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Home My WebLink AboutDAQ-2024-0072561 DAQC-CI130590001-24 Site ID 13059 (B1) MEMORANDUM TO: FILE – SOUTH VALLEY WATER RECLAMATION FACILITY – Wastewater Treatment Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: March 13, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: November 20, 2023 SOURCE LOCATION: 7495 South 1300 West West Jordan, UT 84084 DIRECTIONS: SOURCE CONTACTS: Randy Wyness, Manager 801-566-7711 rwyness@svwater.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: This facility is a 50 million gallons per day wastewater treatment plant. Natural gas-fired boilers provide steam and heat to the Administration Building, Solids Processing Building, and the Headworks Building. Two diesel fired engine generators are used exclusively as stand-by units. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN130590006-23, dated August 1, 2023 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 SOURCE EVALUATION: Name of Permittee: Permitted Location: South Valley Water Reclamation Facility Wastewater Treatment Plant 7495 South 1300 West 7495 South 1300 West West Jordan, UT 84084 West Jordan, UT 84084 0 0 2 SIC Code: 4952: (Sewerage Systems) 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. Records were current and made available for review at the time of inspection. The facility appeared to be well maintained and properly operated. Mr. Wyness stated that there had not been any breakdowns in the last two years. Emission inventories are not required of this source at this time. Notification is not necessary, the equipment was already 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 Wastewater Treatment Plant II.A.2 Two (2) Boilers Rating: 14.3 MMBtu/hr Fuel: Natural Gas Control: Low-NOx NSPS Applicability: 40 CFR 60 Subpart Dc II.A.3 Two (2) Thermal Oxidizers Rating: 2.5 MMBtu/hr Fuel: Natural Gas Exhaust: 20 ppm Methane II.A.4 Two (2) Storage Silos Control: Bin Vents and Cartridge Filters II.A.5 Various Boilers/Heaters Ratings: <5 MMBtu/hr Fuel: Natural Gas *For informational purposes only II.A.6 One (1) Emergency Engine Generator Rating: 2,875 HP (2,145 kW) Fuel: Diesel Installed: Pre-2006 MACT Applicability: 40 CFR 63 Subpart ZZZZ II.A.7 One (1) Emergency Engine Generator Rating: 2,220 HP (1,352 kW) Fuel: Diesel Tier: 2 Manufactured: 2021 NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ Status: In Compliance. Equipment listed is consistent with that observed on-site. II.B Requirements and Limitations II.B.1 Opacity Requirements II.B.1.a The owner/operator shall not allow visible emissions to exceed the following: A. All bin vents and baghouse - 10% opacity B. All natural gas combustion exhaust points - 10% opacity C. All diesel engines - 20% opacity 4 D. Haul Roads - 20% opacity E. All other points - 20% opacity [R307-401-8] II.B.1.a.1 Opacity observations of visible emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.a.2 Visible emission determinations for fugitive dust from haul roads and operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15- second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8] Status: In Compliance. No visible emissions were observed during the inspections. II.B.2 Natural Gas-Fired Boilers. Heaters, and Thermal Oxidizer Requirements II.B.2.a The owner/operator shall use only natural gas as a fuel in the boilers, heaters, and thermal oxidizers. [R307-401-8] Status: In Compliance. Only natural gas is used as fuel in the above equipment. II.B.2.b The owner/operator shall not exceed a methane concentration of 20 ppmv in the exhaust gas of each thermal oxidizer at all times. [R307-401-8] II.B.2.b.1 The owner/operator shall record each thermal oxidizer exhaust gas methane concentration at least per operating day while each thermal oxidizer is operating. [R307-401-8] II.B.2.b.2 The owner/operator shall maintain the following records of the exhaust gas methane concentration for each thermal oxidizer: A. Unit identification; B. Daily exhaust gas methane concentration C. Date of reading. [R307-401-8] II.B.2.c The owner/operator shall monitor the methane concentration in the thermal oxidizer exhaust gas with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.2.d At least once every 12 months, the owner/operator shall calibrate the methane monitoring equipment in accordance with the manufacturer's instructions or replace the methane monitoring equipment. [R307-401-8] 5 II.B.2.d.1 The owner/operator shall maintain records of the methane monitoring equipment calibrations and replacements. [R307-401-8] Status: Not Applicable. According to Mr. Wyness the source does not process methane or route it through the thermal oxidizers. The source submitted an NOI on February 2, 2024, to remove these conditions from the AO. As of the date of this memo, the proposed modification is out for public comment. II.B.3 Diesel-Fired Emergency Engine Generator Requirement II.B.3.a The owner/operator shall not exceed the following limits: A. Operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations B. Operate any emergency engine on site before 10:00 am or after 4:00 pm during non-emergency situations C. Operate more than one (1) emergency engine at a time during non-emergency situations D. Test each emergency engine for more than 52 times per rolling 12-month period There is no time limit on the use of the engines 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 time engine usage begins each day D. The time engine usage ends each day E. 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 for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The 2,875 HP generator operated 7 hours and the 2,220 HP generator operated for 21.5 hours in the last 12 months. Testing and maintenance operation is tracked and contains the information listed above. Both engines have a non-resettable hour meter. 6 II.B.3.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.3.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. [R307-401-8] II.B.3.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] Status: In Compliance. Diesel fuel is purchased through RelaDyne and is 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), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. The boilers have only operated on natural gas in the last 24 months. NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. Testing and maintenance activities are below the 100 hour limit. Regular PM maintenance is conducted. Annual maintenance is conducted by Cummins Rocky Mountain. MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. Testing and maintenance activities are below the 100 hour limit. Regular PM maintenance is conducted. Annual maintenance is conducted by Cummins Rocky Mountain. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-210. Stationary Sources Status: In Compliance. This area source rule is applicable per Subpart IIII. Compliance with this area source rule is satisfied by compliance with Section II.B.3 of the AO. This area source rule is also applicable per Subpart Dc. The source has only used natural gas as fuel in the boilers in the last 12 months, therefore in compliance with Subpart Dc. R307-214. National Emission Standards for Hazardous Air Pollutants Status: In Compliance. This area source rule is applicable per Subpart ZZZZ. Compliance with this area source rule is satisfied by compliance with Section II.B.3 of the AO. 7 R307-304. Solvent Cleaning. Status: Not Applicable. The source uses Solvent (Exxsol D 40) but do not use 55 gallons in a 12-month period which would trigger applicability. The source last purchased this solvent in a 55-gallon drum in 2009 and still have a few gallons remaining currently. R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards Status: In Compliance. The requirements of this area source rule are satisfied by compliance with AO condition II.B.1. R307-309. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust Status: In Compliance. No visible emissions were observed during the inspection. The grounds are grass or asphalt. R307-325. Ozone Nonattainment and Maintenance Areas: General Requirements. Status: In Compliance. The source keeps all VOC-containing materials lidded when not in use. Waste rags are stored in covered containers. No spills of VOC-containing materials were observed. R307-335. Degreasing. Status: In Compliance. The source has a Graymills parts washer on site which is lidded and kept closed while not in use. Instructions of proper use are posted on the lid. Waste rags are stored in covered containers. The cleaning agent is kept in a covered container. No spills were observed during the inspection. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from South Valley Water Reclamation Facility – Wastewater Treatment Plant on the Approval Order (AO) DAQE-AN130590006-23, dated August 1, 2023. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 25321.00 Carbon Monoxide 32.28 Nitrogen Oxides 12.30 Particulate Matter - PM10 1.69 Particulate Matter - PM2.5 1.69 Sulfur Dioxide 0.13 Volatile Organic Compounds 1.30 Hazardous Air Pollutant PTE lbs/yr Generic HAPs (CAS #GHAPS) 40 Hexane (CAS #110543) 740 8 PREVIOUS ENFORCEMENT ACTIONS: Compliance Advisory – August 9, 2022 – Failure to submit NOI by specified time No Further Action – December 12, 2023 – For the above CA COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN130590006-23, dated August 1, 2023: South Valley Water Reclamation Facility should be considered in compliance with AO DAQE-AN130590006-23 at the time of inspection. The facility appeared to be well maintained and operated properly. Records were current and made available for review. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. NSR RECOMMENDATIONS: Remove methane conditions from AO requirements. ATTACHMENTS: VEO Form, Parts Washer Email.