as a primary fuel in the five boilers.
Only #2 fuel oil is used in the emergency generator.

13. The sulfur content of diesel fuel oil burned shall not exceed:

0.5 percent by weight

The sulfur content shall be determined by ASTM Method D-4294-89 or approved
equivalent. Certification of fuel oil shall be either by Granite School District’s own
testing or test reports from the fuel oil fuel marketer.

Status: In Compliance. According to the Certificate of Analysis from Sinclair, the
sulfur content of the diesel indicated 6.3 parts per million ( ppm). See the
attachment for additional information.

5
14. 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 Executive Secretary 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,
and the records shall be maintained for a period of two years.

Status: In Compliance. The Granite School District maintains all maintenance
records performed on approved equipment for at least two years.

15. The owner/operator shall comply with R307-107 (Attachment A). General Requirements:
Unavoidable Breakdowns.

Status: In Compliance. The Granite School District indicated that there have been
no unavoidable breakdowns resulting in an emissions event.

APPLICABLE FEDERAL RULES

40 CFR Part 63 Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Status: In Compliance. The Granite School District operates a 1991, 347 hp diesel-fueled
Caterpillar emergency generator weekly for 30 minutes for testing and maintenance purposes.
Records reviewed of Generator Run times from January-December 2023, indicated 21.0 hours.
According to the Certificate of Analysis from Sinclair, the sulfur content of the diesel indicated 6.3
parts per million ( ppm). See the attachment for additional information.

40 CFR Part 60 Subpart Dc—Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units

Status. Not Applicable. The Granite School District operates five 5.124 MMBtu/hr natural gasfired
boilers to provide steam, comfort heat, and hot water for the school and to heat the swimming
pool. One of the five boilers serves as backup. Only boilers equal to or greater than 10 MMBtu are
subject to this rule. The rolling 12-month natural consumption from December 2022, to November
2023, indicated 50,482 decatherms. See the attachment for additional information.

40 CFR Part 63 Subpart JJJJJJ—National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers Area Sources

Status: Not applicable: All the boilers are natural gas-fueled, and therefore, not applicable to this
subpart. See the attachment for additional information.

6
AREA SOURCE RULES

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

Status: In Compliance. There were no visible emissions observed from the boilers and the
emergency generator during this inspection.

R307-343 Wood Furniture Manufacturing Operations

Status: In Compliance. The Granite School District operates a paint booth equipped with fabric
filters at the wood shop. All the exhaust air from the paint booth is routed through two dust
collectors before being vented to the atmosphere. The Granite School District uses the Variseal HS
Pre-Cat Clear Sealer and the Vanicure Low Gloss coatings which are hand-rubbed on the wood
furniture or sprayed from a can. See the SDSs in the attachments.

EMISSION INVENTORY:

Not applicable. The Granite School District is not required to submit an Emissions Inventory
Report at this time.

The calculated PTE emissions for this AO in tons/year include the following: PM10: 0.83, NOx: 9.60,
SO2: 3.70, CO: 1.38, and VOC: 1.29

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement action in the last five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance. Based on the records reviewed, Granite School
District is in compliance with the requirements of AO
DAQE-066-02 dated January 22, 2002. The source maintained
good housekeeping practices.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual.

RECOMMENDATION FOR
NSR PERMITTING REVIEW: Consider updating the boiler ratings to 5.124 MMBtu/hr.

Consider removing 40 CFR Part 60 Subpart Dc applicability for
the boilers based on the size.

Consider removing 40 CFR Part 63 Subpart JJJJJJ applicability
for the boilers based on the sole usage of natural gas.

Consider including the paint booth in the wood furniture shop.

Consider including the two dust collectors that are tied to the
wood furniture shop.

ATTACHMENTS: Visible Emission Observation Form, Natural Gas Consumption
Log, Fuel Certification, SDSs, Photos