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Home My WebLink AboutDAQ-2024-0048591 DAQC-CI126340001-24 Site ID 12634 (B1) MEMORANDUM TO: FILE – INTERMOUNTAIN HEALTHCARE – Central Laundry Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: January 10, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County INSPECTION DATE: December 20, 2023 SOURCE LOCATION: 1180 West 2600 South Woods Cross, UT 84087 SOURCE CONTACTS: Matt Saunders, Maintenance Manager 801-298-2661 matt.saunders@imail.org OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Intermountain Central Laundry is a commercial laundry service that caters to all IHC hospitals and numerous medical clinics in northern Utah. Soiled garments and beddings are washed with a water-based detergent. Washed items are dried in natural gas fired dryers, pressed using steam, folded in the folding machine, then returned to the different hospitals and clinics. There are two natural gas fired boilers that supply the hot water for washing the items and the steam for pressing. Each boiler is 16.8 million BTU/hr and subject to NSPS Subpart Dc. There are 12 natural gas-fueled dryers. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN126340002-19, dated January 29, 2019. NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 0 0 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Intermountain Healthcare - Central Laundry Facility 36 South State Street 1180 West 2600 South Salt Lake City, UT 84111 Woods Cross, UT 84087 SIC Code: 3582: (Commercial Laundry, Drycleaning, & Pressing Machines) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process. Regular maintenance is conducted and tracked with a PM schedule. No reportable breakdowns have occurred since the previous inspection. Emission inventories are not required by this source at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Central Laundry Facility II.A.2 Two (2) Steam Boilers Max Rating: 16.8 MMBtu/hr (each) Fuel: Natural gas NSPS/MACT applicability: 40 CFR 60 Subpart Dc 3 II.A.3 Various dryers less than 5 MMBtu/hr each Fuel: Natural gas II.A.4 One (1) Emergency Generator Engine (new) Max Engine Rating: 95 kW (128 HP) Fuel: Diesel Model Year: 2002 NSPS/MACT applicability: 40 CFR 63 Subpart ZZZZ Status: In Compliance. The equipment observed on site was consistent with that listed. II.B Requirements and Limitations II.B.1 Site-Wide Requirement II.B.1.a The owner/operator shall use natural gas only as fuel in all boilers and dryers. [R307-401-8] Status: In Compliance. Only natural gas is used as fuel in the specified equipment. II.B.1.b The owner/operator shall not allow visible emissions from the following emission points to exceed the specified values at the exhaust stack: A. All boilers - 10% opacity. B. Emergency generator engine - 20% opacity. [R307-201-3, R307-401-8] II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. No visible emissions were observed other than steam from the boiler stack. II.B.2 Emergency Generator Engine Requirement II.B.2.a The owner/operator shall not operate the emergency generator 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 engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] 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 the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used. B. The duration of operation in hours. C. The reason for the emergency engine usage. [40 CFR 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 on the emergency generator engine on site. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The 12-month rolling total for testing and maintenance operation was 34.9 hours. Testing and maintenance operation is logged. The generator is equipped with a non-resettable hour meter which read 694.6 during the inspection. II.B.3 Fuel Requirement II.B.3.a The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency engine. All diesel burned shall meet the requirements of 40 CFR 80.510(c). [40 CFR 63 Subpart ZZZZ] 4 II.B.3.a.1 To demonstrate compliance with the fuel oil requirements, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [40 CFR 63 Subpart ZZZZ] Status: In Compliance. Diesel fuel was purchased through Precision Power, and is shown on the invoice to meet the 15 ppm or less. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60), A: General Provisions Status: In compliance. Required records, maintenance, and notifications have been met. NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In compliance. This subpart is applicable to the natural gas-fired boilers in Section II.A.2. Compliance is satisfied by the source utilizing natural gas. Natural gas is brought in from Dominion Energy and the amount used is tracked. MACT (Part 63), A: General Provisions Status: In compliance. Required reports, notification, records, and maintenance have been met. MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In compliance. The engine is certified by the manufacturer to meet emission standards through regular maintenance on a monthly and yearly basis. ULSD is utilized as verified by a refueling/maintenance ticket. The engine operates under the 100-hour maintenance and testing limit per calendar year. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-203. Emission Standards: Sulfur Content of Fuels Status: In compliance. ULSD is utilized as verified by a refueling/maintenance ticket. R307-210. Standards of Performance for New Stationary Sources. Status: In compliance. This is met by compliance with NSPS (Part 60), Dc. R307-214. National Emission Standards for Hazardous Air Pollutants. Status: In compliance. This is met by compliance with MACT (Part 63), ZZZZ. 5 R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards Status: In compliance. No visible emissions were observed. The generator was not operating at the time of inspection. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Intermountain Healthcare - Central Laundry Facility on the Approval Order (AO) DAQE-AN126340002-19, dated January 29, 2019: PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 27154.00 Carbon Monoxide 8.88 Nitrogen Oxides 13.40 Particulate Matter - PM10 1.48 Particulate Matter - PM2.5 1.48 Sulfur Dioxide 0.31 Volatile Organic Compounds 1.22 Hazardous Air Pollutant PTE lbs/yr Formaldehyde (CAS #50000) 34 Generic HAPs (CAS #GHAPS) 12 Hexane (CAS #110543) 820 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN126340002-19, dated January 29, 2019: IHC Central Laundry should be considered in compliance at the time of inspection. The facility appeared to be well maintained and operated properly. Records were made available for review during the inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form.