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Home My WebLink AboutDAQ-2024-0049621 DAQC-CI129440001-24 Site ID 12944 (B1) MEMORANDUM TO: FILE – INTERMOUNTAIN HEALTHCARE – Alta View Hospital THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: January 30, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: January 24, 2024 SOURCE LOCATION: 9660 South 1300 East Sandy, UT 84094 SOURCE CONTACTS: Matt Wood, Facilities Manager 801-505-2909 John Bernardo, Boiler Maintenance Supervisor David Nickle, Generator Maintenance Supervisor Jim Blankenau, Corporate Facilities Manager 801-484-6114 james.blankenau@imail.org OPERATING STATUS: Operating normally. PROCESS DESCRIPTION: Intermountain Healthcare operate Alta View Hospital in Sandy, UT. There are three diesel-fired Emergency Generators and various steam and hot water boilers. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129440003-19, dated March 13, 2019 NSPS (Part 60) Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60) IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, 0 0 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Intermountain Healthcare – Alta View Hospital 36 South State Street 9660 South 1300 East Salt Lake City, UT 84111 Sandy, UT 84094 SIC Code: 8062 (General Medical & Surgical Hospitals) 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] 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] Status: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process. Maintenance is regularly conducted and records are maintained. No reportable breakdowns have occurred since the previous inspection. The source is not required to submit an emission inventory at this time. All equipment listed in the AO was installed at the time the AO was issued. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Alta View Hospital II.A.2 One (1) Emergency Generator Engine Max Engine Rating: 910 kW (1,220 HP) Fuel: Diesel Model Year: 2009 NSPS/MACT applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ II.A.3 Two (2) Emergency Generator Engines Max Engine Rating: 1,656 kW (2,220 HP) Fuel: Diesel Model Year: 2017 NSPS/MACT applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ II.A.4 Two (2) Dual-Fuel Steam Boilers Max Rating: 3.5 MMBtu/hr (each) Fuel: Natural gas and diesel II.A.5 Three (3) Dual-Fuel Boilers Max Rating: 6 MMBtu/hr Fuel: Natural gas and diesel II.A.6 Various boilers less than 5 MMBtu/hr each Fuel: Natural gas and/or propane Status: In compliance. Equipment observed on-site was consistent with that listed. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a 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 when fired on natural gas - 10% opacity B. All emergency generator engines and boilers when fired on diesel - 20% opacity. [R307-305, R307-401-8] II.B.1.a.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. [R307-305] Status: In Compliance. No visible emissions were observed from any point during the inspection. II.B.2 Boiler Requirements II.B.2.a The owner/operator shall use only natural gas as a primary fuel in all boilers on site. [R307-401-8] Status: In Compliance. The boilers operate on natural gas unless the utility company requires otherwise. No diesel fuel has been used in the last 12 months. 4 II.B.2.b The owner/operator shall limit fuel oil usage in all dual-fuel boilers to 48 hours each, per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the dual-fuel boilers during periods of natural gas curtailment, gas supply interruption, or startups. [40 CFR 63 Subpart JJJJJJ, R307-401-8] II.B.2.b.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 fuel oil usage in each dual-fuel boiler shall be kept in a log and shall include the following: A. The date fuel oil was used B. The duration of operation in hours C. The reason for fuel oil usage. [R307-401-8] Status: In Compliance. The boilers operate on natural gas unless the utility company requires otherwise. No diesel fuel has been used in the last 12 months. II.B.3 Emergency Generator Engine Requirements II.B.3.a The owner/operator shall not operate each 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.3.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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter on each emergency generator engine on site. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. During the 12-month period of January through December 2023, the 910 kW/1,220 hp generator operated for 16.5 hours, the north 1,656 kW/2,220 hp generator operated for 16.6 hours, and the south 1,656 kW/2,220 hp generator operated for 16.3 hours. Each generator is equipped with a non-resettable hour meter which read 519.9 (910 kW), 174.8 (north 1,656 kW), and 175.5 (south 1,656 kW). II.B.3.b The owner/operator shall perform maintenance and testing of the emergency generator engines during non-emergency situations in accordance with the following: A. Maintenance and testing operations shall only be conducted between 6:00 AM to 6:00 PM; B. A maximum of one (1) engine shall be operated at any one time during maintenance and testing operations; and C. Maintenance and testing operations shall not exceed one (1) time per month, per engine. [R307-410] 5 II.B.3.b.1 To determine compliance with the maintenance and testing requirements, the owner/operator shall document the date and the hours of the day that the maintenance and testing was performed and the generator engine that was maintained and tested. The owner/operator shall maintain records anytime an engine is tested. [R307-401-8] Status: In Compliance. Operation logs are kept and contain the required information. II.B.4 Fuel Requirements II.B.4.a The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the boilers and emergency engines. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm sulfur. [R307-401-8] II.B.4.a.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, 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. [R307-401-8] Status: In Compliance. Diesel fuel is purchased through RelaDyne and is Ultra-low sulfur. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: Not Applicable. The boilers are less than 10 MMBtu/hr. The boiler operates on natural gas as the primary fuel. The boilers have not operated on diesel fuel during the past 12 months. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The generators operate on Ultra-low sulfur diesel fuel. Regular maintenance is conducted with the last oil change taking place June 20, 2023, for all three engines. All engines are equipped with a non-resettable hour meter. Each generator was tested under the 100-hour testing limit. Maintenance activities are recorded. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The generators operate on Ultra-low sulfur diesel fuel. Regular maintenance is conducted with the last oil change taking place June 20, 2023, for all three engines. All engines are equipped with a non-resettable hour meter. Each generator was tested under the 100-hour testing limit. Maintenance activities are recorded. 6 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Diesel fuel is purchased from RelaDyne and is Ultra-low sulfur. Stationary Sources [R307-210] Status: Not Applicable to Subpart Dc but applicable to Subpart IIII. All boilers are less than 10 MMBtu/hr. The boilers have only operated on natural gas during the last 12 months. Compliance with Subpart IIII is met by compliance with Subpart IIII listed in the above Federal Requirements. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This Area Source Rule is applicable per Subpart ZZZZ. The generators operate on Ultra-low sulfur diesel fuel. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. No visible emissions were observed from the boilers or generators during the inspection. Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. No visible emissions were observed from any point during the inspection. The property is either paved or landscaped. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Intermountain Healthcare- Alta View Hospital on the Approval Order (AO) DAQE-AN129440003-19, dated March 13,2019. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 23409.00 Carbon Monoxide 13.16 Nitrogen Oxides 8.96 Particulate Matter - PM10 1.48 Particulate Matter - PM2.5 1.48 Sulfur Dioxide 0.12 Volatile Organic Compounds 0.86 Hazardous Air Pollutant PTE lbs/yr Benzene (Including Benzene from Gasoline) (CAS #71432) 4 Formaldehyde (CAS #50000) 30 Generic HAPs (CAS #GHAPS) 15 Hexane (CAS #110543) 688 Toluene (CAS #108883) 2 7 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129440003-19, dated March 13, 2019: The source 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 at the time of inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form.