Loading...
HomeMy WebLinkAboutDAQ-2024-0082991 DAQC-CI104500001-24 Site ID 10450 (B1) MEMORANDUM TO: FILE – SALT LAKE CITY DEPARTMENT OF AIRPORTS – Salt Lake City International Airport THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: May 16, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: March 27, 2024 SOURCE LOCATION: 776 North Terminal Drive Salt Lake City, UT 84122 DIRECTIONS: Contact source prior to site visit as some of the permitted equipment is located in secured areas. SOURCE CONTACTS: Kevin Staples, Environmental Manager (801) 575-3470, kevin.staples@slcgov.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Salt Lake City Department of Airports (SLCDA) operates support facilities for the Salt Lake City International Airport. There are numerous emergency generators used to provide backup power to essential airport equipment and operations. These generators operate on diesel. There are multiple above-ground fuel tanks: Two 8,000-gallon diesel fuel tanks, one 8,000-gallon gasoline fuel tank, three 1000-gallon diesel fuel tanks, one 250-gallon used-oil fuel tank, one 15,000-gallon diesel fuel tank, one 8,000-gallon biodiesel fuel tank, and one 6,000-gallon diesel fuel tank. All remaining fuel tanks are located underground. Two paint booths are also operated on-site. One booth, located at the carpenter shop in the maintenance building, is used to paint and varnish wooden office furniture. The other booth is in the fleet operations building and is used to repaint vehicles after repair work is completed. Four new dual fuel boilers (25 MMBtu/hr.) operate at this location. The remaining on-site boilers are rated less than 5 MMBTU/hr. The source also operates a variety of miscellaneous equipment including a baghouse. ) 1 2 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104500030-24, dated February 9, 2024 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, NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, MACT (Part 63) CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities, MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Salt Lake City Department of Airports Salt Lake City International Airport P.O. Box 145550 776 North Terminal Drive Salt Lake City, UT 84114 Salt Lake City, UT 84122 SIC Code: 4581: (Airports, Flying Fields, & Airport Terminal Services) 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] 3 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. Each condition of Section I was reviewed with the source and appeared to be in compliance. The 2023 Emission Inventory was submitted by the required date but is still under review. An updated construction status letter was submitted after the inspection. Refer to this letter in the attachments. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 SLCDA Salt Lake City International Airport II.A.2 Maintenance Shop Baghouse One (1) vacuum dust collection system Location: Maintenance Shop/ North Support Area II.A.3 Boilers and Comfort Heating Devices Various natural gas-fired boilers and comfort heating devices each rated at less than 5 MMBtu/hr - for information only II.A.4 Boilers Four (4) boilers each rated at 25 MMBtu/hr Primary Fuel: Natural gas Backup Fuel: Diesel Location: Central Utility Plant NSPS applicable: Subpart Dc II.A.5 Heat Exchanger One (1) natural gas-fired heat exchanger Location: Glycol Plant Rating: 8 MMBtu/hr II.A.6 135 kW Emergency Generator Engine Fuel: Natural Gas/Propane Number of units: One (1) Location: Fire Station 12 MACT applicable: Subpart ZZZZ 4 II.A.7 105 kW Emergency Generator Engine Fuel: Propane Number of units: One (1) Location: Communications Building MACT applicable: Subpart ZZZZ II.A.8 80 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Park and Wait Lot NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.9 80 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Airport Operations Building NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.10 80 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Fire Station 11 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.11 100 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: TRP South Parking Area - South Support Building (SS08) NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.12 200 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: East Economy Lot NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.13 200 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Rental Car Quick Turn Around (QTA) NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.14 205 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) 5 Location: Parking Lot B/West Economy Lot MACT applicable: Subpart ZZZZ II.A.15 210 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: South Employee Lot NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.16 275 KW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Parking Admin. Building MACT applicable: Subpart ZZZZ II.A.17 300 kW Emergency Generator Engines Fuel: Diesel Number of units: Two (2) Location: North Support Area and Pump Station No. 9 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.18 300 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Pump Station No. 1 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.19 300 and 350 kW Emergency Generator Engines Fuel: Diesel Number of units: One rated at 300 kW and one rated at 350 kW Locations: Terminal Unit Connector (350 kW)/Building Warehouse (300 kW) NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.20 450 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) EPA Tier 2 Certified Location: Pump Station #5 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.21 400 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Taxiway L Deicing Facility NSPS applicable: IIII MACT applicable: ZZZZ 6 II.A.22 550 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: Runway 34L deicing facility NSPS applicable: IIII MACT applicable: ZZZZ II.A.23 565 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: EDS MACT applicable: Subpart ZZZZ II.A.24 750 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: South Vault MACT applicable: Subpart ZZZZ II.A.25 800 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: East/West Vault MACT applicable: Subpart ZZZZ II.A.26 1,000 kW Emergency Generator Engine Fuel: Diesel Number of units: One (1) Location: East/West Vault MACT applicable: Subpart ZZZZ II.A.27 60 kW Emergency Generator Engines Fuel: Diesel Number of Units: Two (2) Manufacture Date: 2015 Locations: One (1) at cell phone parking lot, the other at Police Training Facility NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.28 300 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2017 EPA Tier 3 certified Location: Airport Operations Center NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.29 300 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) 7 Manufacture Date: 2017 EPA Tier 3 certified Location: Airport Operations Center NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.30 100 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2017 EPA Tier 3 certified Location: Technical Services Building NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.31 1,500 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2017 EPA Tier 2 certified Location: Central Utility Plant NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.32 600 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2014 Location: Runway 16L NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.33 600 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2017 Location: Gateway NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.34 1,250 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2017 Location: South Concourse West NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.35 1,500 kW emergency Generator Engines Fuel: Diesel Number of Units: Three (3) 8 Manufacture Date: 2017 Location: Two (2) at Terminal and one (1) at South Concourse West NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.36 2,500 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2017 Location: Terminal NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.37 150 kW Emergency Generator Engine Fuel: Diesel Number of Units: Two (2) EPA Tier III Certified Location: Central Warehouse Building and Concourse F NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.38 375 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) EPA Tier 2 certified Location: Airport Training Facility NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.39 500 kW Emergency Generator Engines Fuel: Diesel Number of Units: Two (2) Manufacture Date: 2017 EPA Tier 2 certified Location: Parking Garage #1 and #2 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.40 750 kW Emergency Generator Fuel: Diesel Number of Units: One (1) Location: Glycol/Wildlife Building EPA Tier 2 Certified Manufacturer Date: 2021 NSPS Applicable: Subpart IIII MACT Applicable: Subpart ZZZZ II.A.41 1,500 kW Emergency Generator Engine Fuel: Diesel Number of Units: One (1) Manufacture Date: 2018 9 EPA Tier 2 certified Location: North Concourse West #1 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.42 2,000 kW Emergency Generator Engines Fuel: Diesel Number of Units: Two (2) Manufacture Date: 2018 EPA Tier 2 certified Location: North Concourse West #2 and #3 NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.43 1500 kW Emergency Generator Engines Fuel: Diesel Number of Units: Three (3) Manufacture Date: 2021 EPA Tier 2 certified Location: South Concourse East NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.44 1500 kW Emergency Generator Engines Fuel: Diesel Number of Units: Two (2) Manufacture Date: 2023 EPA Tier 2 certified Location: North Concourse East NSPS applicable: Subpart IIII MACT applicable: Subpart ZZZZ II.A.45 Paint Booths Two (2) paint booths Locations: Vehicle Maintenance Shop/Carpenter Shop at North Support Area II.A.46 Gasoline Underground Storage Tank (UST) One (1) 12,000-gallon underground storage tank Location: North Support Area MACT Applicable: Subpart CCCCCC II.A.47 Diesel Aboveground Storage Tank (AST) One (1) 6,000 gallons Location: Fire Station 11 II.A.48 Diesel USTs Two (2) each rated at 5,000 gallons emergency backup USTs Location: East/West Vault II.A.49 Diesel UST One (1) rated at 6,000-gallon emergency backup UST Location: South Vault 10 II.A.50 Diesel USTs Two (2) each rated at 12,000 gallons Location: North Support Area II.A.51 Biodiesel AST One (1) biodiesel above-ground storage tank Capacity: 8,000 gallons Location: North Support Area II.A.52 Diesel USTs Two (2) diesel underground storage tanks Capacity: 12,000 gallons each Location: Taxiway Lima Deicing Facility and Runway 34L Deicing Facility II.A.53 Gasoline USTs Three (3) gasoline underground storage tanks Capacity: 25,000 gallons each Location: TRP - Rental Car Quick Turn Around (QTA) MACT Applicable: Subpart CCCCCC II.A.54 Diesel AST One (1) above-ground storage tank rated at 15,000 gallons Service: Diesel Location: Central Utility Plant II.A.55 Used-Oil AST One (1) above-ground storage tank rated at 250 gallons Service: Used oil Location: North Support Area II.A.56 Three (3) Diesel AST Capacity: 1000 gallons Location: One (1) at Fire station No. 11 and Two (2) at South Support Building II.A.57 Two (2) Diesel ASTs Capacity: 8,000 gallons each Location: North Support Area II.A.58 Gasoline AST Capacity: 8,000 gallons Location: North Support Area Status: In Compliance. The listed equipment was observed during the inspection. No unapproved equipment was observed. Additional Information: II.A.17: The 300kW generator engine has not yet been installed at Pump Station No.9 II.A.44: The two 1500kW generator engines have not yet been installed at North Concourse East II.A.57: The two diesel ASTs have not yet been installed II.A.58: The gasoline AST has not yet been installed 11 II.B Requirements and Limitations II.B.1 Source-Wide Requirements. II.B.1.a The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309] Status: In Compliance. The applicable requirements of this area source rule are followed. No fugitive dust or emissions were observed during the inspection. Refer to the VEO Form in the attachments. II.B.1.b The owner/operator shall comply with a Fugitive Dust Control Plan (FDCP) acceptable to the Director for control of all dust sources associated with the Salt Lake City International Airport. [R307-309-6] Status: In Compliance. All FDCPs associated with the Salt Lake City International Airport are current. Multiple FDCPs have been submitted due to ongoing, phased construction projects. II.B.1.c The owner/operator shall not allow visible emissions from the following emission units to exceed the following opacity limits: A. All paint booth exhaust stacks - 10% opacity B. All boiler exhaust stacks - 10% opacity when burning diesel, 7% when burning natural gas C. All natural gas-fired emergency generator engine exhaust stacks - 10% opacity D. All diesel-fired emergency generator engine exhaust stacks - 20% opacity E. The vacuum dust collection system - 10% opacity F. All other points - 20% opacity. [40 CFR 60 Subpart Dc, R307-201, R307-309, R307-401-8] II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any of the listed points. Refer to the VEO Form in the attachments. II.B.1.d The following limits shall not be exceeded: A. 576,000 gallons of gasoline throughput per rolling 12-month period for the 12,000-gallon underground storage tank; B. 2,000,000 gallons of gasoline throughput per rolling 12-month period for the three (3) 25,000-gallon underground storage tanks combined; C. 6,000 gallons of diesel fuel throughput per rolling 12-month period for the 6,000-gallon above ground diesel fuel storage tank; 12 D. 48 hours of operation using fuel oil per calendar year for periodic testing for each of the 25 MMBtu/hr boilers. [R307-401-8] II.B.1.d.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 of fuel throughput and boiler hours of use shall be kept for all periods when the plant is in operation. Fuel throughput and boiler hours of use shall be determined by the following: A. Fuel throughput shall be determined by examination of the flow measurements from the gasoline and diesel fuel storage tanks, and B. Supervisor monitoring and maintaining of an operations log shall determine the hours of operation using fuel oil for the four (4) 25 MMBtu/hr boilers. These records of boiler operations, fuel throughput, and boiler hours of use shall be kept on a daily basis. [R307-401-8] Status: In Compliance. Calculations are made according to this condition. Records of boiler operation, fuel throughput, and boiler hours are kept on a daily basis. The source was notified that Item C nearly exceeded the allowable limit for the rolling 12-month period. The source mentioned they will talk with NSR to amend this requirement to better reflect the typical throughput. A) 111,313 gallons of gasoline for the rolling 12-month period ending February 2024 B) 1,578,996 gallons of gasoline for the rolling 12-month period C) 5,919 gallons of diesel for the rolling 12-month period D) 0 hours of operation using fuel oil for the rolling 12-month period II.B.1.e The owner/operator shall not emit more than the following from evaporative sources including the paint booth, degreasers, storage tanks, and other associated airport operations on site: 9.96 tons per rolling 12-month period of VOCs 1.93 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.1.e.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall estimate emissions from the storage tanks using the EPA TANKS program. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.1.e.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] II.B.1.e.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material 13 B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] Status: In Compliance. Calculations are made according to these conditions. Each SDS is kept and was available to view. The total VOC and HAPs emissions for the rolling 12-month period are as follows: 0.045 tons of VOCs 0.040 tons of HAPs II.B.1.f All materials, including service rags containing any VOC or HAP shall be stored in covered containers, except when in active use. [R307-325] Status: In Compliance. Service rags were observed in covered containers. No other VOC or HAP containing materials were observed to be exposed to the open atmosphere. II.B.1.g The owner/operator shall comply with the applicable provisions of UAC R307-328 with respect to the 12,000-gallon and 25,000-gallon underground gasoline fuel storage tanks. [R307-328-5, R307-401-8] Status: In Compliance. The gasoline fuel storage tanks were in compliance according to UAC Rule 307-328. The underground storage tanks were viewed during the inspection. Submerged fill pipes extend the required depth from the bottom of the tanks. Submerged filling and vapor control are practiced according to this rule. The source indicated that vapor tightness tests occur on an annual basis. Refer to the most recent vapor tightness test located in the attachments. 14 II.B.1.h The owner/operator shall comply with all applicable requirements of 40 CFR 63 Subpart CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities. [40 CFR 63 Subpart CCCCCC] Status: In Compliance. Air pollution control practices were observed and throughput records are maintained. Measures are taken to prevent vapor release. These include minimizing gasoline spills, covering all open gasoline containers, and cleaning up spills as expeditiously as practicable. Bulk tanks are filled via submerged filling with vapor recovery. II.B.1.i The owner/operator shall install submerged fill pipes in the 8,000-gallon diesel and gasoline storage tanks listed in conditions II.A.57 and II.A.58. The owner/operator shall paint the exterior of these storage tanks with a white enamel coating. [R307-401-8] Status: Not Applicable. The fuel storage tanks listed in Condition II.A.57 and II.A.58 have not yet been installed. II.B.2 Boiler Requirements II.B.2.a The owner/operator shall install and operate the 25 MMBtu/hr boilers with low NOx burners and flue gas recirculation systems. [R307-401-8] Status: In Compliance. The 25MMBtu/hr boilers are equipped with low NOx burners and flue gas recirculation systems. II.B.2.a.1 The owner/operator shall maintain manufacturer's guarantee showing that the NOx emissions shall not exceed 9 ppm from the boilers. [R307-401-8] Status: In Compliance. The source maintains records of the manufacturer’s guarantee of NOx emissions not exceeding 9ppm. These records were viewed during the inspection. II.B.2.b The owner/operator shall use natural gas as primary fuel and fuel oil as back-up fuel in the 25 MMBtu/hr boilers. [R307-203-1, R307-401-8] Status: In Compliance. Natural gas is the primary fuel used in the 25 MMBtu/hr boilers. Fuel oil is available as a backup fuel but has not been used since the boilers were installed. II.B.2.c The owner/operator shall install and operate the 8 MMBtu/hr heat exchanger with an ultra-low NOx burner. [R307-401-8] II.B.2.c.1 The owner/operator shall maintain a manufacturer's guarantee showing the NOx emissions shall not exceed 9 ppm from the heat exchanger. [R307-401-8] Status: In Compliance. The heat exchanger is equipped with an ultra-low NOx burner. The source maintains the manufacturer’s guarantee of the NOx emissions not exceeding 9ppm. II.B.3 Emergency Generator Engine Requirements. II.B.3.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. [40 CFR 63 Subpart ZZZZ, R307-401-8] 15 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: 1. The date the emergency engine was used 2. The duration of operation in hours 3. 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. Each emergency engine did not operate for more than 100 hours for the rolling 12-month period. Operating hours ranged from 0-55 hours. Each engine operates on a monthly basis for maintenance and testing. The date of operation, duration, and reason for usage are documented. Each engine has a non-resettable hour meter. II.B.3.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator 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.3.b.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. [40 CFR 60 Subpart IIII, R307-401-8] Status: In Compliance. The emergency engines only operate using #2 ultra-low sulfur diesel. This was determined by a certificate of analysis and tank inspection records provided by the supplier. Refer to a recent tank inspection record located in the attachments. II.B.3.c The owner/operator shall not test each engine listed in II.A.34, II.A.35, II.A.36, and II.A.43 more than 52 times per rolling 12-month period. The owner/operator shall not test the above emergency generators before 7 am or after 7 pm each day. All other generators may be tested at any time of the day. [R307-410] II.B.3.c.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 for engine testing shall be kept in a log and shall include the following: 1. The date of the test 2. The start and end time of any test. [R307-410] Status: In Compliance. The applicable engines are tested once a month. Test dates, along with start and stop times, are recorded on paper logs located in each engine housing unit. The source is aware of the time restrictions to operate these engines and has added this to the training protocol. II.B.4 Paint Booth Requirement 16 II.B.4.a The paint spray booths shall each be equipped with a set of paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting each booth shall pass through this control system before being vented to the atmosphere (outside building/operation). [R307-401-8] Status: In Compliance. Particulate filters were observed at each of the paint booths and all exiting air appeared to pass through these filters. 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. This subpart is applicable to the natural gas-fired boilers in Condition II.A.4. Boilers over 10 MMBtu/hr are subject to this rule. Compliance is satisfied by the source utilizing natural gas and maintaining records for two years. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The applicable generator engines to this subpart operated for less than 100 hours for emergency usage for the rolling 12-month period. Each engine operates at least monthly for preventative maintenance. Maintenance is performed according to manufacturer specifications and operational records are kept which include the date, duration, and reason for usage. Refer to Section II.B.3 for more details. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Status: Not Applicable. Any generator engine applicable to this rule has been permanently removed and replaced with a diesel-fueled engine. MACT (Part 63) CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Status: In Compliance. Refer to Condition II.B.1.g and II.B.1.h for more details. MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The applicable generator engines to this subpart operated for less than 100 hours for emergency usage for the rolling 12-month period. Each engine operates at least monthly for preventative maintenance. Maintenance is performed according to manufacturer specifications and operational records are kept which include the date, duration, and reason for usage. Refer to Section II.B.3 for more details. 17 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. The fuel sulfur content is below the required 15ppm threshold. This was verified from a certificate of analysis and fuel tank inspection provided by the supplier. Stationary Sources [R307-210] Status: In Compliance. This area source rule is satisfied through compliance with NSPS Subpart IIII and Subpart Dc listed above. Refer to the Federal Requirements section for more details. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This area source rule is satisfied through compliance with MACT Subpart ZZZZ and Subpart CCCCCC. Refer to the Federal Requirements section for more details. Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. Refer to Conditions II.B.1.a and II.B.1.b for more details. Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: In Compliance. Refer to Condition II.B.1.f for more details. Davis and Salt Lake Counties and Ozone Nonattainment Areas: Gasoline Transfer and Storage [R307-328] Status: In Compliance. Refer to Condition II.B.1.g and II.B.1.h for more details. Degreasing [R307-335] Status: In Compliance. Three parts washers were observed on site in the maintenance shop. R307-335-4 requires the lid to be closed except during actual loading, unloading, or handling of parts. The parts washer lids were closed, had instructions posted, and used solvent was stored in a tank beneath the washer. All equipment appeared to be in good operating condition and no leaks were observed. Adhesives and Sealants [R307-342] Status: Not Applicable. R307-342-3(6) states this rule shall not apply to the use of any adhesives, sealants, adhesive primers, sealant primers, cleanup solvents, and surface preparation solvents, provided the total volume of noncomplying adhesives, sealants, primers, cleanup, and surface preparation solvents applied facility-wide does not exceed 55 gallons per rolling 12-month period. The source used 29.53 gallons for rolling 12-month period. Therefore, the source is exempt from the requirements of the rule at this time. 18 EMISSION INVENTORY: Listed before are the 2022 Actual Emissions Inventory provided from Salt Lake City Department of Airports - Salt Lake City International Airport. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN104500030-24, dated February 9, 2024 is provided. The 2023 Emissions Inventory was submitted by the required date but is still under review. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 113210.00 N/A Carbon Monoxide 59.82 11.40 Nitrogen Oxides 31.15 9.421 Particulate Matter - PM10 5.48 4.44 Particulate Matter - PM2.5 5.48 0.69 Sulfur Oxides 1.27 0.086 Volatile Organic Compounds 13.51 8.673 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Formaldehyde (CAS #50000) 256 3.74 Generic HAPs (CAS #GHAPS) 80 N/A Hexane (CAS #110543) 6520 N/A PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN104500030-24, dated February 9, 2024: In Compliance. The source appears to be well maintained and operated. Records were current and sent after the inspection via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the normal frequency. Look for an AO amendment to better reflect diesel fuel throughput for Condition II.B.1.d, item C. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form, Construction Status Notification Letter, Generator Information, Generator Operating Hours Example, Underground Storage Tank Throughput, Above Ground Storage Tank Throughput, VOCs and HAPs Usage Log, Vapor Tightness Annual Test -, STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY Page _of_ EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM Source Name: \t U4.lat :J-'1Uf'a&-b I ,4:kpcu± Street Address: ...,, (, ,A) Je,o, ,.,.,. , l>ri«- Phone: Ro\ -575-'.JLfl k Site ID: lOL\s:o Facility: Atr1oc:\:: Equipment/Process: ~0, \~ ~t/\"'!h>CS: 1 ~,:uo).. Control Equipment: 1 p-, lkt5 Emission Point: S\-o.i'<s Sky Conditions: Clear [ ] Partly Cloudy [ ] Overcast [ ] Precipitation: No [ ] Yes [ ] Wind: Direction: ___ Speed: __ _ mph Ambient Temp: °F RH: ___ % Height Relative to Observer: --- Distance From Observer: --- Condensed Water Vapor Present: No [ ] Yes [ ] Attached [ ] Detached [ ] Length of Condensed Water Vapor Plume: _____ _ Background: _____________ _ Sketch process unit: indicate observer position relative to source; indicate potential emission points and/or actual 1 emission points. 0 Ur:1w 11<1111! :.irrc•Y. • observer .Sun t Wind Emission Point with Plume (_)___, Observer Position x Observer's Signature: (;.,..,..,. ~-:, . Distrib: white-file; canary-inspector; pink-owner/operator OBSERVATION DATE: 3,/-Z.1/-Z.~ Start time: • )0 ;4.0 Stop time: \ 0 4 I, ~ c min 0 15 30 45 1 2 / 3 0 4 YJ 5 /v 6 / 7 8 9 10 11 12 to11ii:, 11--Mol'k-Peno.\ (Mr.rdA. =-fcb zoiq) COMMENTS: 1! l d.: G-~cd1u. , \)it.St\ l¼m,~l)V't t: Kt1l o,'1 11,ua 1l 6 f ,e. : \JOC. q,-J, HAPc !yarA!-t-hivi mhd 1l &,I ' cPoSoli'rt, Sb:. lt.lPlr UO:f¥ Ao1111JI t.,,,t 1tsf- ,'b,1, c.:, Mon~ {9a5ot.~ 7vtcQAT~f"\-' 1t &,1A ½ 1t,f1,2,L ex,,,;,,.. ct ""9! G.<ckvi°1tC UIW Wv wHf'tg~ 1I".5 Su~ ', 8~t(\c.'j ~c O~l(Qtt~ ~s tlt1.d,~ -~,~. Duid!Vl, &c4SM &r ~l 1tb,3k> ·, U\\-,,. S.uV D,',~I \Ju•~c.,/.,~ '3o7-3C(t. •• 1,~ \ \X.C <m iSstc1-' Qr adw,,es om sttJ I ~8: : Co,w\M\tOI\ S~h,s 4+kr Pl~,_ eMc.1 I rwxtJs c>=~o'-"Sk: e. ulQh 9011 'c 1 A 'Tr, \ 8:::, "lDI».. • l I have received a copy of thes 'ob'servations: SIGNATURE: Printed Name: Title: April 3, 2024 Bryce Bird, Director Attn: NSR Section Division of Air Quality 150 North 1950 West P.O. Box 144820 Salt Lake City, Utah 84114-4820 Re: Approval Order Equipment Notification In compliance with Utah Admin. Code 307-401-18 and Section I.8, General Provision of the Salt Lake City Department of Airports (SLCDA) Approval Order DAQE-AN104500030-24. The SLCDA is writing this letter to notify the Director of the Division of Air Quality that the following emergency generators and equipment have been installed at the airport and are operational. • Four (4) boilers each rated at 25 MMBtu/hr – Central Utility Plant • Heat Exchanger Glycol Plant • 400 kW Emergency Generator Engine - Taxiway L Deicing Facility • 550 kW Emergency Generator Engine - Runway 34L Deicing Facility • 1,500 kW Emergency Generator Engine – Central Utility Plant • 600 kW Emergency Generator Engine – Runway 16L • 600 kW Emergency Generator Engine – Gateway Building • 1,250 kW Emergency Generator Engine – South Concourse West • 1,500 kW emergency Generator Engines – Terminal (2) and South Concourse West • 2,500 kW Emergency Generator Engine – Terminal • 375 kW Emergency Generator Engine – Airport Training Facility • 500 kW Emergency Generator Engines – Parking Garage #1/#2 • 750 kW Emergency Generator – Glycol Building • 1,500 kW Emergency Generator Engine – North Concourse West #1 • 2,000 kW Emergency Generator Engines – North Concourse West #2 and #3 • 1500 kW Emergency Generator Engines – South Concourse East (3) • Diesel Aboveground Storage Tank (AST) – Fire Station 11 • Gasoline USTs – Rental Car QTA • Diesel AST – Central Utility Plant • Three (3) Diesel AST – Fire Station 11 (1) and South Support Building (2) Please call if you have any questions or need further clarification. Regards, Kevin E. Staples, P.E. LEED AP Environmental Program Manager (801) 575-3470 Caution: This is an external email. Please be cautious when clicking links or opening attachments. Connor Kijowski <ckijowski@utah.gov> RE: (EXTERNAL) Re: SLC Airport Air Quality Inspection Follow-up (2024) 4 messages Staples, Kevin <Kevin.Staples@slcgov.com>Thu, Apr 18, 2024 at 8:21 AM To: Connor Kijowski <ckijowski@utah.gov> Connor, See the attached ULSD certification. Kevin From: Connor Kijowski <ckijowski@utah.gov> Sent: Wednesday, April 3, 2024 5:40 PM To: Staples, Kevin <Kevin.Staples@slcgov.com> Subject: (EXTERNAL) Re: SLC Airport Air Quality Inspecon Follow-up (2024) Received. Thanks, Kevin. I will reach out if I have any questions. Best, Connor On Wed, Apr 3, 2024 at 2:25 PM Staples, Kevin <Kevin.Staples@slcgov.com> wrote: Good Afternoon Connor – I have attached our Compliance Tracker for your review. I have also attached our most recent UST integrity testing results. We have a message into Sapp Brothers for a recent ULSD certification but have not heard back from them, yet. I have included one from 2021for reference. I have attached the new/operational equipment letter, please let me know if I need to send this into DAQ separately. I believe that is all that was requested – I will send over the ULSD certification when our fleet managers receive their copy. 5/16/24, 2:25 PM State of Utah Mail - RE: (EXTERNAL) Re: SLC Airport Air Quality Inspection Follow-up (2024) https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1796682623022852511&simpl=msg-f:17966826230228525…1/4 Please reach out with questions or comments. Thank you. Kevin Kevin E. Staples, P.E. LEED AP Environmental Manager Salt Lake City Department of Airports (801) 575-3470 (tel) kevin.staples@slcgov.com www.slcairport.com -- Connor Kijowski Environmental Scientist | Minor Source Compliance M: (385)-245-6720 airquality.utah.gov 5/16/24, 2:25 PM State of Utah Mail - RE: (EXTERNAL) Re: SLC Airport Air Quality Inspection Follow-up (2024) https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1796682623022852511&simpl=msg-f:17966826230228525…2/4 3-5-2024 ULSD.PDF 204K Connor Kijowski <ckijowski@utah.gov>Fri, Apr 19, 2024 at 9:57 AM To: "Staples, Kevin" <Kevin.Staples@slcgov.com> Thanks, Kevin. [Quoted text hidden] Staples, Kevin <Kevin.Staples@slcgov.com>Wed, May 15, 2024 at 5:40 PM To: Connor Kijowski <ckijowski@utah.gov> Cc: "Lehosky, Jeff" <Jeff.Lehosky@slcgov.com>, "Martinez, Juan" <Juan.Martinez@slcgov.com> Hi Connor, Thanks for the feedback; the 6,000-gallon limitation is leftover when the tank was connected to our Boiler Plant, I will have it amended for our next permit. Regarding the VOCs and HAPs, I apologize, I didn’t have the final calcs in the spreadsheet (just the back up for each product used). For your information, the following are the Total VOCs and HAPS for 2022 and 2023: 2022 - HAPs (201.3 lbs – 0.100 tons); VOCs (226.74 lbs – 0.113 tons) 2023 – HAPs (137.99 lbs – 0.070 tons); VOCs (154.43 lbs – 0.077 tons) Rolling total, up to April 2024 – HAPS (79.55 lbs – 0.040 tons); VOCs (90.81 lbs – 0.045 tons) Let me know if you have further questions. Kevin From: Connor Kijowski <ckijowski@utah.gov> Sent: Wednesday, May 15, 2024 4:08 PM To: Staples, Kevin <Kevin.Staples@slcgov.com> Subject: (EXTERNAL) Re: SLC Airport Air Quality Inspecon Follow-up (2024) 5/16/24, 2:25 PM State of Utah Mail - RE: (EXTERNAL) Re: SLC Airport Air Quality Inspection Follow-up (2024) https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1796682623022852511&simpl=msg-f:17966826230228525…3/4 Caution: This is an external email. Please be cautious when clicking links or opening attachments. Hey Kevin, I am finalizing the inspection memo and wanted to double check a couple records with you based on the Approval Order (attached for your reference): 1) Condition II.B.1.d, item C: This states no more than 6,000 gallons of diesel throughput for the rolling 12-month average for the 6,000 gallon Diesel AST at Fire Station 11. The total gallons for 2023 was 7,590 gallons. However, I calculated the rolling average to 5,919 gallons for March 2023-February 2024. I would keep a close eye on this tank or consider changing the condition to better reflect its throughput. 2) Condition II.B.1.e: I am trying to find the total tons of VOCs and HAPs emitted for the 12-month period on the Compliance Tracker Form you sent me. Can you help me find these values or let me know what the values are? Thanks, Connor [Quoted text hidden] Connor Kijowski <ckijowski@utah.gov>Thu, May 16, 2024 at 8:33 AM To: "Staples, Kevin" <Kevin.Staples@slcgov.com> Cc: "Lehosky, Jeff" <Jeff.Lehosky@slcgov.com>, "Martinez, Juan" <Juan.Martinez@slcgov.com> No problem, and thanks for the clarification. I believe that answers my questions for now. Best, Connor [Quoted text hidden] 5/16/24, 2:25 PM State of Utah Mail - RE: (EXTERNAL) Re: SLC Airport Air Quality Inspection Follow-up (2024) https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1796682623022852511&simpl=msg-f:17966826230228525…4/4