DAQ-2024-004889

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DAQC-CI117510001-24
Site ID 11751 (B1)

MEMORANDUM

TO: FILE – SALT LAKE COMMUNITY COLLEGE – South City Campus

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: January 25, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: December 14, 2023

SOURCE LOCATION: 1575 South State Street
Salt Lake City, UT 84115
DIRECTIONS: Boiler room is in southeast corner of campus. Check there for
inspection contact.

SOURCE CONTACTS: Sherie Thornton, Manager
801-957-4902 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Salt Lake Community College South City Campus has three fire
tube duel fuel boilers. Boilers are fired by natural gas unless
there is a curtailment of service, during which #2 fuel oil can be
used as a back-up fuel. Boiler one is the primary boiler used,
operating on natural gas. Boiler two is a natural gas standby
boiler for high demand days. Boiler three is set to burn oil during
curtailment. The boilers are used to heat water under pressure to
make steam that provides heat and hot water to the buildings on
campus. The boilers each have a separate exhaust stack which
extends through the roof. They are equipped with monitors that
control operations. No heat is supplied to any source off campus.
The emergency generators are only used for maintenance,
testing, and during episodes of power outage.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN117510003-17, dated February
3, 2017
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:

Salt Lake Community College
South City Campus

4600 South Redwood Road 1575 South State Street
Taylorsville, UT 84130 Salt Lake City, UT 84115

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

Section I: GENERAL PROVISIONS

I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.2 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.3 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.4 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.5 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

I.7 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]

Status: Out of Compliance. Equipment modifications have occurred since the previous
inspection. See Section II for more information. No limits set forth in this AO appear to
have been exceeded. 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.

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Section II: SPECIAL PROVISIONS

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

II.A.1 SLCC South Campus

SLCC operates a heating plant for comfort heating equipment.

II.A.2 Three (3) Dual Fuel Boilers

Fuel: Natural Gas or #2 Diesel
Boiler #1
Rating: 20.9 MMBtu/hr

NSPS Applicability: 40 CFR 60 NSPS Dc

Boiler #2
Rating: 20.9 MMBtu/hr

NSPS Applicability: 40 CFR 60 NSPS Dc

Boiler #3
Rating: 6.3 MMBtu/hr

II.A.3 Two (2) Emergency Engines
Fuel: #2 Diesel
301 South City Main Building
Rating: 450 kW
Manufactured: 2011
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ

302 South City Facilities Annex
Rating: 125 kW
Manufactured: March 2006
MACT Applicability: 40 CFR 63 Subpart ZZZZ

II.A.4 Underground Storage Tank
30,000 Gallon Underground Storage Tank for #2 Diesel Fuel

Status: Not in Compliance. Boilers 1 and 2 in Condition II.A.2 have been replaced with
duel-fueled boilers that have an input rating of 5,022,000 Btu/hr. The source
submitted required information to Minor NSR, and an Administrative Amendment
is currently in peer review. No action is recommended at this time.

The South City Main Building engine is rated at 605 hp. The South City Facilities
Annex Building engine is rated at 167 hp.

II.B Requirements and Limitations

II.B.1 Limitations and Testing Requirements

II.B.1.a Visible emissions from on-site equipment shall not exceed:

A. Boiler -10%
B. Emergency Engines - 20%
C. All other Sources - 20%. [R307-201, R307-401-8]

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II.B.1.a.1 Opacity observations of emissions from stationary sources shall be in accordance with 40 CFR
60, Appendix A, Method 9. [R307-201]

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.2 Fuels

II.B.4 Emergency Engines

II.B.2.a The sulfur content of diesel fuels shall not exceed 15 ppm by weight. [40 CFR 60 Subpart IIII,
R307-401-8]

II.B.4.a The owner/operator shall only use emergency engines for maintenance and readiness testing or
during periods of electric power interruption from the public utilities. [R307-401-8]

Status: In Compliance. Emergency engines were only used for maintenance and readiness
testing as required.

II.B.2.a.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of fuel oil and diesel fuel shall be either by the owner/operator's own
testing or by test reports from the fuel oil or diesel fuel marketer. [R307-203-1]

Status: In Compliance. The last time SLCC South City campus purchased fuel was in 2017
and it was ULSD. See the attached invoice. They stated that they plan to purchase fuel
again this year.

II.B.3 Dual Fuel Fired Boilers

II.B.4.b The owner/operator shall operate and maintain all engines according to the manufacturer's
specifications. [R307-401-8]

Status: In Compliance. The engines are maintained according to manufacturer's
specifications as required.

II.B.3.a The boilers shall operate using natural gas as a primary fuel and #2-diesel fuel oil as a backup
fuel during periods of gas curtailment, gas supply interruption, startups, or for periodic testing,
maintenance, or operator training on liquid fuel. [R307-401-8]

Status: In Compliance. Only natural gas and diesel are used as fuels in the boilers.

II.B.4.c Each emergency engine shall be limited to 100 hours of operation for maintenance and testing
during a 12-month rolling period. There is no time limit on the use of emergency engines during
emergencies. [R307-401-8]

II.B.4.c.1 Records documenting engine usage shall be kept in a log and include; the date the engine was
used, the duration, in hours, of each engine's usage and, the reason for each engine's usage.
[R307-401-8]

Status: In Compliance. Records are maintained as required. For the rolling 12-month
period from November 2022 - October 2023:

The South City Standby Generator was used for 37.1 hours
The South Annex Standby Generator was used for 28.4 hours

II.B.3.b Boiler periodic testing, maintenance, and operator training on liquid fuels will not exceed a
combined total of 48 hours per rolling 12-month period. [R307-401-8]

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II.B.3.b.1 Records documenting diesel fuel usage in the boilers shall be kept in a log and include the date
the boiler was used; the duration, in hours, of each boiler usage and; the reason for each boilers
usage. [R307-401-8]

Status: In Compliance. Records are maintained as required. For the rolling 12-month
period from November 2022 - October 2023:

Boiler 1 used diesel fuel for 21 hours.
Boiler 2 used diesel fuel for 0 hours.
Boiler 3 used diesel fuel for 0 hours.

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.

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

Status: Not in Compliance. The three dual-fueled boilers only use ULSD and natural gas. Records of
use for both fuels are maintained as required by this subpart. The source is also required to submit
semi-annual reports summarizing diesel usage for those six months. Compliance assistance was
provided to submit an initial report for July – December 2023, and the source was instructed to continue
to submit these reports in the future. See the attached report below. No further action is recommended
at this time.

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

Status: In Compliance. Compliance with this subpart is satisfied by installing a certified engine,
maintaining and operating the engines in accordance with the manufacturer's instructions, installation
of a non-resettable hour meter, and maintaining records of use. All information provided at the time of
inspection indicate the engine manufactured in 2011 is being properly maintained and operated in
accordance with this subpart.

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

Status: In Compliance. This subpart applies to both emergency engines. Each engine was used for less
than 100 hours for maintenance and other non-emergency purposes. Maintenance occurs per
manufacturer recommendations, and the non-resettable hour meter is checked weekly. Only low-sulfur
diesel is used in all of the generators.

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. The last time SLCC South City campus purchased fuel was in 2017 and it
was ULSD. See the attached invoice. They stated that they plan to purchase fuel again this year.

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

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirements NSPS (Part 60) Subparts Dc and IIII. See Section III above for more information.

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

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subpart ZZZZ. See Section III above for more information.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Salt Lake Community College- South
City Campus for the 2020 emissions year. A comparison of the estimated total potential emissions (PTE)
on AO: DAQE-AN117510003-17, dated February 3, 2017, is provided. PTE are supplied for
supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 29035.01 N/A
Carbon Monoxide 17.50 5.67318
Nitrogen Oxides 11.26 7.07709
Particulate Matter - PM10 3.89 0.5115
Particulate Matter - PM2.5 3.89 0.51128
Sulfur Dioxide 0.39 0.04054
Volatile Organic Compounds 1.18 0.37869

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 40 N/A
Hexane (CAS #110543) 740 N/A

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN117510003-17,
dated February 3, 2017: Not in compliance at the time of
inspection. The source has submitted all required paperwork for
an Administrative Amendment which is currently under peer
review. See the attached correspondence with the source
engineer. The source also was instructed to submit semi-annual
reports of diesel usage in the boilers according to NSPS (Part 60)
Subpart Dc. No compliance action is recommended at this time.

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HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at normal frequency for this type of source.

NSR RECOMMENDATIONS: Finish and issue AA modifying Boilers 1 and 2.

ATTACHMENTS: VEO form, fuel invoices, correspondence with source engineer
Sinclair Wyoming Refining Company⦁Laboratory Services⦁Sinclair, WY Certificate of Analysis, Pioneer Pipeline #2 Diesel Fuel
Transferor:Sinclair Wyoming Refining Company100 E. Lincoln Highway ⦁ PO Box 277Sinclair, WY 82334EPA Company ID: 4624, Facility ID: 82453
Transferee:ConocoPhillipsPioneer Pipeline600 N. Dairy Ashford RoadHouston, TX 77079-1175EPA Company ID: 4528, Facility ID: 82245
CoA Date:9/25/2017
Tender:
Sample Date:9/25/2017
Tank Number:Tank 508
Sampler(s):L. Roman
Tester(s): Brent Brugger, Courtney Portz

Available BBLS:
Approved By: Date:
#2 Diesel 15ppm w/w Sulfur Motor Vehicle Diesel Fuel.
15ppm w/w Sulfur (maximum) Undyed Ultra-Low Sulfur #2 Diesel Fuel. For use in all diesel vehicles and engines. This
product may contain Tolad 3030 and Tolad 3232D.
SPECIFICATIONSTestMETHODRESULT
MINIMUM MAXIMUM
Gravity, API @ 60°F ASTM D4052 37.4 30.0
Flash Point (PMCC), °F ASTM D93 148 135
Haze @ 70°F ASTM D4176, Proc. 2 1 2
Bright & Clear ASTM D4176 Pass PASS
Color ASTM D1500 0.5 2.5
Ash, wt%ASTM D482 <0.001 0.010
Distillation @ 760mmHg, °F ASTM D86
IBP 340.1 REPORT
10 vol.% Recovered 399.2 REPORT
50 vol.% Recovered 495.4 REPORT
90 vol.% Recovered 614.8 540.0 640.0
FBP 661.0 REPORT
% Total Recovered 99.5 REPORT
% Residue 1.4 REPORT
BS&W, vol%ASTM D2709 0.025 0.050
Sulfur, ppm ASTM D7039 8.3 10.0
Copper Strip Corrosion, 3hr @ 212°F ASTM D130 1a 1b
CR, Ramsbottom, wt%ASTM D524 0.05 0.35
Thermal Stability, Y Filter ASTM D6468 99.5 82.0
Cetane Index, 4V ASTM D4737, Proc. A 49.0 40.0
Cloud Point, °F ASTM D5773 2.2 6.0
Pour Point, °F ASTM D5949 -15 -15.0
Viscosity @ 104°F, cSt ASTM D445 2.470 1.900 3.400
NACE Rust Test, Rating TM0172-2001 A B+
1/17/24, 10:53 AM State of Utah Mail - 11751 Administrative Amendment
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-5327460642618218350&simpl=msg-a:r-5692848364883…1/2
Daniel Riddle <[e-mail]>
11751 Administrative Amendment
4 messages
Daniel Riddle <[e-mail]>Wed, Dec 20, 2023 at 10:23 AM
To: Jacob Ries <[e-mail]>
Cc: Chad Gilgen <[e-mail]>, Jon Black <[e-mail]>
Jake,
I inspected 11751 - SLCC south campus last Thursday and I saw that their boilers were replaced in 2021, but their AO is from 2020. In the NOI status
it says their application is being reviewed. According to them, this one would just be an administrative amendment since the 2 new boilers are a
reduction in emissions from the old boilers. Do you have any updates on the status of their updated AO?
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Daniel Riddle <[e-mail]>Mon, Jan 8, 2024 at 10:49 AM
To: Jacob Ries <[e-mail]>
Cc: Chad Gilgen <[e-mail]>, Jon Black <[e-mail]>
Jake - any updates on the progress of this new AO? The source has provided me with correspondence showing the submittal of their NOI - the
source sent me some emails from September 2021 saying that they had spoken with you and the Administrative amendment was in progress at that
time.
[Quoted text hidden]
Jacob Ries <[e-mail]>Tue, Jan 9, 2024 at 7:30 AM
To: Daniel Riddle <[e-mail]>
Cc: Chad Gilgen <[e-mail]>, Jon Black <[e-mail]>
Hi Daniel,
Hope the holidays were great for you! Sorry for not responding sooner.
The AA is currently in peer review so it should be issued soon. I have the 12279 Jordan Campus also moving forward with it, so they will be issued at
the same time.
Please let me know if you have any questions.
Thank you,
[Quoted text hidden]
--
Jake Ries
Environmental Engineer | Major NSR Section
P: [phone]
airquality.utah.gov
Daniel Riddle <[e-mail]>Tue, Jan 9, 2024 at 10:46 AM
To: Jacob Ries <[e-mail]>
Cc: Chad Gilgen <[e-mail]>, Jon Black <[e-mail]>
1/17/24, 10:53 AM State of Utah Mail - 11751 Administrative Amendment
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-5327460642618218350&simpl=msg-a:r-5692848364883…2/2
Thank you for letting me know. Sounds good.
[Quoted text hidden]
Daniel Riddle
Minor Source Compliance Section
Utah Division of Air Quality
P.O. Box 144820
Salt Lake City Utah 84114-4820

The New Source Performance Standards for Small Industrial-Commercial-Institutional Steam
Generating Units (NSPS Boilers) 40 CFR 60 Subpart Dc requires reporting on the quantity of fuel.
other than natural gas combusted during the reporting period for Salt Lake Community College – South
City Campus – UDAQ Site ID 11751.

[7/01/2023-12/31/2023]

[0 gallons of diesel fuel used]

[Was included in the previous email.]

In accordance with Utah Administrative Code R307-415-5d and based on information
and belief formed after reasonable inquiry, I certify that the statements and information in this
document are true, accurate, and complete.

X
Sherie Thornton
EVHS Manager