DAQ-2024-008085

DAQE-AN128150003-24

{{$d1 }}

Jeff Katter
Salt Lake City Corporation
451 South State Street
Salt Lake City, UT 84111
[e-mail]

Dear Mr. Katter:

Re: Approval Order: Minor Modification to Approval Order DAQE-AN128150002-22 to Update
Equipment
Project Number: N128150003

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
27, 2023. Salt Lake City Corporation must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Dungan Adams, 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. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA: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

April 29, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN128150003-24
Minor Modification to Approval Order
DAQE-AN128150002-22 to Update Equipment

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Salt Lake City Corporation - City/County Building Complex & Main City
Library

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality
April 29, 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 ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN128150003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Salt Lake City Corporation Salt Lake City Corporation - City/County
Building Complex & Main City Library

Mailing Address Physical Address
451 South State Street 450 South 200 East
Salt Lake City, UT 84111 Salt Lake City, UT 84111

Source Contact UTM Coordinates
Name: Jeff Katter 425,409 m Easting
Phone: [phone],512,367 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 9199 (General Government, NEC)

SOURCE INFORMATION
General Description
Salt Lake City Corporation (SLCC) is a government entity and the owner/operator of the combined
single-source main city library and office complex. The source contains two (2) 9,822,500 Btu/hr natural
gas boilers and one (1) 5,979,000 Btu/hr dual fuel (natural gas and #2 fuel oil) boiler. The source also
contains diesel-fired emergency generator engines that provide power to the complex when local utility
power is interrupted.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN128150003-24
Page 4

Project Description
SLCC has requested to replace the existing 500 kW and 278 kW diesel-fired emergency generators with
two (2) new 500 kW emergency generators and one (1) new 600 kW emergency generator.

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 63.65 13624.82
Carbon Monoxide 0.27 1.60
Nitrogen Oxides -0.77 3.27
Particulate Matter - PM10 -0.08 0.82
Particulate Matter - PM2.5 -0.08 0.82
Sulfur Dioxide 0 0.07
Volatile Organic Compounds -0.06 0.62

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 420
Change (TPY) Total (TPY)
Total HAPs 0 0.21

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-AN128150003-24
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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 City/County Office Complex & City Library Building

II.A.2 Two (2) 250 HP Boilers
Rated Input: 9.8 MMBtu/hr Each
Fuel: Natural Gas
Control: Low NOx Burner
Location: City Library Building

II.A.3 One (1) 150 HP Boiler
Rated Input: 6.0 MMBtu/hr
Fuels: Natural Gas, #2 Fuel Oil
Control: Low NOx Burner
Location: City Library Building

II.A.4 Two (2) Emergency Generators (New)
Electrical Output: 500 kW (670 hp)
Fuel: Diesel
Emission Standard: Tier III
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Location: City Library Building

II.A.5 One (1) Emergency Generator (New)
Electrical Output: 600 kW (804 hp)
Fuel: Diesel
Emission Standard: Tier II
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Location: City Library Building

DAQE-AN128150003-24
Page 6

II.A.6 One (1) Storage Tank
Capacity: 10,000 gallons
Service: Diesel
* for information purposes only

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Limitations
II.B.1.a The owner/operator shall use natural gas as a primary fuel and #1 or #2 grade fuel oil (diesel
fuel) as a backup fuel in the 150 HP boiler. [R307-401-8]

II.B.1.b The owner/operator shall not operate the 150 HP boiler for more than 48 hours per rolling
12-month total during periodic testing, maintenance, or operator training on liquid fuel. There is
no time limit on the use of liquid fuel in the 150 HP boiler during gas curtailment, gas supply
interruption, or startups. [R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log.

B. Record hours of operation and reason for operation on liquid fuel each day.

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months.

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

II.B.1.c The owner/operator shall not consume more than the following:

A. 25,350 gallons of diesel fuel (#1 or #2 grade fuel oil) per rolling 12-month
period.

B. 166,486,100 standard cubic feet of natural gas per rolling 12-month period.

[R307-401-8]

DAQE-AN128150003-24
Page 7

II.B.1.c.1 The owner/operator shall:

A. Determine consumption by examination of the individual fuel supplier billing
records.

B. Record consumption of natural gas and diesel fuel on a daily basis.

C. Use the records of natural gas and diesel fuel consumption to calculate a new
rolling 12-month total by the 20th day of each month using data from the
previous 12 months.

D. Keep consumption records for all periods the office/library complex is in
operation.

[R307-401-8]

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

A. Each boiler is fueled by natural gas - 10% opacity.

B. Each boiler fueled by diesel fuel - 20% opacity.

C. All diesel engines - 20% opacity.

D. All other points - 20% opacity.

[R307-401-8]

II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Method 9. [R307-201-3]

II.B.2 Emergency Engine Requirements
II.B.2.a 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.2.a.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.

D. Keep hours of operation records for all periods the plant is in operation.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.a.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]

II.B.2.b 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]

DAQE-AN128150003-24
Page 8

II.B.2.b.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.
[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.b.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]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN128150002-22 dated March 3, 2022
Is Derived From NOI dated October 27, 2023
Incorporates Additional Information dated February 14, 2024

DAQE-AN128150003-24
Page 9

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-IN128150003-24

March 21, 2024

Jeff Katter
Salt Lake City Corporation
451 South State Street
Salt Lake City, UT 84111
[e-mail]

Dear Mr. Katter:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN128150002-22 to Update
Equipment.
Project Number: N128150003

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Dungan Adams, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dungan Adams, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA: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

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN128150003-24
Minor Modification to Approval Order
DAQE-AN128150002-22 to Update Equipment

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Salt Lake City Corporation - City/County Building Complex & Main City
Library

Issued On
March 21, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

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
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN128150003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Salt Lake City Corporation Salt Lake City Corporation - City/County
Building Complex & Main City Library

Mailing Address Physical Address
451 South State Street 450 South 200 East
Salt Lake City, UT 84111 Salt Lake City, UT 84111

Source Contact UTM Coordinates
Name: Jeff Katter 425,409 m Easting
Phone: [phone],512,367 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 9199 (General Government, NEC)

SOURCE INFORMATION
General Description
Salt Lake City Corporation (SLCC) is a government entity and the owner/operator of the combined
single-source main city library and office complex. The source contains two (2) 9,822,500 Btu/hr natural
gas boilers and one (1) 5,979,000 Btu/hr dual fuel (natural gas and #2 fuel oil) boiler. The source also
contains diesel-fired emergency generator engines that provide power to the complex when local utility
power is interrupted.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-IN128150003-24
Page 4

Project Description
The source has requested to replace the existing 500 kW and 278 kW diesel-fired emergency generators
with two (2) new 500 kW emergency generators and one (1) new 600 kW emergency generator.

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 63.65 13624.82
Carbon Monoxide 0.27 1.60
Nitrogen Oxides -0.77 3.27
Particulate Matter - PM10 -0.08 0.82
Particulate Matter - PM2.5 -0.08 0.82
Sulfur Dioxide 0 0.07
Volatile Organic Compounds -0.06 0.62

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 420
Change (TPY) Total (TPY)
Total HAPs 0 0.21

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Salt Lake Tribune and Deseret News on March 24, 2024.
During the public comment period the proposal and the evaluation of its impact on air quality will be
available for the public to review and provide comment. If anyone so requests a public hearing within 15
days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as
close as practicable to the location of the source. Any comments received during the public comment
period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result
of the comments received.

DAQE-IN128150003-24
Page 5

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.

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

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.

II.A THE APPROVED EQUIPMENT

II.A.1 City/County Office Complex & City Library Building

DAQE-IN128150003-24
Page 6

II.A.2 Two (2) 250 HP Boilers
Rated Input: 9.8 MMBtu/hr Each
Fuel: Natural Gas
Control: Low NOx Burner
Location: City Library Building

II.A.3 One (1) 150 HP Boiler
Rated Input: 6.0 MMBtu/hr
Fuels: Natural Gas, #2 Fuel Oil
Control: Low NOx Burner
Location: City Library Building

II.A.4 Two (2) Emergency Generators (New)
Electrical Output: 500 kW (670 hp)
Fuel: Diesel
Emission Standard: Tier III
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Location: City Library Building

II.A.5 One (1) Emergency Generator (New)
Electrical Output: 600 kW (804 hp)
Fuel: Diesel
Emission Standard: Tier II
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Location: City Library Building

II.A.6 One (1) Storage Tank
Capacity: 10,000 gallons
Service: Diesel
* for information purposes only

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.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Limitations
II.B.1.a The owner/operator shall use natural gas as a primary fuel and #1 or #2 grade fuel oil (diesel
fuel) as a backup fuel in the 150 HP boiler. [R307-401-8]

II.B.1.b The owner/operator shall not operate the 150 HP boiler for more than 48 hours per rolling
12-month total during periodic testing, maintenance, or operator training on liquid fuel. There is
no time limit on the use of liquid fuel in the 150 HP boiler during gas curtailment, gas supply
interruption, or startups. [R307-401-8]

DAQE-IN128150003-24
Page 7

II.B.1.b.1 The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log.

B. Record hours of operation and reason for operation on liquid fuel each day.

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months.

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

II.B.1.c The owner/operator shall not consume more than the following:

A. 25,350 gallons of diesel fuel (#1 or #2 grade fuel oil) per rolling 12-month
period.

B. 166,486,100 standard cubic feet of natural gas per rolling 12-month period.

[R307-401-8]

II.B.1.c.1 The owner/operator shall:

A. Determine consumption by examination of the individual fuel supplier billing
records.

B. Record consumption of natural gas and diesel fuel on a daily basis.

C. Use the records of natural gas and diesel fuel consumption to calculate a new
rolling 12-month total by the 20th day of each month using data from the
previous 12 months.

D. Keep the consumption records for all periods the office/library complex is in
operation.

[R307-401-8]

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

A. Each boiler fueled by natural gas - 10% opacity.

B. Each boiler fueled by diesel fuel - 20% opacity.

C. All diesel engines - 20% opacity.

D. All other points - 20% opacity.

[R307-401-8]

II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Method 9. [R307-201-3]

DAQE-IN128150003-24
Page 8

II.B.2 Emergency Engine Requirements
II.B.2.a 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.2.a.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.

D. Keep hours of operation records for all periods the plant is in operation.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.a.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]

II.B.2.b 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.2.b.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.
[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.b.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]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN128150002-22 dated March 3, 2023
Is Derived From NOI dated October 27, 2023
Incorporates Additional Information dated February 14, 2024

DAQE-IN128150003-24
Page 9

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-NN128150003-24

March 21, 2024

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on March 24, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council
cc: Salt Lake County

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

DAQE-NN128150003-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Salt Lake City Corporation
Location: Salt Lake City Corporation - City/County Building Complex & Main City
Library – 450 South 200 East, Salt Lake City, UT
Project Description: Salt Lake City Corporation is a government entity and the owner/operator of the
combined single-source main city library and office complex. The source
contains two (2) 9,822,500 Btu/hr natural gas boilers and one (1) 5,979,000
Btu/hr dual fuel (natural gas and #2 fuel oil) boiler. The source has requested to
replace the existing 500 kW and 278 kW diesel-fired emergency generators with
two (2) new 500 kW emergency generators and one (1) new 600 kW emergency
generator. The emergency generator engines provide power to the complex when
local utility power is interrupted.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before April 23, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: March 24, 2024

{{#s=Sig_es_:signer1:signature}}

THANK YOU for your business.
This is your confirmation that your order has been changed. Below are the details of your transaction. Please save this
confirmation for your records.
Job Details
Order Number:
SLT0026694
Classification:
Other Notices
Package:
Legals
Order Cost:
$163.40
Referral Code:
DAQE-NN104350031-24
Account Details
TERRI WEISS
PO BOX 144820
SALT LAKE CITY, UT 84114
801-536-4000
[e-mail]
UTAH DIVISION OF AIR QUALITY
Schedule for ad number SLT00266940
Sat Mar 23, 2024
The Salt Lake Tribune E-Edition
All Zones
Sun Mar 24, 2024
The Salt Lake Tribune Legals
All Zones

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
DAQE-

RN128150003
March 12, 2024

Jeff Katter
Salt Lake City Corp.
451 South State Street
Salt Lake City, UT 84111
[e-mail]

Dear Jeff Katter,

Re: Engineer Review:
Minor Modification to DAQE-AN128150002-22 to Update Equipment.
Project Number: N128150003

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 permitting program. Salt Lake City Corp. should
complete this review within 10 business days of receipt.

Salt Lake City Corp. should contact Dungan Adams at [phone] if there are questions or concerns with the
review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams at
[e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an
ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any
comments and will prepare an Approval Order (AO) for signature by the DAQ Director.

If Salt Lake City Corp. does not respond to this letter within 10 business days, the project will move forward
without source concurrence. If Salt Lake City Corp. has concerns that cannot be resolved and the project becomes
stagnant, the DAQ Director may issue an Order prohibiting construction.

Approval Signature _________________________________3-15-24_____________________
(Signature & Date)

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

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

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N128150003
Owner Name Salt Lake City Corp.
Mailing Address 451 South State Street
Salt Lake City, UT, 84111

Source Name Salt Lake City Corp.- City/County Building Complex & Main
City Library
Source Location 450 South 200 East
Salt Lake City, UT 84111

UTM Projection 425,409 m Easting, 4,512,367 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 9199 (General Government, NEC)

Source Contact Jeff Katter
Phone Number [phone]
Email [e-mail]

Billing Contact Jeff Katter
Phone Number (801) 535 - 6428
Email [e-mail]

Project Engineer Dungan Adams, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted October 27, 2023
Date of Accepted Application November 6, 2023

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 2
SOURCE DESCRIPTION

General Description
Salt Lake City Corporation (SLCC) is a government entity and the owner/operator of the
combined single source main city library and office complex. The source contains two (2)
9,822,500 Btu/hr natural gas boilers and one (1) 5,979,000 Btu/hr dual fuel (natural gas and #2
fuel oil) boiler. The source also contains diesel-fired emergency generators engines that provide
power to the complex when local utility power is interrupted.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, and Salt Lake
County SO2 NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Proposal
Minor Modification to DAQE-AN128150002-22 to Update Equipment.

Project Description
The source has requested to replace the existing 500 kW and 278 kW diesel-fired emergency
generators with two (2) new 500 kW emergency generators and one (1) new 600 kW emergency
generator.

EMISSION IMPACT ANALYSIS
The emission increases resulting from the proposed modification do not exceed the threshold levels established
in R307-410-4 and R307-410-5. Therefore, modeling is not required. [Last updated February 16, 2024]

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 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 63.65 13624.82
Carbon Monoxide 0.27 1.60
Nitrogen Oxides -0.77 3.27
Particulate Matter - PM10 -0.08 0.82
Particulate Matter - PM2.5 -0.08 0.82
Sulfur Dioxide 0 0.07
Volatile Organic Compounds -0.06 0.62

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 420
Change (TPY) Total (TPY)
Total HAPs 0 0.21

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding New Emergency Engines
The proposed 600 kW emergency engine will result in an emission increase of 0.42 tpy of NOx,
0.23 tpy of CO, and small amounts of PM10, PM2.5, VOCs, SO2, and HAPs (<0.03 tpy, each). The
proposed 500 kW emergency engine will each result in an emission increase of 0.22 tpy of NOx,
0.19 tpy of CO, and small amounts of PM10, PM2.5, VOCs, SO2, and HAPs (<0.03 tpy, each).

One way of reducing overall engine emissions is to install newer equipment that meets EPA's
tiered emission standards. 40 CFR Part 1039, Appendix I requires nonroad compression-ignition
engines manufactured after 2006 and greater than 560 kW to meet Tier II standards. It requires
nonroad compression-ignition engines manufactured after 2006 and between 130 kW and 560 kW
to meet Tier III standards.

The source has indicated that it is purchasing new emergency stationary diesel engines subject to
40 CFR 60 Subpart IIII. The source has therefore elected to install two (2) Tier III 500 kW engines
manufactured after 2006. Tier III certification limits emissions for NOx, CO, and PM. Due to the
inconsistent and low volume of air pollutants emitted from each engine during testing and
maintenance, the cost to install 500 kW HP Tier IV engines is considered cost prohibitive. For the
same reason, additional add-on controls such as use of an SCR (selective catalytic reduction) or
DOC (diesel oxidation catalyst) system to control PM10, PM2.5, VOCs, and HAPs are cost
prohibitive.

The source has also elected to install a Tier II 600 kW engine manufactured after 2006. Tier II
certification limits emissions for NOx, CO, and PM. For the same reasons listed above, the cost to
replace the Tier II engine with a Tier IV engine or install additional add-on control technologies is
considered cost prohibitive. Tier III standards do not exist for the 600 kW size unit.

Each engine will not exceed 100 hours of operation per year for maintenance and testing purposes.
The potential to emits are based on 100 hours of emergency use per engine.

Therefore, BACT to control emissions from the new emergency generator engines is maintaining a
Tier III certification for each 500 kW engine and a Tier II certificate for the 600 kW engine.
Additionally, the source will operate and maintain the engine in accordance with manufacturer
recommendations. BACT is also ensuring each engine does not exceed 100 hours of operation per
rolling 12-month period for maintenance checks and readiness testing.

Sulfur dioxide emissions occur from the reaction of various sulfur compounds in diesel fuel. Sulfur
in diesel fuel oxidizes during combustion to SO2 and sulfur trioxide (SO3). In the presence of water
vapor, these hydrolyze to H2SO4. The source will use ultra-low sulfur diesel fuel containing no
more than 15 parts per million by weight of sulfur which is considered BACT. BACT is also
maintaining visible emissions from each engine at or below 20% opacity.
[Last updated March 11, 2024]

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 5
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]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 6
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 City/County Office Complex & City Library Building

II.A.2 Two (2) 250 HP Boilers
Rated Input: 9.8 MMBtu/hr Each
Fuel: Natural Gas
Control: Low NOx Burner
Location: City Library Building

II.A.3 One (1) 150 HP Boiler
Rated Input: 6.0 MMBtu/hr
Fuels: Natural Gas, #2 Fuel Oil
Control: Low NOx Burner
Location: City Library Building

II.A.4 Two (2) Emergency Generators (New)
Electrical Output: 500 kW (670 hp)
Fuel: Diesel
Emission Standard: Tier III
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Location: City Library Building

II.A.5 One (1) Emergency Generator (New)
Electrical Output: 600 kW (804 hp)
Fuel: Diesel
Emission Standard: Tier II
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Location: City Library Building

II.A.6 One (1) Storage Tank
Capacity: 10,000 gallons
Service: Diesel
* for information purposes only

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 7
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 Limitations
II.B.1.a The owner/operator shall use natural gas as a primary fuel and #1 or #2 grade fuel oil (diesel
fuel) as a backup fuel in the 150 HP boiler. [R307-401-8]

II.B.1.b
NEW
The owner/operator shall not operate the 150 HP boiler for more than 48 hours per rolling 12-
month total during periodic testing, maintenance, or operator training on liquid fuel. There is
no time limit on the use of liquid fuel in the 150 HP boiler during gas curtailment, gas supply
interruption, or startups. [R307-401-8]

II.B.1.b.1
NEW
The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log

B. Record hours of operation and reason for operation on liquid fuel each day

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

II.B.1.c
NEW
The owner/operator shall not consume more than the following:

A. 25,350 gallons of diesel fuel (#1 or #2 grade fuel oil) per rolling 12-month period

B. 166,486,100 standard cubic feet of natural gas per rolling 12-month period. [R307-
401-8]

II.B.1.c.1
NEW
The owner/operator shall:

A. Determine consumption by examination of the individual fuel supplier billing records

B. Record consumption of natural gas and diesel fuel on a daily basis

C. Use the records of natural gas and diesel fuel consumption to calculate a new rolling
12-month total by the 20th day of each month using data from the previous 12 months

D. Keep the consumption records for all periods the office/library complex is in
operation. [R307-401-8]

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 8
II.B.1.d
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Each boiler fueled by natural gas - 10% opacity

B. Each boiler fueled by diesel fuel - 20% opacity

C. All diesel engines - 20% opacity

D. All other points - 20% opacity. [R307-401-8]

II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted in accordance
with 40 CFR 60, Method 9. [R307-201-3]

II.B.2 Emergency Engine Requirements
II.B.2.a 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.2.a.1
NEW
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

D. Keep hours of operation records for all periods the plant is in operation. [40 CFR 63
Subpart ZZZZ, R307-401-8]

II.B.2.a.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]

II.B.2.b 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.2.b.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. [40 CFR 63 Subpart ZZZZ,
R307-401-8]

II.B.2.b.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]

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 9
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Is Derived From NOI dated October 27, 2023
Supersedes DAQE-AN128150002-22 dated March 3, 2023
Incorporates Additional Information dated February 14, 2024

REVIEWER COMMENTS

1. Comment regarding Small Source Exemption Status:
This source is eligible for a Small Source Exemption (SSE) under UAC R307-401-9. The source is
anticipating modifying the facility and increasing emission rates within several years. To ease this
future process, the source wants to have an Approval Order. [Last updated March 11, 2024]

2. Comment regarding Federal Subpart Applicability:
Boilers
40 CFR 60 Subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units) does not apply as all three (3) boilers have a maximum design heat input of
less than 10 MMBtu/hr.

40 CFR Part 63 Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers Area Sources) does not apply to the two (2) 250 HP
boilers as they run only on natural gas. The one (1) 150 HP boiler is a dual-fuel boiler, however
periodic testing, maintenance, or operator training on liquid fuel shall not exceed a combined total of
48 hours during any calendar year. Therefore, the 150 HP boiler runs primarily on natural gas and 40
CFR Part 63 Subpart JJJJJJ does not apply to this facility.

Emergency Generators
40 CFR 60 Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines) and 40 CFR 63 (National Emissions Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion Engines) apply to the source as all three engines
are manufactured after April 1, 2006.

40 CFR 63 MACT Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines) is applicable to owners/operators of
stationary RICE at a major or area sources of HAP emissions. The provisions of MACT Subpart
ZZZZ are applicable to the three (3) emergency engines on site. Therefore, MACT Subpart ZZZZ
applies to this facility. [Last updated March 12, 2024]

3. 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 Sources
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.

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 10

This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR
61 (NESHAP) regulations. The facility is subject to 40 CFR 60 (NSPS) Subpart IIII and 40 CFR 63
(MACT) Subpart ZZZZ. Both NSPS Subpart IIII and MACT Subpart ZZZZ each exempt sources
from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not
otherwise required by law to obtain a permit. Therefore, Title V does not apply to this facility as per
R307-415-4(2)(c).
[Last updated February 16, 2024]

Engineer Review N128150003: Salt Lake City Corp.- City/County Building Complex & Main City Library
March 12, 2024
Page 11
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

2/16/24, 4:56 PM State of Utah Mail - Minor Modification for SLC Corporation's City/County/Library Complex
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8479949568453359618&simpl=msg-a:r439974117594654…1/4
Dungan Adams <[e-mail]>
Minor Modification for SLC Corporation's City/County/Library Complex
8 messages
Dungan Adams <[e-mail]>Wed, Nov 8, 2023 at 11:38 AM
To: [e-mail]
Cc: [e-mail]
Hi Amit,
I am reviewing the NOI for Salt Lake City Corporation's Minor Modification to DAQE-AN128150002-22. I am requesting
some additional information regarding BACT determination.
1. You have provided cost-effectiveness evaluation for Tier II and Tier IV engines. Please provide the same evaluation for
Tier II and Tier III engines.
2. I believe the 500 kW engines are required to be Tier III according to NSPS Subpart IIII (40 CFR part 1039, Appendix I,
Table 3). However, I could be making an incorrect assumption based on engine specifications. Please justify why Tier III is
not required for the 500 kW emergency generators.
3. Lastly, please provide more information (emissions standards, model year, etc.) for the three engines that you will be
using. This can be a manufacturer specification sheet or an EPA certification.
Let me know if you have any questions.
Thanks,
Dungan
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
Amit Nair <[e-mail]>Thu, Nov 16, 2023 at 2:32 PM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Hi Dungan
Thanks for your email. Jeff and I are working on sourcing information for the items you have listed. We will respond asap.
Regards
Amit
2/16/24, 4:56 PM State of Utah Mail - Minor Modification for SLC Corporation's City/County/Library Complex
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8479949568453359618&simpl=msg-a:r439974117594654…2/4

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 8, 2023 11:39 AM
To: Amit Nair <[e-mail]>
Cc: [e-mail]
Subject: Minor Modification for SLC Corporation's City/County/Library Complex

External Email
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Jan 2, 2024 at 7:30 AM
To: Amit Nair <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Hi Amit,
Happy new year. I wanted to reach out to ask about the status of the additional information I requested for Salt Lake City
Corporation's NOI. Please provide an update when you get the chance.
Thanks,
Dungan
[Quoted text hidden]
Amit Nair <[e-mail]>Wed, Jan 10, 2024 at 7:33 AM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Hello Dungan
Happy new year to you too. We have gathered updated equipment information and are finalizing a response to your
request for additional information. We hope to have it your way next week. Thanks for your patience.
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Jan 10, 2024 at 10:47 AM
To: Amit Nair <[e-mail]>
Amit,
I appreciate the update. Thank you.
Best,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Feb 6, 2024 at 11:28 AM
To: Amit Nair <[e-mail]>
Hi Amit,
It's been several weeks since you suggested the additional information would be sent to me and about three months since
my initial request. I would like to receive the additional BACT information by the end of February. Please let me know if
you have any concerns with this.
Thanks,
Dungan
2/16/24, 4:56 PM State of Utah Mail - Minor Modification for SLC Corporation's City/County/Library Complex
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8479949568453359618&simpl=msg-a:r439974117594654…3/4
[Quoted text hidden]
Amit Nair <[e-mail]>Wed, Feb 14, 2024 at 5:43 PM
To: Dungan Adams <[e-mail]>
Cc: "Katter, Jeffrey" <[e-mail]>
Dungan,
Thanks for your patience.
See below in red for our responses. Also attached are revised emission and BACT calculations.
Please review and let me know if you have any additional questions.
Thanks
Amit

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 8, 2023 11:39 AM
To: Amit Nair <[e-mail]>
Cc: [e-mail]
Subject: Minor Modification for SLC Corporation's City/County/Library Complex

External Email
Hi Amit,

I am reviewing the NOI for Salt Lake City Corporation's Minor Modification to DAQE-AN128150002-22. I am requesting
some additional information regarding BACT determination.

1. You have provided cost-effectiveness evaluation for Tier II and Tier IV engines. Please provide the same evaluation for
Tier II and Tier III engines.
We are now providing updated cost-effectiveness evaluations for Tier III (vs. Tier IV) engines. Please note that this is only
being provided for the 500 kW units since no Tier III standards exist for the 600 kW size unit. Please refer to new Table D-
4 which documents the cost-effectiveness evaluation for a Tier III vs a Tier IV for the 500 kW sized units. Our analysis
shows that it is not cost-effective to need a Tier IV engine for 500 kW size units.
We have also revised the engine and facility-wide emission calcs using Tier III emission factors instead of the previously
used Tier II ones for the 500 kW units. No changes to emissions from the Tier II 600 kW units.

2. I believe the 500 kW engines are required to be Tier III according to NSPS Subpart IIII (40 CFR part 1039, Appendix I,
Table 3). However, I could be making an incorrect assumption based on engine specifications. Please justify why Tier III is
not required for the 500 kW emergency generators.
You are correct about the requirement. SLC Corp. will require the contractors to bid for a Tier III spec for the 500 kW units.
The 600 kW unit will still remain at a Tier II level.

3. Lastly, please provide more information (emissions standards, model year, etc.) for the three engines that you will be
using. This can be a manufacturer specification sheet or an EPA certification.
These units have not yet been ordered or purchased by SLC Corp. The procurement process involves requiring bidders to
propose specs and costs followed by selection of contractor/ vendor for the units. Only after the contractor/ vendor wins
the bid will they usually nail down specifics like model year, serial number etc. Manufacturer/ EPA spec sheets may also
2/16/24, 4:56 PM State of Utah Mail - Minor Modification for SLC Corporation's City/County/Library Complex
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8479949568453359618&simpl=msg-a:r439974117594654…4/4
only be available at that stage.
We can assume that since these will be new units that the winning bidders will have to purchase, the model year could be
2022 or later.
[Quoted text hidden]
SLC23L159447_R1_SLCCorpNOI_Revised Tables 02-13-24.pdf
515K
Dungan Adams <[e-mail]>Fri, Feb 16, 2024 at 1:35 PM
To: Amit Nair <[e-mail]>
Amit,
Thanks for sending this over. I'll let you know if I have any questions in the next few days.
Thanks,
Dungan
[Quoted text hidden]
10/30/23, 11:04 AM State of Utah Mail - Fwd: NOI Application Submittal - SLC Corporation 10-27-23
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1780932441939401292&simpl=msg-f:17809324419394012…1/4
Dungan Adams <[e-mail]>
Fwd: NOI Application Submittal - SLC Corporation 10-27-23
2 messages
Alan Humpherys <[e-mail]>Fri, Oct 27, 2023 at 11:58 AM
To: Dungan Adams <[e-mail]>
Dungan,
Can you please process this NOI?
Site ID: 12815
Peer: Christine
Thanks,
Alan
---------- Forwarded message ---------
From: Amit Nair <[e-mail]>
Date: Fri, Oct 27, 2023 at 11:01 AM
Subject: NOI Application Submittal - SLC Corporation 10-27-23
To: Alan Humpherys <[e-mail]>
Cc: Katter, Jeffrey <[e-mail]>
Hello Alan
Please find attached an NOI application from SLC Corporation to modify its current AO for the central heating plant at the
Main Library and City and County Building in Salt Lake City. Please let me or Jeff (cc’d) know if you have any questions
on this NOI. Looking forward to working with the permit engineer this gets assigned to.
Thanks,
Amit

From: Alan Humpherys <[e-mail]>
Sent: Thursday, March 30, 2023 7:24 AM
To: Amit Nair <[e-mail]>
Cc: Katter, Jeffrey <[e-mail]>
Subject: Re: Meeting availability

External Email
Amit,

Unfortunately if any pollutant increases, even a 0.0006 tpy increase, the source does not qualify for
R307-401-12. Please let me know what questions you have.

Thanks,
10/30/23, 11:04 AM State of Utah Mail - Fwd: NOI Application Submittal - SLC Corporation 10-27-23
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1780932441939401292&simpl=msg-f:17809324419394012…2/4
Alan

On Wed, Mar 29, 2023 at 4:16 PM Amit Nair <[e-mail]> wrote:
Alan
I am following up from the voicemail I left you a couple of days ago regarding applying R307-401-12 for Salt Lake City
Corp’s proposed changes in emergency generators at the SL City/ County Building complex. With a reduction in
emergency generator hours, the criteria pollutants emissions decrease, but the HAPs do not decrease at the same rate
(HAPs are size dependent and we also use same AP-42 factors for both the outgoing and incoming new units). The
change in HAPs at 90 hrs/yr are +0.0006 tpy – can we consider that as essentially zero and therefore R307-401-12 (1)
(a) applies?
Thanks
Amit

From: Alan Humpherys <[e-mail]>
Sent: Tuesday, February 21, 2023 5:08 PM
To: Amit Nair <[e-mail]>
Cc: Katter, Jeffrey <[e-mail]>
Subject: Re: Meeting availability

External Email
Amit,

I am available either Wednesday afternoon or Thursday afternoon this week. Please let me know
what works best for you.

Thanks,
Alan

On Tue, Feb 21, 2023 at 12:53 PM Amit Nair <[e-mail]> wrote:
Hi Alan
How is your availability for a call to discuss permitting options for Salt Lake City Corporation (AO attached)?
Thanks
Amit
Amit Nair
Principal Professional
849 West Levoy Drive Suite 200
Salt Lake City, Utah 84123
o| 801.261.3336
10/30/23, 11:04 AM State of Utah Mail - Fwd: NOI Application Submittal - SLC Corporation 10-27-23
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1780932441939401292&simpl=msg-f:17809324419394012…3/4
d| 801.713.2842
m| 801.891.9648

--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
10/30/23, 11:04 AM State of Utah Mail - Fwd: NOI Application Submittal - SLC Corporation 10-27-23
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1780932441939401292&simpl=msg-f:17809324419394012…4/4
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
(SLC23L159447)-SLC Corporation NOI Application 10-27-23.pdf
2508K
Alan Humpherys <[e-mail]>Fri, Oct 27, 2023 at 11:59 AM
To: Amit Nair <[e-mail]>
Cc: "Katter, Jeffrey" <[e-mail]>, Dungan Adams <[e-mail]>
Amit,
We've received the application, and I've assigned it to Dungan Adams. If you have any questions, you can ask Dungan.
Thanks,
Alan
[Quoted text hidden]

20233327.001A/SLC23L159447 Page 1 of 4 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com

KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336

October 25, 2023
Kleinfelder Project No.: 20233327.001A

Mr. Alan Humpherys
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116

SUBJECT: Approval Order Notice of Intent (NOI) Modification
Salt Lake City Corporation
451 South State Street
Salt Lake City, UT 84111

Dear Mr. Humpherys:

On behalf of Salt Lake City Corporation (SLC Corp.), Kleinfelder, Inc. (Kleinfelder) is submitting a Notice of
Intent (NOI) application to the Utah Division of Air Quality (UDAQ) for a permit modification to update
the current Approval Order (AO# DAQE-AN12815002-22), for the central heating plant located at the
address above in Salt Lake City, Utah. This NOI application is based on discussions during the pre-NOI
meeting with Mr. Alan Humpherys on February 23, 2023. A completed UDAQ Form 2 is provided as
Attachment A. This NOI proposes the replacement of two existing diesel-fired emergency generators
with three new diesel-fired emergency generators. While the proposed facility-wide emission totals will
remain below small source exemption thresholds of 5 tons per year (tpy) under Utah Air Rules
R307-401-9, SLC Corp. is still seeking an Approval Order.

BACKGROUND AND PROPOSED MODIFICATIONS

The Facilities Division of SLC Corp.’s Public Services Department operates and maintains the central
plant that supplies electrical power, steam, and chilled water to City Hall, Main City Library and The
Leonardo buildings, herein collectively referred to as ‘the Complex’ or facility. Existing natural gas boilers
provide heat and diesel-fired generators provide emergency power to the buildings and facilities within
the Complex.

SLC Corp. is currently working on a new project to update the electrical feed systems to all three
buildings in the Complex. As part of this project, SLC Corp. plans to replace the existing permitted
diesel-fired emergency generators (listed in Conditions II.A.4 and II.A.5 of the current AO) with two new
(2) 500 kilowatt (kW) and one new (1) 600 kW diesel-fired emergency generators. Site map showing
proposed equipment locations is included as Attachment B. There will be no other changes to
equipment or permitted processes at this time. The Complex is located in Salt Lake County, which is
designated as a National Ambient Air Quality Standards (NAAQS) non-attainment area for PM2.5, SO2,
and O3.

20233327.001A/SLC23L159447 Page 2 of 4 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com

KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336
PROPOSED EMISSION CHANGES

The purpose of the generators is to provide emergency power in case of main-line power failure. All of
the proposed emergency generators will be new and EPA-certified to meet at least Tier II emission
standards, as required by 40 Code of Federal Regulations (CFR) 60.4202(a)(2), based on their size. The
existing two generator units will be disconnected from the network and removed from operation. SLC
Corp. anticipates minimal use of these three new emergency generators in addition to the requirements
for routine maintenance and testing; however, as a conservative estimate, emission calculations
presented in this NOI are based on 100 hours of operations annually for each of these generators.
Detailed emission calculations for criteria pollutants, HAPs and GHGs are provided in Attachment C of
this NOI. A summary of total emission changes due to the proposed addition of the three new
generators and removal of existing two generators is included in Table 1 below. The proposed
equipment modifications detailed above will result in an overall decrease in VOC, NOx, and PM
emissions and a small increase in CO, SO2, HAPs and CO2e emissions from the facility.

Table 1
Summary of Facility Wide Proposed Emissions (in tpy)
Source VOC NOx CO PM10 PM2.5 SO2 HAPs CO2e
Existing/ Outgoing
Emergency Generators 0.13 1.63 0.35 0.12 0.12 0.001 4.91E-04 60.96
Proposed New
Emergency
Generators1
0.08 1.13 0.62 0.04 0.04 0.001 1.13E-03 124.62
Proposed Net Project
Change -0.06 -0.50 0.27 -0.08 -0.08 0.001 0.0006 63.65
Current Facility-wide
Emission Totals2 0.68 4.04 1.33 0.90 0.90 0.07 0.21 13561.17
Proposed Facility-wide
Emission Totals 0.62 3.54 1.60 0.82 0.82 0.07 0.21 13624.82

Detailed emission calculations and a summary of emissions by source type are provided in
Attachment C.

REGULATORY APPLICABILITY

Based on the proposed changes to equipment at the facility, the facility will remain a minor source for
criteria pollutants and an area source for HAPs (emit less than 10 tpy of a HAP or less than 25 tpy of
combined HAPs). The current operations will largely remain unchanged and existing air regulations, as
currently permitted, still apply. SLC Corp.’s review is limited to evaluating state and federal regulations’
applicability to this NOI.

All three of the proposed diesel-fired emergency generator engines are new and will be EPA certified to
meet at least Tier II standards, as required, based on their size. Since all proposed generators will be
expected to be manufactured after April 1, 2006, the following federal regulations apply:

• New Source Performance Standards (NSPS) Subpart IIII: Compression Ignition Internal
Combustion Engines; and
20233327.001A/SLC23L159447 Page 3 of 4 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com

KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336
• National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart ZZZZ: (Institutional)
Stationary Reciprocating Internal Combustion Engines.

BEST AVAILABLE CONTROL TECHNOLOGY (BACT)

Although qualifying as an exempt small source under R307-401-9, SLC Corp. has evaluated equipment
and emission control technology associated with the proposed equipment by considering energy,
environmental, and economic impacts, and other costs.

BACT for proposed, new diesel emergency generators

The three proposed engines are expected to be certified as at least Tier II, as prescribed by 40 CFR
60.4202(a)(2), based on their size. Since the proposed new generators will have operations limited to
emergency situations and to produce power to critical networks or equipment, they qualify as
emergency engines per EPA’s definition in 40 CFR 60 Subpart IIII (Section 4219).

For the diesel-fired emergency generators, the following is proposed as BACT:

1. Good combustion practices (GCP);
2. Use of clean-burning fuels;
3. Restricted operating hours (<100 hours per year, per generator); and
4. Use of Tier II certified engines (as required by 40 CFR 60.4202(a)(2) based on generator size).

SLC Corp. will ensure proper maintenance and operation of the proposed Tier II emergency generators,
restrict operating hours, and use ULSD fuel with a sulfur concentration of 15 ppm or less as BACT to
control PM2.5, NOX, SO2, CO and VOC emissions.

A quantitative evaluation of the cost-effectiveness (for NOx) of using Tier IV engines vs. the proposed
Tier II engines is included in Attachment D. As shown in Tables D-2 and D-3, the cost per ton of NOX
removed is greater than $88,000. This cost effectiveness price is not considered reasonable by SLC
Corp.; therefore, replacement of the proposed Tier II generators with Tier IV certified units is considered
economically infeasible for BACT.

EMISSION OFFSETS

Since the facility is not a major source and this project is not considered a major modification, the facility
is not subject to ozone offset requirements under R307-420-1. The combined emissions increase of
PM10, SO2, and NOX attributable to the proposed modifications at the facility is less than the 25 tpy
threshold; therefore, the requirement under R307-421-5 to obtain PM10 emission reduction credits
(ERCs) prior to initiating construction does not apply.

AMBIENT AIR QUALITY ANALYSIS

Ambient air quality modeling is required in attainment areas if emissions from the proposed AO exceed
the emission thresholds listed in UAC R307-410-4. The facility building is located in Salt Lake County,
which is a non-attainment area for ozone, PM2.5 and SO2. The emissions associated with this
NOI application do not exceed any of the applicable thresholds listed in R307-410-4.

20233327.001A/SLC23L159447 Page 4 of 4 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com
KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336
LIMITATIONS
This work was performed in a manner consistent with that level of care and skill ordinarily exercised by
other members of Kleinfelder’s profession practicing in the same locality, under similar conditions and at
the date the services are provided. Our conclusions, opinions, and recommendations are based on a
limited number of observations and data provided by SLC Corp. It is possible that conditions could vary
between or beyond the data evaluated. Kleinfelder makes no other representation, guarantee, or
warranty, express or implied, regarding the services, communication (oral or written), report, opinion,
or instrument of service provided.
CLOSURE
Kleinfelder prepared this NOI application based on our understanding of the future needs of SLC Corp.,
and in accordance with the standard of care in Utah at the time of this submittal. If you have any
questions that need to be addressed directly by SLC Corp., please contact Jeff Katter at 801.535.6428. If
you have any questions for Kleinfelder, please contact Amit Nair at 801.261.3336.
Respectfully Submitted,
KLEINFELDER, INC.
Amit Nair
Principal Air Quality Professional
ATTACHMENTS
A UDAQ NOI Form 2
B Site Map
C Emission Calculation Spreadsheets
D BACT Analysis – NOx Reduction Cost Effectiveness
At
t
a
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m
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t

A
20233327.001A/SLC23L159447 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com
KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336
ATTACHMENT A
UDAQ NOI FORM 2
1of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: Ƒ Initial Approval Order Ƒ Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2. Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email:_______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3. Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4. Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5. The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7. If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8. Brief (50 words or less) description of process.
Electronic NOI
9. A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal Ƒ %RWK
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:[phone]
Email:[e-mail]>
Date:
October 17, 2023
✔
Salt Lake Corporation
451 South State
Salt Lake City, UT 84111
Jeff Katter
[phone]
[e-mail]
Salt Lake
40.759
-111.884
9199
AN128150002-22 3 3 22
SLCC is requesting to replace two existing emergency generators (500kW & 278kW) that have
reached the end of their life cycle. The old generators will be replaced with two new 500kW and one
new 600kW generator. The new units will meet Tier II emissions standards.
✔
Energy/Utilities Coordinator
Katter,
Jeffrey
Digitally signed by Katter,
Jeffrey
Date: 2023.10.19
14:20:06 -06'00'
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20233327.001A/SLC23L159447 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com

KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336
ATTACHMENT B

SITE MAP

!(
#*
#*
UNIVERSITY BOULEVARD
500 S
S 200 E
S 300 E
SOUTH STATE STREET
Existing 500 kW Generatorto be removed
Existing 278 kW Generatorto be removed
New Equipment Location
Existing 10,000-gallonUnderground Storage Tank
SITE MAP
SALT LAKE CITY CORPORATION451 SOUTH STATE STREETSALT LAKE CITY, UT
PROJECT:FIGURE
1DRAWN:
DRAWN BY:
CHECKED BY:
Source: Esri, Maxar, Earthstar Geographics, and theGIS User Community; ESRI World Imagery,Salt LakeCounty image date 10/15/2021.
FILE NAME:StateSt_F1.mxd
Explanation
#*Equipment To Be RemovedNew Equipment Location
!(Existing Underground Storage Tank
20233327
OCT 2023
K. HAGAN
C. BEGALKE
10/18/2023 10:05:34 AM, KHagan
\\azrgisstorp03\GIS_Projects\Client\SaltLakeCity_Corporation\20233327.04\StateSt_F1.mxd
The information included on this graphic representation has been compiledfrom a variety of sources and is subject to change without notice. Kleinfeldermakes no representations or warranties, express or implied, as to accuracy,completeness, tim eliness, or rights to the use of such information. Thisdocument is not intended for use as a land survey product nor is it designed orintended as a construction design docum ent. The use or m isuse of theinformation contained on this graphic representation is at the sole risk of theparty using or misusing the inform ation.
£0 75 150
Feet
Locations are Approximate
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20233327.001A/SLC23L159447 October 25, 2023
© 2023 Kleinfelder www.kleinfelder.com

KLEINFELDER 849 West Levoy Drive, Suite 200, Salt Lake City, UT 84123 p | 801.261.3336
ATTACHMENT C

EMISSION CALCULATION SPREADSHEETS

Salt Lake City Corporation
Table C-1: Emission Calculations Summary
Project Emission Totals Summary
VOC NOx CO
PM10 PM2.5 PM2.7 HAPs CO2
tpy tpy tpy tpy tpy tpy tpy
Existing/ Outgoing Emergency Generators 0.13 1.63 0.35 0.12 0.12 0.001 4.91E-04 60.96
Proposed New Emergency Generators1 0.08 1.13 0.62 0.04 0.04 0.001 1.13E-03 124.62
Proposed Net Project Change -0.06 -0.50 0.27 -0.08 -0.08 0.001 0.0006 63.65
Current Facility-wide Emission Totals2 0.68 4.04 1.33 0.90 0.90 0.07 0.21 13561.17
Proposed Facility-wide Emission Totals 0.62 3.54 1.60 0.82 0.82 0.07 0.21 13624.82
1. Proposed New Emergency Generators will be diesel-fired and will meet at least EPA Tier 2 emission standards
2. Current Emission Totals from AO DAQE-AN12815002-22, dated March 3, 2022
Source
20233327.001A/SLC23L159447 1 of 1 October 25, 2023
Salt Lake City Corporation
Table C-2: Emergency Diesel Generators Emission Calculations
Emission Unit Generator Set
Make
Generator Set
Power (kW)
Generator Set
Power (hp)
Hours of Operation
(annually)
Total
hp-hrs
Existing/ Outgoing Emergency Generator 1 / City Library Building Cummins 278 373 100 37,280
Existing/ Outgoing Emergency Generator 2 / City/County Office
Building Cummins 508 681 100 68,057
TOTAL: 786 1,053 200 105,337
Emission Unit
Proposed Facility-
wide Emission
Totals
Generator Set
Power (kW)
Generator Set
Power (hp)
Hours of Operation
(annually)
Total
hp-hrs
NEW Emergency Generator 1 / City Library Building TBD 600 805 100 80,461
NEW Emergency Generator 2 / City Library Building TBD 500 671 100 67,051
NEW Emergency Generator 3 / City Library Building TBD 500 671 100 67,051
TOTAL: 1,600 2,146 300 214,564
Emission Unit VOC NOx CO PM10 PM2.5 SO2 Units Reference
Existing/ Outgoing Emergency Generator 1 / City Library Building 2.51E-03 0.031 6.68E-03 2.20E-03 2.20E-03 1.21E-05 lb/hp-hr
Existing/ Outgoing Emergency Generator 2 / City/County Office
Building 2.51E-03 0.031 6.68E-03 2.20E-03 2.20E-03 1.21E-05 lb/hp-hr
NEW Emergency Generator 1 / City Library Building 7.05E-04 0.0105 5.75E-03 3.29E-04 3.29E-04 1.21E-05 lb/hp-hr
NEW Emergency Generator 2 / City Library Building 7.05E-04 0.0105 5.75E-03 3.29E-04 3.29E-04 1.21E-05 lb/hp-hr
NEW Emergency Generator 3 / City Library Building 7.05E-04 0.0105 5.75E-03 3.29E-04 3.29E-04 1.21E-05 lb/hp-hr
VOC NOx CO PM10 PM2.5 SO2
(lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
Existing/ Outgoing Emergency Generator 1 / City Library Building 0.94 11.56 2.49 0.82 0.82 4.52E-03
Existing/ Outgoing Emergency Generator 2 / City/County Office
Building 1.71 21.10 4.55 1.50 1.50 8.26E-03
TOTAL: 2.65 32.65 7.04 2.32 2.32 0.01
VOC NOx CO PM10 PM2.5 SO2
(tpy) (tpy) (tpy) (tpy) (tpy) (tpy)
Existing/ Outgoing Emergency Generator 1 / City Library Building 0.05 0.58 0.12 0.04 0.04 2.26E-04
Existing/ Outgoing Emergency Generator 2 / City/County Office
Building 0.09 1.05 0.23 0.07 0.07 4.13E-04
TOTAL: 0.132 1.633 0.35 0.12 0.116 0.001
Existing/ Outgoing On-Site Emergency Power (Diesel)
Proposed New On-Site Emergency Power (Diesel)
Engine Emission Factors
Existing/ Outgoing Generators Hourly Emissions2
Emission Unit
Emission Unit
Existing/ Outgoing Generators Annual Emissions3
EPA Tier 2 nonroad diesel emission
standards for NOx, CO, and PM; AP-42
Table 3.4-1 for VOC, SO2 emission
factors
AP-42 Table 3.3-1
(See Table Note 1 for SO2)
20233327.001A/SLC23L159447 1 of 2 October 25, 2023
VOC NOx CO PM10 PM2.5 SO2
(lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
NEW Emergency Generator 1 / City Library Building 0.57 8.47 4.63 0.26 0.26 0.01
NEW Emergency Generator 2 / City Library Building 0.47 7.05 3.86 0.22 0.22 0.01
NEW Emergency Generator 3 / City Library Building 0.47 7.05 3.86 0.22 0.22 0.01
TOTAL: 1.51 22.58 12.35 0.71 0.71 0.03
VOC NOx CO PM10 PM2.5 SO2
(tpy) (tpy) (tpy) (tpy) (tpy) (tpy)
NEW Emergency Generator 1 / City Library Building 0.028 0.42 0.23 0.013 0.013 4.88E-04
NEW Emergency Generator 2 / City Library Building 0.024 0.35 0.19 0.011 0.011 4.07E-04
NEW Emergency Generator 3 / City Library Building 0.024 0.35 0.19 0.011 0.011 4.07E-04
TOTAL: 0.076 1.129 0.617 0.035 0.035 0.001
All Generators Hourly and Annual HAP Emissions
Hourly Emissions 2 Annual Emissions 3 Hourly Emissions 2 Annual
Emissions 3
Hourly
Emissions 2
Annual Emissions
3
Hourly
Emissions 2
Annual
Emissions 3
Hourly
Emissions 2
Annual
Emissions 3
(lb/MMBtu)(lb/hp-hr) 6 (lb/MMBtu)(lb/hp-hr) 6 (lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy)
Acetaldehyde 75-07-0 7.76E-04 5.43E-06 2.52E-05 1.76E-07 2.03E-03 1.01E-04 1.20E-04 6.00E-06 1.42E-04 7.10E-06 1.18E-04 5.91E-06 1.18E-04 5.91E-06
Acrolein 107-02-8 9.25E-05 6.48E-07 7.88E-06 5.52E-08 2.41E-04 1.21E-05 3.75E-05 1.88E-06 4.44E-05 2.22E-06 3.70E-05 1.85E-06 3.70E-05 1.85E-06
Benzene 71-43-2 9.33E-04 6.53E-06 7.76E-04 5.43E-06 2.43E-03 1.22E-04 3.70E-03 1.85E-04 4.37E-03 2.19E-04 3.64E-03 1.82E-04 3.64E-03 1.82E-04
Formaldehyde 50-00-0 1.18E-03 8.26E-06 7.89E-05 5.52E-07 3.08E-03 1.54E-04 3.76E-04 1.88E-05 4.44E-04 2.22E-05 3.70E-04 1.85E-05 3.70E-04 1.85E-05
Naphthalene 91-20-3 8.48E-05 5.94E-07 1.30E-04 9.10E-07 2.21E-04 1.11E-05 6.19E-04 3.10E-05 7.32E-04 3.66E-05 6.10E-04 3.05E-05 6.10E-04 3.05E-05
Toluene 108-88-3 4.09E-04 2.86E-06 2.81E-04 1.97E-06 1.07E-03 5.34E-05 1.34E-03 6.69E-05 1.58E-03 7.91E-05 1.32E-03 6.59E-05 1.32E-03 6.59E-05
Xylene (Total) 1330-20-7 2.85E-04 2.00E-06 1.93E-04 1.35E-06 7.44E-04 3.72E-05 9.19E-04 4.60E-05 1.09E-03 5.44E-05 9.06E-04 4.53E-05 9.06E-04 4.53E-05
TOTAL: 9.81E-03 4.91E-04 7.11E-03 3.55E-04 8.40E-03 4.20E-04 7.00E-03 3.50E-04 7.00E-03 3.50E-04
NOTES:
The emission factor for SOx = 0.0089 x S, where S = sulfur content of the fuel (% by weight) = 0.0015 %
3. Annual Emissions (tpy) = Emission Factor (lb/hr-hr) x Generator Rating (hp) x Annual Operating Hours (hrs) x 1 ton/2000 lbs
6. Emission factors converted from lb/MMBTU to lb/hp-hr based on 7,000 BTU/hp-hr; AP-42, Table 3.3-1 & Table 3.4-1, notes "a" & "e" respectively.
New Emergency Generator 3 /
City Library Building 5
5. Emission factors for HAPs pollutants were obtained from AP-42 5th Ed, Section 3.4, Table 3.4-3 and 3.4-4 dated October 1996.
4. Emission factors for HAPs pollutants were obtained from AP-42 5th Ed, Section 3.4, Table 3.3-2 dated October 1996.
Emission Unit
2. Hourly Emissions (lb/hr) = Emission Factor (lb/hp-hr) x Generator Rating (hp)
CAS NumberHazardous Air Pollutant
AP-42 Table 3.3-2 Emission Factors
1. The SOX emission factors was calculated based on AP-42 5th Ed, Section 3.4, Table 3.4-1 dated October 1996. Emission factors were converted from g/hp-hr to lb/hp-hr based on 453.592 grams per pound.
Existing Emergency Generator 1 / City Library
Building 4
AP-42 Tables 3.4-3 and 3.4-4 Emission
Factors
Existing Emergency Generator 2 / City/County Office
Building 5
New Emergency Generator 1 / City
Library Building 5
New Emergency Generator 2 /
City Library Building 5
New Generators Hourly Emissions2
Emission Unit
New Generators Annual Emissions3
20233327.001A/SLC23L159447 2 of 2 October 25, 2023
Salt Lake City Corporation
Table C-3: Emergency Diesel Generators Greenhouse Gas (GHG) Emission Calculations
Global Warming Potentials
CO2 CH4 N2O
1 25 298
Generator Emission Factors
(Hp) (Annually)(lb/hp-hr)(lb/hp-hr)
Existing/ Outgoing Emergency Generator 1 / City Library Building 373 100 1.15 N/A
Existing/ Outgoing Emergency Generator 2 / City/County Office
Building 681 100 1.16 6.35E-05
NEW Emergency Generator 1 / City Library Building 805 100 1.16 6.35E-05
NEW Emergency Generator 2 / City Library Building 671 100 1.16 6.35E-05
NEW Emergency Generator 3 / City Library Building 671 100 1.16 6.35E-05
Generator Emission Factors
Hourly 3 Hourly 3
(lbs/hr)(TPY) (tonnes/yr)(lbs/hr)(TPY) (tonnes/yr) (TPY) (tonnes/yr)
Existing/ Outgoing Emergency Generator 1 / City Library Building 428.72 21.44 19.45 N/A N/A N/A 21.44 19.45
Existing/ Outgoing Emergency Generator 2 / City/County Office
Building 789.46 39.47 35.81 1.08 0.05 0.05 39.53 35.86
NEW Emergency Generator 1 / City Library Building 933.35 46.67 42.34 1.28 0.06 0.06 46.73 42.39
NEW Emergency Generator 2 / City Library Building 777.79 38.89 35.28 1.06 0.05 0.05 38.94 35.33
NEW Emergency Generator 3 / City Library Building 777.79 38.89 35.28 1.06 0.05 0.05 38.94 35.33
NOTES:
1. GWPs obtained from 40 CFR Part 98 Subpart A, Table A-1
3. Hourly Emissions (lb/hr) = Emission Factor (lb/hp-hr) x Generator Rating (hp)
4. Annual Emissions (tpy) = Hourly emissions (lb/hr) x hours of operation (hrs/yr) / 2000 lbs/ton
5. Annual Emissions (CO2e metric tonnes/year) = CO2 Emissions (tpy) x 0.907185 (tonnes/US ton).
Conversion to metric tonnes:
1 US ton = 0.907185 metric tonne
2. For generators > 600 hp, methane (CH4) emission factor was obtained TOC emission factor (using Note f) from AP-42 5th Ed, Section 3.4, Table 3.4-1, dated October 1996.
2. For generators > 600 hp, the greenhouse gas (CO2) emission factor was obtained from AP-42 5th Ed, Section 3.4, Table 3.4-1, dated October 1996. For generators < 600 hp, the CO2 emission factor was
obtained from AP-42, 5th Ed, Section 3.3, Table 3.3-1, dated October 1996.
Emission Unit
Global Warming Potential (GWP)1
Rating Hours of
Operation
Emission Unit
CO2 Emission
Factor2
CH4 Emission
Factor3
Total CO2e EmissionsCO2 Emissions
Annual 4,5
CO2e Emissions (as CH4)
Annual 4,5
20233327.001A/SLC23L159447 1 of 1 October 25, 2023
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20233327.001A/SLC23L159447 October 25, 2023
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ATTACHMENT D
BACT ANALYSIS
NOX COST EFFECTIVENESS EVALUATION