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Home My WebLink AboutDAQ-2024-0079191 DAQC-CI143300002-24 Site ID: 14330 (B1) MEMORANDUM TO: FILE – ORACLE AMERICA, INC. – Utah Computer Center THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: April 9, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: February 14, 2024 SOURCE LOCATION: 6136 West 10120 South West Jordan, UT 84084 SOURCE CONTACT: Wayne Marcelis, Senior Manager, Data Center Facilities Engineering, Mobile: (801)-230-3705, wayne.marcelis@oracle.com OPERATING STATUS: In operation PROCESS DESCRIPTION: Oracle operates a secured data center, which has twelve compression ignition (CI) engines used for emergency power generation: eight 3,353 hp 2010 Detroit Diesel Tier 2, two 4,060 hp 2014 Cummins Tier 2, two 2015 Cummins Tier 2, one 5,051 hp and one 1,490 hp, and also one 2010 Clarke 157 hp Emergency Fire Pump Engine. Heating for office space is provided by two Ajax 1.5MMBtu/hr Boilers. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN143300007-24 dated March 11, 2024 40 CFR Part 60, Subpart IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, 40 CFR Part 63, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, SOURCE EVALUATION: Name of Permittee: Permitted Location: Oracle America, Inc. - Utah Computer Center P.O. Box 9004 6136 West 10120 South West Jordan, UT 84084 West Jordan, UT 840814729 SIC Code: 7374: (Computer Processing & Data Preparation & Processing Services) / : 2 SECTION I: GENERAL PROVISIONS I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.2 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.3 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.4 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.5 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.7 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] Status: In Compliance. Oracle has not made any modifications to the equipment or processes approved by this AO. Oracle did not exceed any limits set forth in this AO. Oracle maintains records for at least two years and also maintains records of maintenance activities conducted on approved equipment. Oracle confirmed that there were no breakdown of equipment resulting in an emissions event. According to the SLEIS Database, Oracle is not required to submit an Emissions Inventory Report at this time. SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Oracle Utah Computer Center Source-wide Equipment II.A.2 Emergency Generator Engines 1-8 Fuel: Diesel Maximum engine rating: Eight (8) 3,353 hp engines Model Year: 2010 NSPS Applicability: Subpart III MACT Applicability: Subpart ZZZZ 3 II.A.3 Emergency Generator Engines 9-10 Fuel: Diesel Maximum engine rating: Two (2) 4,060 hp engines Model Year: 2014 NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.4 Emergency Generator Engines 11-12 Fuel: Diesel Maximum Engine Rating: One (1) 5,051 hp engine and one (1) 1,490 hp engine Model Year: 2016 NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.5 Emergency Fire Pump Engine - new One (1) pump engine Fuel: diesel Maximum Engine Rating: 117 kW (157 hp) Model Year: 2010 NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ Status: In Compliance. There was no new or unapproved equipment observed during this inspection. SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Facility-Wide Requirement II.B.1.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engines. [R307-401-8] II.B.1.b 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.1.b.1 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. Oracle only uses diesel fuel in the Emergency Generator engines and the Emergency Fire Pump engine. According to an invoice from Rhinehart Oil, the sulfur content of the diesel is categorized as Ultra Low Sulfur Diesel. See the attachment for additional information. II.B.1.c The owner/operator shall operate emergency generator engines for electric power-producing operation, and emergency pump engine to run the water pump only during periods when electric power from the public utilities is interrupted, or for maintenance and testing of the emergency generator/pump engines and load systems. [R307-401-8] Status: In Compliance. Oracle only runs the Emergency Generator engines weekly for testing and maintenance purposes and for emergency purposes when there is a power outage. 4 II.B.1.d The owner/operator shall not operate each emergency generator or pump engine: A. More than a total of 100 hours per rolling 12-month period for planned testing and maintenance purposes, and B. More than 52 days per rolling 12-month period for planned testing and maintenance purposes. [R307-401-8, R307-410-4] Status: In Compliance. Oracle indicated compliance with these AO Conditions. The hours of operation and the days of planned testing and maintenance in a rolling 12-month from February 2023 to January 2024, are represented in the Table below: EQUIPMENT - EMERGENCY GENERATOR YEAR OF MANUFACTURE/ MANUFACTURER RATING/HP HOURS OF OPERATION IN ROLLING 12- MONTH DAYS OF OPERATION IN ROLLING 12- MONTH GEN 1 2010 -Detroit Diesel 3,353 13.76 20 GEN 2 2010 -Detroit Diesel 3,353 13.76 20 GEN 3 2010 -Detroit Diesel 3,353 13.76 20 GEN 4 2010 -Detroit Diesel 3,353 13.76 20 GEN 5 2010 -Detroit Diesel 3,353 13.76 20 GEN 6 2010-Detroit Diesel 3,353 13.76 20 GEN 7 2010-Detroit Diesel 3,353 13.76 20 GEN 8 2010-Detroit Diesel 3,353 14.08 20 GEN 9 2014 - Cummins 4,060 1.79 20 GEN 10 2014 - Cummins 4,060 1.71 21 GEN 11 2016 - Cummins 5,051 4.19 21 GEN 12 2016 - Cummins 5,051 1.79 23 EMERGENCY FIRE PUMP ENGINE 2010 - Clarke 157 17.2 42 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 documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date and time the emergency engine was used B. The duration of operation in hours C. The reason for the emergency-engine usage. [R307-401-8] Status: In Compliance. Oracle maintains records documenting the operation of each Emergency Generator engine as required by this AO Condition. II.B.1.e The owner/operator may operate the emergency generator and pump engines for emergencies including unplanned emergency maintenance and repairs. There is no time limit on the use of the engines during the emergencies. [R307-401-8] Status: In Compliance. Oracle operates the Emergency Generator and Emergency Fire Pump engines for emergency purposes including unplanned emergency maintenance and repairs as required by this AO Condition. II.B.1.f To determine the duration of engine operations, 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. All the Emergency Generators engines and the Emergency Fire Pump engine are each equipped with a non-resettable hour meter. 5 II.B.1.g The owner/operator shall not allow visible emissions from the emergency generator and pump engines to exceed 20% opacity. [R307-401-8] II.B.1.g.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. There were no visible emissions observed during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. 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. 40 CFR Part 60, Subpart IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. All 12 Emergency Generator Engines and the Emergency Fire Pump Engine are subject to 40 CFR Part 60, Subpart IIII. The planned maintenance for the Emergency Generator engines was conducted on November 3, 2023. See the attachment for additional information to include the Exhaust Emission Compliance data for the Emergency Generators. The rolling 12-month operation usage and the days of operation for planned testing and maintenance can be found in AO Condition II.B.1.d. 40 CFR Part 63, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. All 12 Emergency Generator Engines and the Emergency Fire Pump Engine are diesel-fueled, and each is equipped with a non-resettable hour meter. According to an invoice from Rhinehart Oil, the sulfur content of the diesel is categorized as Ultra Low Sulfur Diesel. See the attachment for additional information. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-203 Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. According to an invoice from Rhinehart Oil, the sulfur content of the diesel is categorized as Ultra Low Sulfur Diesel. See the attachment for additional information. R307-210 - Standards of Performance for New Stationary Sources Status: In Compliance. This area source rule is applicable to 40 CFR Part 60 Subpart IIII. See Section III for compliance with this requirement. R307-214 - National Emission Standards for Hazardous Air Pollutants Status: In Compliance. This area source rule is applicable to 40 CFR Part 63, Subpart ZZZZ. See Section III for compliance with this requirement. 6 EMISSION INVENTORY: Status – Not applicable. According to the SLEIS Database, Oracle is not required to submit an Emissions Inventory Report at this time The emissions listed below are an estimate of the total potential emissions (PTE) from Oracle America, Inc. - Utah Computer Center on the Approval Order (AO) DAQE-AN143300007-24 dated March 11, 2024. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 2229.00 Carbon Monoxide 11.98 Nitrogen Dioxide 21.92 Particulate Matter - PM10 0.68 Particulate Matter - PM2.5 0.68 Sulfur Dioxide 0.05 Volatile Organic Compounds 1.33 Hazardous Air Pollutant PTE lbs/yr Acetaldehyde (CAS #75070) 1 Acrolein (CAS #107028) 0 Benzene (Including Benzene From Gasoline) (CAS #71432) 21 Formaldehyde (CAS #50000) 2 PAH, Total (CAS #234) 6 Toluene (CAS #108883) 8 Xylenes (Isomers And Mixture) (CAS #1330207) 5 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Oracle is in compliance with the conditions of Approval Order (AO) DAQE-AN143300007-24 dated March 11, 2024. Oracle maintains good housekeeping practices. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots and safety glasses. This is a secure facility. Schedule inspection in advance. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: Applicable Supporting Documentation Included