DAQ-2024-008284

1
DAQC-CI122320001-24
Site ID 12232 (B1)

MEMORANDUM

TO: FILE – INTERMOUNTAIN HEALTHCARE – IHC Lake Park Office Complex

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: May 23, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: March 13, 2024

SOURCE LOCATION: 4646 West Lake Park Boulevard
West Valley City, UT 84119
SOURCE CONTACTS: Brett Jensen, Data Center Manager
[e-mail],

David Cox, Office Building Manager
[e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: This is an office building. The emission points are four natural
gas boilers, three standby diesel generators, and a 1,500-stall
parking lot. The only controls are low NOx burners on the
boilers. The boilers are comfort heaters; the generators are for
emergency power. Also, a water heater powered by natural gas is
found on-site.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE—AN122320004-16, dated
December 6, 2016
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

2
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Intermountain Healthcare
IHC Lake Park Office Complex

Attention: John Thomas
36 South State Street

4646 West Lake Park Boulevard
Salt Lake City, UT 84111 West Valley City, UT 84119

SIC Code: 1542: (Nonresidential Buildings, Except Industrial Buildings & Warehouses)

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 set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. This source
is not required to submit an emissions inventory at this time.
3
Section II: SPECIAL PROVISIONS

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

II.A.1 Lake Park Office Complex

II.A.2 Emergency Generator Engine #3512
Rating: 1,250 kW(1,818 hp)
Manufacture Date: March 1998
Fuel: Diesel
NSPS/MACT Applicability: 40 CFR 63 Subpart ZZZZ

II.A.3 Emergency Generator Engine #3516C
Rating: 2 MW (2,937 hp)
Manufacture Date: March 2007
Fuel: Diesel
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII

II.A.4 Emergency Generator Engine #3516C (New Equipment)
Rating: 2 MW (2,937 hp)
Manufacture Date: April 2008
Fuel: Diesel
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII

II.A.5 Two Natural Gas-Fired Boilers
Rating: 4.5 MMBtu/hr each
Burner Type: Low-NOx
NSPS/MACT Applicability: None
*Listed for information purposes only

II.A.6 Water heaters
Natural gas-fired water heaters
*Listed for information purposes

Manufacturer and model numbers listed for informational purposes only

Status: In Compliance. No unapproved equipment was observed at the time of
inspection. Note that the two boilers in Condition II.A.5 have been replaced
with 4 new boilers rated at 2 MMBtu/hr each. See the attached
manufacturer's plates from these boilers. Since the new boilers are < 5
MMBtu/hr, no action is recommended at this time.

II.B Requirements and Limitations

II.B.1 Source-Wide Requirements

II.B.1.a Visible emissions from the following emission points shall not exceed the following values:

A. All boilers exhaust stacks - 10% opacity

4
B. All diesel-fueled emergency generator engine exhaust stacks - 20% opacity

C. All other points - 20% opacity.

[R307-309, R307-401-8]

II.B.1.a.1 Opacity observations of emissions from the stationary sources shall be conducted according to
40 CFR 60, Appendix A, method 9. [R307-305-3]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See the attached VEO form.

II.B.2 Emergency Generator Engines Requirements

II.B.2.a The owner/operator shall use the emergency generator engines for electricity-producing
operation only during the periods when electric power from the public utilities is interrupted.
[R307-401-8]

Status: In Compliance. The emergency generators are only utilized during periods when
power from public utilities are interrupted.

II.B.2.b Each emergency generator engines shall not exceed 100 hours of operation for testing and
maintenance per rolling 12-month period. [R307-401-8]

II.B.2.b.1 Compliance with the limit of the hours of operation shall be determined by installation of an hour
meter on the emergency generator engines or by recording hours of operation in an operations
log. Records documenting the operation of the emergency generator engines shall be kept in a
log and shall include the following:

A. The date the emergency generator engine was used;
B. The duration of operation each day in hours; and
C. The reason for the emergency generator engine usage.

[R307-401-8]

II.B.2.b.2 To determine compliance with the rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the twentieth day of each month using data from the previous 12 months.
[R307-401-8]

Status: In Compliance. For the rolling 12-month period from February 2023 – January
2024:

The generator in Condition II.A.2 was run for 15 hours
The generator in Condition II.A.3 was run for 23 hours
The generator in Condition II.A.4 was run for 38.6 hours

See attached records and logs below for more details. In the spreadsheet, generator B
refers to the generator in Condition II.A.3, and generator A refers to the generator in
Condition II.A.4

5
II.B.2.c The owner/operator shall use #1, #2 or a combination of #1 and #2 diesel fuel in the emergency
generator engines. [R307-401-8]

II.B.2.c.1 The sulfur content of any fuel oil or diesel fuel burned shall not exceed 15 ppm by weight.
[40 CFR 63 Subpart ZZZZ, R307-401-8]

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

Status: In Compliance. Only ULSD is used at this source. See the attached fuel invoice
from Christensen Oil Co.

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) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. This subpart applies to the two MW emergency generators which were
manufactured in March 2007 and April 2008. Compliance with this subpart is satisfied by installing a
certified engine, maintaining and operating the engines in accordance with the manufacturer's
instructions, installation of a non-resettable hour meter, and maintaining records of use. All
information provided at the time of inspection indicate these engines are being properly maintained and
operated in accordance with this subpart. ULSD is utilized for both engines as certified by an invoice
from Christensen Oil Co.

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

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

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. Only ULSD is used at this source. See the attached fuel invoice from
Christensen Oil Co.
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Stationary Sources [R307-210]

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

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

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

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Intermountain
Healthcare – IHC Lake Park Office Complex on the Approval Order (AO) DAQE-AORA-01422: exact
fetch returns more than requested number of rows-ORA-01422: exact fetch returns more than requested
number of rows, dated ORA-01422: exact fetch returns more than requested number of rows. PTE are
supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 5083.07
Carbon Monoxide 4.06
Nitrogen Oxides 10.46
Particulate Matter - PM10 0.37
Particulate Matter - PM2.5 0.37
Sulfur Dioxide 0.03
Volatile Organic Compounds 0.33

Hazardous Air Pollutant PTE lbs/yr
Generic HAPs (CAS #GHAPS) 160

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order DAQE-AN12232004-16, dated
December 6, 2016: In compliance at the time of inspection. The
facility appears to be well-maintained and operated.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at typical frequency for this source.

NSR RECOMMENDATIONS: Remove the boilers from Condition II.A.5 and replace with the
new boilers with lower rating.

ATTACHMENTS: VEO form, email correspondence, generator records, ULSD
invoice
Daniel Riddle <[e-mail]>
12232 - follow up to air quality inspection
8 messages
Daniel Riddle <[e-mail]>Wed, Mar 13, 2024 at 11:04 AM
To: "[e-mail]" <[e-mail]>, [e-mail]
Brett and Chris,
Thank you for taking the time to meet today for your air quality inspection. As discussed, here are the records I require to complete my inspection
report:
From AO DAQE-AN122320004-16:
Condition II.B.2.b - hours of operation for all 3 emergency generators from Feb 2023 - Jan 2024
Condition II.B.2.c.1 - proof of ultra low sulfur diesel fuel usage
I confirmed with my manager - since your new boilers are rated at < 5 MMBtu/hr, you will not need to pursue a new permit at this time.
Please provide these records by March 20, 2024, and let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Brett Jensen <[e-mail]>Thu, Mar 14, 2024 at 10:11 AM
To: Daniel Riddle <[e-mail]>
Here’s the information you requested.

From: Bill Doerr <[e-mail]>
Sent: Wednesday, March 13, 2024 2:26 PM
To: Jeff Evensen <[e-mail]>; Brett Jensen <[e-mail]>; Andy Wilde <[e-mail]>
Cc: Chris Rhea <[e-mail]>
Subject: RE: 12232 - follow up to air quality inspection

Jeff,

Here is the current Generator log sheet for Gen A & B. Also here is the latest receipt for fuel we ordered for the 10k.

Thanks,

William B. Doerr
Senior | Enterprise Data Center Infrastructure & Operations
Intermountain Health | Lake Park Campus
4646 West Lake Park Blvd.
Salt Lake City, UT 84120
5/16/24, 9:47 AM State of Utah Mail - 12232 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r7186373921143070830&simpl=msg-a:r65025648443659…1/4
Email: [e-mail]
Office: 385.563.4290

From: Jeff Evensen <[e-mail]>
Sent: Wednesday, March 13, 2024 2:14 PM
To: Brett Jensen <[e-mail]>; Andy Wilde <[e-mail]>
Cc: Chris Rhea <[e-mail]>; Bill Doerr <[e-mail]>
Subject: RE: 12232 - follow up to air quality inspection

Bill,

Can you please get the information in red and send to this group.

Thanks,
Jeff

From: Brett Jensen <[e-mail]>
Sent: Wednesday, March 13, 2024 12:51 PM
To: Andy Wilde <[e-mail]>; Jeff Evensen <[e-mail]>
Cc: Chris Rhea <[e-mail]>
Subject: FW: 12232 - follow up to air quality inspection

Hello,

Chris had an air quality inspection done on the generators but in order to complete the inspection we need to provide documentation for two items
shown below in red. Can you help Chris with this request?

Thanks
[Quoted text hidden]
NOTICE: This e-mail is for the sole use of the intended recipient and may contain confidential and privileged information. If you are not the intended
recipient, you are prohibited from reviewing, using, disclosing or distributing this e-mail or its contents. If you have received this e-mail in error,
please contact the sender by reply e-mail and destroy all copies of this e-mail and its contents.
2 attachments
2015-Date Gen Run Times and Fuel Usage.xlsx
19K
February Fuel Receipt.pdf
107K
Daniel Riddle <[e-mail]>Mon, Mar 18, 2024 at 9:55 AM
To: Brett Jensen <[e-mail]>
Thank you - I'll let you know if I need anything else.
[Quoted text hidden]
Daniel Riddle <[e-mail]>Tue, Apr 23, 2024 at 10:59 AM
5/16/24, 9:47 AM State of Utah Mail - 12232 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r7186373921143070830&simpl=msg-a:r65025648443659…2/4
To: Brett Jensen <[e-mail]>
Brett - Generators A and B correspond to which generators on your equipment list on your approval order? I'm attaching it for your reference. Also,
you have three generators permitted at this site - what about the run times and maintenance for the third generator?
12232 ao.pdf
[Quoted text hidden]
Daniel Riddle <[e-mail]>Tue, Apr 23, 2024 at 11:07 AM
To: [e-mail], [e-mail]
I got a message failed notification when I sent this question to Brett, so I'm sending it you as well - could you help clarify?
[Quoted text hidden]
Daniel Riddle <[e-mail]>Thu, May 2, 2024 at 8:24 AM
To: [e-mail], [e-mail], Brett Jensen <[e-mail]>
Hello - I still need hours of operation for the third generator on this site. These are the three generators listed on your AO
The attachment I was sent on March 14, 2024 only included generator hours for two generators, and I was also not sure which of those
corresponded to the ones on this AO. Please clarify which generator is A, which is B, and provide hours of usage for your third generator from
February 2023 - January 2024 asap. Let me know if you have any questions.
[Quoted text hidden]
Jeff Evensen <[e-mail]>Thu, May 2, 2024 at 8:54 AM
To: Daniel Riddle <[e-mail]>, Bill Doerr <[e-mail]>, Brett Jensen <[e-mail]>, Shawn Folkman
<[e-mail]>
++ Shawn Folkman

From: Daniel Riddle <[e-mail]>
Sent: Thursday, May 2, 2024 8:25 AM
To: Bill Doerr <[e-mail]>; Jeff Evensen <[e-mail]>; Bre Jensen <[e-mail]>
Subject: Re: FW: 12232 - follow up to air quality inspecon

Hello - I still need hours of operation for the third generator on this site. These are the three generators listed on your AO The attachment I was sent on March 14, 2024 only included generator hours for two generators, and I was also not
Hello - I still need hours of operation for the third generator on this site. These are the three generators listed on your AO
5/16/24, 9:47 AM State of Utah Mail - 12232 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r7186373921143070830&simpl=msg-a:r65025648443659…3/4
The attachment I was sent on March 14, 2024 only included generator hours for two generators, and I was also not sure which of those
corresponded to the ones on this AO. Please clarify which generator is A, which is B, and provide hours of usage for your third generator from
February 2023 - January 2024 asap. Let me know if you have any questions.

On Tue, Apr 23, 2024 at 11:07 AM Daniel Riddle <[e-mail]> wrote:
I got a message failed notification when I sent this question to Brett, so I'm sending it you as well - could you help clarify?
---------- Forwarded message ---------
From: Daniel Riddle <[e-mail]>
Date: Tue, Apr 23, 2024 at 10:59 AM
Subject: Re: FW: 12232 - follow up to air quality inspection
To: Brett Jensen <[e-mail]>

Brett - Generators A and B correspond to which generators on your equipment list on your approval order? I'm attaching it for your reference.
Also, you have three generators permitted at this site - what about the run times and maintenance for the third generator?
12232 ao.pdf

On Mon, Mar 18, 2024 at 9:55 AM Daniel Riddle <[e-mail]> wrote:
[Quoted text hidden]
[Quoted text hidden]
Daniel Riddle <[e-mail]>Wed, May 8, 2024 at 9:52 AM
To: Jeff Evensen <[e-mail]>
Cc: Bill Doerr <[e-mail]>, Brett Jensen <[e-mail]>, Shawn Folkman <[e-mail]>
Hello Shawn - do you have this information?
[Quoted text hidden]
5/16/24, 9:47 AM State of Utah Mail - 12232 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r7186373921143070830&simpl=msg-a:r65025648443659…4/4
Daniel Riddle <[e-mail]>
Hours of operation for generator
3 messages
Daniel Riddle <[e-mail]>Mon, May 13, 2024 at 11:05 AM
To: [e-mail]
David,
I got your email from Bill Doerr - I inspected the Intermountain Healthcare offices on March 13, 2024, and I need one record to complete my inspection
report.
I'm looking for hours of operation for non-emergency/maintenance purposes for the 1,250 kW generator located at the office building from February
2023 - January 2024. This total should be less than 100 hours to be in compliance.
Please reply upon receipt of this email and provide this record no later than May 20, 2024. Thanks and let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
David Cox <[e-mail]>Wed, May 15, 2024 at 10:47 AM
To: Daniel Riddle <[e-mail]>
Cc: Jesse Eskelson <[e-mail]>, Becky Opoulos <[e-mail]>
I have attached our weekly generator reports for the Lake Park building for reference. The report shows that we had 766 hours on
this generator on 2/01/23. We recorded 781 hours on 1/03/24. That leaves a difference of 15 hours run time for the year. If any more
info is needed, please feel free to contact me via email. Thank you.
[Quoted text hidden]
NOTICE: This e-mail is for the sole use of the intended recipient and may contain confidential and privileged information. If you are not the intended
recipient, you are prohibited from reviewing, using, disclosing or distributing this e-mail or its contents. If you have received this e-mail in error,
please contact the sender by reply e-mail and destroy all copies of this e-mail and its contents.
2 attachments
[e-mail]_20240515_073032.pdf
233K
LP 02.01.pdf
343K
Daniel Riddle <[e-mail]>Thu, May 16, 2024 at 9:43 AM
To: David Cox <[e-mail]>
Thank you for the reply. - I'll let you know if I need anything else.
[Quoted text hidden]
5/16/24, 9:43 AM State of Utah Mail - Hours of operation for generator
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-2050855008181310710&simpl=msg-a:r-5564309715644…1/1
Generator Run Logs (EPA Use or Inspection Use)
Year Month(s)
2023 Jan Feb March April May June July Aug Sept Oct Nov Dec Total
Generator/Run Min(s)A-70/B-70 A-61/B-81 A-95/B-84 A-60/B-60 A-98/B-65 A-100/B-125 A-80/B-80 A-100/B-100 A-1220/B-314 A-80/B-110 A-387/B-390 A-60/B-60 A-2,411/B-1,539 min(s)
Fuel Used (Gallons)A-63/B-63 A-71/B-92 A-80/B-85 A-48/B-50 A-89/B-73 A-117/B-121 A-90/B-96 A-102/B-99 A-1610/B-125 A92/B-186 A-70/B-21 A70/B-19 A-2,502/B-1,030 gal(s)
Incident Run Time Minute(s)0 0 0 0 0 0 0 0 A-112/B-21 0 A-48/B-153 0 A-160/B-174 min(s)
Fuel Ordered 10k (Gallons)0 0 0 0 0 0 0 0 2500 0 0 5010 7,510 gal(s)
May Power Work (Gen/Mins)0 0 0 0 Pushed to Sept 0 0 0 A-1160/B-117 0 0 0 A-1160/B-117 min(s)
2024 Jan Feb March April May June July Aug Sept Oct Nov Dec Total
Generator/Run Min(s)A-85/B-85 A-80/B-80 min(s)
Fuel Used (Gallons)A-92/B-41 A-69/B-26 gal(s)
Incident Run Time Minute(s)0 0 0 0 0 0 0 0 0 0 0 0 min(s)
Fuel Ordered 10k (Gallons)0 4,000 0 0 0 0 0 0 0 0 0 0 gal(s)
May Power Work (Gen/Mins)0 0 0 0 0 0 0 0 0 0 0 0 min(s)