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Home My WebLink AboutDAQ-2024-0085511 DAQC-568-24 Site ID 10436 (B1) MEMORANDUM TO: FILE – LARRY H. MILLER ARENA – DBA Vivint Smart Home Arena – Utah Jazz – Delta Center THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: May 21, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: January 31, 2024 SOURCE LOCATION: 301 West and South Temple, Salt Lake City SOURCE CONTACTS: Jamie Galileo, Vice President of Facilities: 801-577-4095 jgalileo@vivintarena.com Mark Crnich, Project Manager, 801-301-3585, mcrnich@deltacenter.com OPERATING STATUS: Operating normally at time of inspection PROCESS DESCRIPTION: The Delta Center is an indoor sports arena, the home of the Utah Jazz, and also where events such as ice shows, circuses, indoor dirt shows, and rodeos are hosted. The Delta Center is a 20,000 seat complex with center floor and several support facilities. There are three 1991 Bryan Flexible Tube Boilers; two 12,600 MBH, and one 6,000 MBH for heating and for domestic hot water. The boilers are equipped with low-NOX burners. There is one 1991 Caterpillar 3508, 750 kW diesel-fueled Emergency Generator. APPLICABLE REGULATIONS: Approval Order (AO) BAQE-199-90, dated March 27, 1990 40 CFR Part 60, Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units 40 CFR Part 63, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: / : 2 1. The Utah Jazz arena, located on the block between South Temple and 100 South, and 300 West and 400 West, shall install the boiler plant according to the information submitted in the notice of intent dated July 7, 1989. The boiler plant shall be fired on natural gas (diesel fuel standby) and shall have a heat input not to exceed 33,000,000 BTU/hr. The owner/operator shall install low-NOx burners in all boilers to minimize emissions of nitrogen oxides. Status: In Compliance. The boiler plant consists of three 1991 Bryan Flexible Tube boilers; two of which are rated at 12,600 MBH and one rated 6,000 MBH. The total heat input for the boiler plant is 31,200,000 BTU/hr. 2. Visible emissions from the boiler plant shall not exceed 0% opacity. Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. Status: In Compliance. There were no visible emissions observed from the boilers during this inspection. 3. Natural gas consumption shall not exceed 30,000,000 scf per 12 month period without prior approval in accordance with Section 3.1, UACR. Compliance with the limitation shall be determined on a rolling-monthly total. On the first day of each month a new 12-month total shall be calculated using the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. Records of consumption shall be made available to the Executive Secretary upon request, and shall include a period of two years ending with the date of the request. Consumption shall be determined by examination of natural gas fuel bills. Status: In Compliance. The rolling 12-month of natural gas consumption records from February 2023 to January 2024 indicated 22,760 dekatherms which equals 22,754,566 standard cubic feet. See the attachment for additional information. 4. The owner/operator shall use only natural gas as a fuel in the boiler plant with diesel fuel as an emergency backup fuel. Diesel fuel may be used only when natural gas service is interrupted by Mountain Fuel. If any other fuel is to be used on a permanent or regular basis, an approval order shall be required in accordance with Section 3.1, UACR. Status: In Compliance. According to the Delta Center, the boilers only operate on natural gas. 5. The sulfur content of any fuel oil burned shall not exceed 0.85 pounds of sulfur per million BTU heat input as determined by ASTM Method D-4239-83. The sulfur content shall be tested if directed by the Executive Secretary. Status: In Compliance. According to an invoice from Pilot Thomas Logistics, the sulfur content of the diesel is characterized as Ultra-Low Sulfur Diesel. See the attachment for additional information. 6. Eighteen months from the date of this approval order the Executive Secretary shall be notified in writing of the status of construction of this project unless the construction is complete and operation has commenced. Status: In Compliance. The construction of the facility was completed in 1991. The boiler plant and the diesel emergency backup generator were installed at that time. 3 7. All installations and facilities authorized by this approval order shall be adequately and properly maintained. Status: In Compliance. The Boilers and the Emergency Generator appeared to be properly maintained and operated at the time of the inspection. According to DAQC-189-13, the Emergency Generator was not required to be permitted at the time that the permit was issued. 8. The Executive Secretary shall be notified in writing upon start-up of the installation, as an initial compliance inspection is required. Status: In Compliance. According to DAQC-189-13, the initial inspection was conducted in 1994. 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, Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. There are three 1991 Bryan Flexible Tube Boilers; two 12,600 MBH, and one 6,000 MBH for heating and for domestic hot water. According to the Delta Center, the 6,000 MBH Boiler #3 runs all the time, while the two 12,600 MBH Boilers #1 and #2, serve as backup. The rolling 12-month of natural gas consumption records for the two 12,600 MBH Boilers #1 and #2 from February 2023 to January 2024 indicated 22,754,566 standard cubic feet. See the attachment for additional information. 40 CFR Part 63, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The Delta Center operates one 1991 diesel-fueled Caterpillar 3508 750 kW Emergency Generator. Compliance Assistance was provided for missing Emergency Generator usage logs from January to April 2023. Emergency Generator usage logs from May 2023 to January 2024 indicated 12.0 hours. 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. Status: In Compliance. According to an Invoice from Pilot Thomas, the sulfur content is characterized as Ultra Low Sulfur Diesel. See the attachment for additional information. 4 R307-210 - Standards of Performance for New Stationary Sources Status: In Compliance. This area source rule is applicable to 40 CFR Part 60, Subpart Dc. 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 MACT (Part 63), ZZZZ. See Section III for compliance with this requirement. EMISSION INVENTORY: The Delta Center is not required to submit an Emission Inventory Report at this time. There is also no Potential to Emit (PTE) emission calculation section noted in this AO. PREVIOUS ENFORCEMENT ACTIONS: None COMPLIANCE STATUS & RECOMMENDATIONS: The Delta Center is in compliance with the conditions of AO BAQE-199-90 dated March 27, 1990, at the time of inspection. The facility maintains good housekeeping practices. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Make sure they are maintaining the Emergency Generator Logs. RECOMMENDATION FOR NSR PERMITTING REVIEW: Consider adding the 1991 diesel-fueled Caterpillar 3508 750 kW Emergency Generator. According to DAQC-189-13, when it was installed it was not required to be permitted. ATTACHMENTS: Visible Emissions Observation Form, Rolling 12-month Natural Gas Consumption, Fuel Certification, Emergency Generator Log, Photos of Emergency Generator and Boilers