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Home My WebLink AboutDAQ-2024-0045651 DAQC-CI144450001-23 Site ID 14445 (B1) MEMORANDUM TO: FILE – GLEN CANYON NRA – Hite Ranger Station THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Daniel Riddle, Environmental Scientist DATE: November 9, 2023 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, San Juan County INSPECTION DATE: June 6, 2023 SOURCE LOCATION: Highway 95, Hite Ranger Station San Juan County, UT DIRECTIONS: From Hanksville, travel approximately 50 miles south on Hwy 95. After crossing the Halls Crossing Bridge at the Colorado River, take the first right onto Hite Marina Road. The Hite Ranger Station will be on the right in about 1.5 miles. The maintenance shop is where the generators are located. SOURCE CONTACTS: Mark Trego, Maintenance Supervisor 928-614-0081 mark_trego@nps.gov OPERATING STATUS: Not in operation at the time of inspection. The generators are only used intermittently as required. PROCESS DESCRIPTION: Hite Station operates two diesel-fired generators which provides power for all the surrounding buildings and operations for the marina. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN144450001-15, dated June 16, 2015 NSPS (Part 60) IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, NSPS (Part 60) ZZZZ : National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, SOURCE EVALUATION: Name of Permittee: Permitted Location: Glen Canyon NRA – Hite Ranger Station 691 Scenic View Road, PO Box 1507 Highway 95 Hite Ranger Station Page, AZ 86040 San Juan County, UT SIC Code: 9512: (Land, Mineral, Wildlife, & Forest Conservation) 2 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: Out of Compliance. Initial performance tests for the generator engines were never completed. See section II for more details. 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 report at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Glen Canyon NRA Hite Ranger Station II.A.2 Generator Engines Number: Two (2) Rating: 180 kW - each Fuel Type: Diesel EPA Tier 3 or better II.A.3 Diesel Storage Tanks Number: One (1) Capacity: 10,000 gallons Status: In Compliance. No unapproved equipment was observed on site at the time of inspection. 3 II.B Requirements and Limitations II.B.1 Source-Wide Requirements. II.B.1.a Hite shall notify the Director in writing when the new equipment listed has been installed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn. Compliance Section. If the construction and/or installation have not been completed within 18 months from the date of this AO, the Director shall be notified in writing on the status of the construction and/or installation. At that time, the Director shall require documentation of the continuous construction and/or installation of the operation and may revoke the AO. [R307-401-8] Status: In Compliance. Notification of installation was completed during a previous inspection. II.B.1.b Visible emissions from the diesel-fired generator engines shall not exceed 20% opacity. [R307-201-3, R307-401-8] II.B.1.b.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. No visible emissions were observed during the inspection. Emissions observations were conducted according to 40 CFR 60, Appendix A, Method 9. II.B.1.c The sulfur content of any fuel oil or diesel burned in the emergency generator engines shall not exceed: 15 ppm by weight. [R307-401-8] II.B.1.c.1 The sulfur content shall be determined by ASTM Method D-4294-89 or United States EPA- approved equivalent. Certification of diesel fuels shall be either by The Canyons' own testing or test reports from the fuel marketer. [R307-401-8] Status: In Compliance. Only ULSD fuel is used at this source. See the attached fuel invoice. II.B.1.d The owner/operator shall comply with all applicable provisions of 40 CFR 63, MACT Standards Subpart A (General Provisions), 63.1 to 63.16, and Subpart ZZZZ (NESHAPs for Stationary Reciprocating Internal Combustion Engines), 63.6580 to 63.6675, for stationary diesel engines on site. To be in compliance, this source must operate in accordance with the most current version of 40 CFR 63 applicable to this source. [ 40 CFR 63 Subpart A, 40 CFR 63 Subpart ZZZZ] Status: Out of Compliance. The generators are out of compliance with 40 CFR 60 subpart IIII. See Condition II.B.1.e below for more details. II.B.1.e The owner/operator shall comply with all applicable provisions of 40 CFR 60, NSPS Standards Subpart A (General Provisions), 60.1 to 60.19, and Subpart IIII (NSPS for Stationary Compression Ignition Internal Combustion Engines), 60.4200 to 60.4219, for stationary diesel engines on site. To be in compliance, this source must operate in accordance with the most current version of 40 CFR 60 applicable to this source. [ 40 CFR 60 Subpart A, 40 CFR 60 Subpart IIII] Status: Out of Compliance. The generators are classified as emergency generators, but are being used for non-emergency purposes. No initial performance testing was completed on the generators to determine emissions. A Compliance advisory was issued on September 28, 2023 (DAQC-1027-23). The source responded on October 26, 2023. An Early Settlement Agreement was issued on November 10, 2023 (DAQC-1228-23). The source is working with a contractor to complete stack testing requirements. No further action is recommended at this time. The generators are equipped with a non-resettable hour meter. 4 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: Out of compliance. See Condition II.B.1.e above for more details. NSPS (Part 60) ZZZZ : National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: Out of compliance. See Condition II.B.1.e above for more details. 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 fuel is used at this source. An invoice was observed at the time of inspection. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Glen Canyon NRA- Hite Ranger Station on the Approval Order (AO) DAQE-AN144450001-15, dated June 16, 2015. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 7284.00 Carbon Monoxide 1.68 Nitrogen Oxides 11.12 Particulate Matter - PM10 0.34 Particulate Matter - PM2.5 0.34 Sulfur Dioxide 4.33 Volatile Organic Compounds 0.65 5 Hazardous Air Pollutant PTE lbs/yr 1,3-Butadiene (CAS #106990) 1 Acetaldehyde (CAS #75070) 678 Acrolein (CAS #107028) 99 Benzene (Including Benzene From Gasoline) (CAS #71432) 28 Formaldehyde (CAS #50000) 602 Methanol (CAS #67561) 97 PAH, Total (CAS #234) 5 Propylene[1-Propene] (CAS #115071) 76 Toluene (CAS #108883) 12 Xylenes (Isomers And Mixture) (CAS #1330207) 8 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN144450001- 15,dated June 16, 2015: Out of compliance at the time of inspection. A Compliance advisory was issued on September 28, 2023 (DAQC-1027-23). The source responded on October 26, 2023. An Early Settlement Agreement was issued on November 10, 2023 (DAQC-1228-23). No further action is recommended at this time. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Ensure stack testing has occurred. Call Mark Trego ahead of time to ensure someone will meet you at this site. NSR RECOMMENDATIONS: Need to clarify if the generators are emergency or non- emergency. ATTACHMENTS: VEO Form, ULSD invoice