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Home My WebLink AboutDAQ-2024-0081181/23/24, 11:50 AM State of Utah Mail - RE: Potential Impact - Serious Ozone Nonattainment Area Designation (DAQP-042-23) https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1786640661594236391&simpl=msg-f:1786640661594236…1/1 Ana Williams <anawilliams@utah.gov> RE: Potential Impact - Serious Ozone Nonattainment Area Designation (DAQP-042-23) DETTENMAIER, ERIK M CIV USAF AFMC 75 CEG/CEIEA <erik.dettenmaier.1@us.af.mil>Fri, Dec 29, 2023 at 11:08 AM To: Ana Williams <anawilliams@utah.gov> Cc: "BECK, ALLISON B CTR USAF AFMC 75 CEG/CEIEA" <allison.beck.ctr@us.af.mil> Ana, In response to the ‘Serious Ozone Nonattainment Area Designation – Potential Impact to Hill Air Force Base’ letter dated May 31, 2023 Hill AFB is pleased to submitted our completed Ozone RACT anaylsis attached. Please confirm receipt at your convience. Please feel free to reach out with any questions. V/R Erik Erik Dettenmaier, Ph.D. Lead Engineer/ Hill AFB Air Quality Program Manager 801-777-0888 (com) 385-368-1042 (mobile) 75CEG/CEIE, Hill AFB, UT 84056-5003 2 attachments Hill AFB RACT Analysis 2023_Cover Letter.pdf 122K Hill AFB Ozone RACT Analysis.pdf 381K DEPARTMENT OF THE AIR FORCE 75TH CIVIL ENGINEER GROUP (AFMC) HILL AIR FORCE BASE UTAH 29 December 2023 Amanda Burton Chief, Environmental Branch 75 CEG/CEIE 7290 Weiner Street, Building 383 Hill Air Force Base UT 84056-5003 Director Utah Division of Air Quality Attention: Major New Source Review P.O. Box 144820 Salt Lake City UT 84114-4820 Dear Director Hill Air Force Base (AFB) is pleased to submit the enclosed Reasonably Available Control Technology (RACT) analysis for control of nitrogen oxides (NOx) and volatile organic compounds (VOCs) from stationary emission sources located at the installation. This submittal is in response to the letter issued by the Utah Division of Air Quality (Division) regarding the Serious Ozone Nonattainment Area (NAA) Designation – Potential Impact to Hill Air Force Base, dated 31 May 2023. In the letter, the Division identified Hill AFB as a major stationary source located in the Northern Wasatch Front Ozone NAA and requested the submittal of NOx and VOC RACT analyses of stationary sources at Hill AFB. The attached includes a top-down analysis and comprehensive summary of RACT for applicable source categories emitting NOx or VOCs. Based on the analysis, the existing emission limits, compliance, and monitoring requirements identified throughout the attached report and those contained within Title V Operating Permit #1100007004 represent or exceed RACT. If you have any questions or would like to discuss this issue further, my point of contact is Dr. Erik Dettenmaier 75 CEG/CEIEA, at (801) 777-0888 or erik.dettenmaier.1@us.af.mil. Sincerely 12/29/2023 X Amanda Burton Signed by: BURTON.AMANDA.CHRISTINE.1270023068 AMANDA BURTON, NH-III, DAF Chief, Environmental Branch Attachment: RACT Analysis Hill Air Force Base Reasonable Available Control Technology Analysis Document no: 230815094046_1e4a034f Revision no: Final Hill Air Force Base – Main Base Contract W91238-22-C-0011 75 CEG/CEIEA December 2023 Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f i Contents Acronyms and Abbreviations .......................................................................................................................................................... iii 1. Introduction .......................................................................................................................................................................... 1-1 2. Background ........................................................................................................................................................................... 2-1 3. Hill AFB Emission Unit Information ............................................................................................................................. 3-1 3.1 Sources of NOx and VOC Emissions................................................................................................................ 3-1 4. RACT Determination ......................................................................................................................................................... 4-1 4.1 Approach .................................................................................................................................................................. 4-1 4.2 RACT Analyses by Source Category ............................................................................................................... 4-1 4.2.1 Chemical Stripping .................................................................................................................................. 4-1 4.2.2 Degreasers .................................................................................................................................................. 4-2 4.2.3 External Combustion .............................................................................................................................. 4-4 4.2.4 Building 507 Melt Furnaces ................................................................................................................. 4-8 4.2.5 Fire Training ............................................................................................................................................... 4-9 4.2.6 Fuel Storage Tanks ............................................................................................................................... 4-10 4.2.7 Internal Combustion ............................................................................................................................ 4-13 4.2.8 Engine Test Stands ............................................................................................................................... 4-14 4.2.9 Landfill Gas Generators ...................................................................................................................... 4-15 4.2.10 Jet Engine Testing ............................................................................................................................... 4-16 4.2.11 Liquid Calibration Units ..................................................................................................................... 4-17 4.2.12 Miscellaneous Armaments Firing .................................................................................................. 4-18 4.2.13 Nondestructive Inspection ............................................................................................................... 4-18 4.2.14 Paint Gun Cleaning ............................................................................................................................. 4-19 4.2.15 Rocket Motor Testing ......................................................................................................................... 4-20 4.2.16 Site Remediation .................................................................................................................................. 4-21 4.2.17 Surface Coating .................................................................................................................................... 4-22 4.2.18 Waste Fuel Reclamation.................................................................................................................... 4-24 4.2.19 Waste Solvent Reclamation ............................................................................................................. 4-25 4.2.20 Wastewater Treatment ...................................................................................................................... 4-25 5. References ............................................................................................................................................................................. 5-1 Appendices Appendix A List of Approval Orders by Source Category Appendix B RBLC Search Results Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f ii Tables Table 3-1. Actual and PTE Emission (tons per year) for NOx and VOC ...................................................................... 3-1 Table 4-1. Available Control Technologies for External Combustion Sources Greater Than or Equal to 2 MMBtu and Less Than 5 MMBtu at Hill AFB ........................................................................................................ 4-4 Table 4-2. Technically Infeasible Control Technologies for External Combustion Sources Greater Than or Equal to 2 MMBtu and Less Than 5 MMBtu at Hill AFB ................................................................................. 4-5 Table 4-3. Available Control Technologies for External Combustion Sources Greater Than or Equal to 5 MMBtu at Hill AFB .......................................................................................................................................................... 4-6 Table 4-4. Technically Infeasible Control Technologies for External Combustion Sources Greater Than or Equal to 5 MMBtu at Hill AFB ................................................................................................................................... 4-7 Table 4-5. Available Control Technologies for Melt Furnaces Less Than 5 MMBtu at Hill AFB ...................... 4-8 Table 4-6. Technically Infeasible Control Technologies for Melt Furnaces Less Than 5 MMBtu at Hill AFB ........................................................................................................................................................................................... 4-9 Table 4-7. Available Control Technologies for Surface Coating Activities at Hill AFB ..................................... 4-22 Table 4-8. Technically Infeasible Control Technologies for Surface Coating at Hill AFB ................................ 4-23 Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f iii Acronyms and Abbreviations °C degree(s) Celsius °F degree(s) Fahrenheit AFB Air Force Base AO Approval Order BACM best available control measure BACT best available control technology bhp brake horsepower(s) CFR Code of Federal Regulations CI compression ignition CO carbon monoxide DoD U.S. Department of Defense EPA U.S. Environmental Protection Agency hr hour(s) ICE internal combustion engine IWTP industrial wastewater treatment plant kW kilowatt(s) LAER lowest achievable emission rate MACT maximum achievable control technology mm millimeter(s) MMBtu million British thermal unit(s) mmcf million cubic feet NAA Nonattainment Area NDI nondestructive inspection NESHAP National Emission Standards for Hazardous Air Pollutants NEW net explosive weight NOx nitrogen oxides NSPS new source performance standards PM2.5 particulate matter less than 2.5 microns in aerodynamic equivalent diameter PM10 particulate matter less than 10 microns in aerodynamic equivalent diameter ppm part(s) per million Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f iv ppmv part(s) per million by volume PTE potential to emit RACT reasonable available control technology RBLC RACT/BACT/LAER Clearinghouse SCR selective catalyst reduction SIP State Implementation Plan UDAQ Utah Division of Air Quality VOC volatile organic compound Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 1-1 1. Introduction This document provides a top down reasonable available control technology (RACT ) analysis and comprehensive summary of RACT for all permitted emission units emitting ozone precursors at Hill Air Force Base (AFB). The analysis was conducted for and in accordance with the request of the State of Utah Division of Air Quality (UDAQ), detailed in a letter dated May 31, 2023 (UDAQ, 2023). In their letter, UDAQ identified Hill AFB as a major stationary source located in the Northern Wasatch Front Ozone Nonattainment Area (NAA) (UDAQ, 2023). In anticipation of U.S. Environmental Protection Agency (EPA) redesignating the Northern Wasatch Front ozone NAA to serious classification in February 2025, UDAQ requested RACT analyses from all major stationary sources and those sources with the potential to become major sources (potential to emit of 50 tons per year or more of nitrogen oxides [NOx] or volatile organic compound [VOCs]) within the NAA in accordance with the Ozone Implementation Rule in 83 FR 62998. UDAQ will use the information presented in the RACT analyses as part of its development of Serious NAA State Implementation Plan (SIP). Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 2-1 2. Background Hill AFB provides worldwide logistics support for some of the U.S. Air Force and U.S. Department of Defense’s (DoD) most sophisticated weapon systems. Support operations include systems management, spare parts, and major maintenance, repair, rework, and modification services. Hill AFB has extensive industrial facilities for painting, paint stripping, metal plating, parts warehousing/distribution, jet engine testing, and wastewater treatment. Hill AFB is a major source for ozone precursors, NOx, and VOC. Hill AFB holds a Title V Operating Permit, Operating Permit #1100007004. Activities at the Base can be grouped in approximately 27 source categories with numerous Approval Orders (AOs) and Approval Letters that outline requirements and limitations for activities permitted within these documents. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 3-1 3. Hill AFB Emission Unit Information 3.1 Sources of NOx and VOC Emissions As noted, Hill AFB has VOC and NOx emission sources from approximately 18 of its 27 source categories. Table 3-1 provides the 2017 actual emissions and the potential to emit (PTE) emissions for these source categories that emit NOx and VOC. Each source category will be addressed in detail in the forthcoming sections. Table 3-1. Actual and PTE Emission (tons per year) for NOx and VOC 2017 Actual Emissions[a] PTE Emissions Source Category NOx VOC NOx VOC PTE Reference Chemical Stripping - 4.09 - -[b] 2020 Title V Renewal Application. 201.2 tons per 12-month period VOC emission limit meets BACT in Subpart H of the PM2.5 SIP Degreasers - 4.15 - 35.0 2020 Title V Renewal Application External Combustion 46.4 2.84 361 17.8 2020 Title V Renewal Application Fire Training 4.91E- 02 1.07E-01 2.20E- 01 2.00E-01 AO DAQE-AN101210272-20 Fuel Storage - 15.7 - 33.6 AO DAQE-AN101210260-19 Internal Combustion 33.6 14.1 401 46.1 2020 Title V Renewal Application Jet Engine Testing 11.6 1.05 64.0 24.0 2020 Title V Renewal Application Liquid Calibration Units - 1.39E-01 - 10.0 2020 Title V Renewal Application Metal Plating[c] - 3.35E-02 - 7.58E-02 2020 Title V Renewal Application Miscellaneous Armaments Firing 8.72E- 04 - 7.20E- 02 - 2020 Title V Renewal Application Nondestructive Inspection - 5.56E-01 - 4.82 2020 Title V Renewal Application and AO DAQE-AN101210275-21 Paint Gun Cleaning - 9.82 - 3.68[b] 2020 Title V Renewal Application. 201.2 tons per 12-month period VOC emission limit meets BACT in Subpart H of the PM2.5 SIP Rocket Motor Testing - 0.00 3.03E- 02 6.83E-04 2020 Title V Renewal Application Site Remediation - 7.14E-01 - 5.00 R307-401-15 Surface Coating - 32.9 - -[c] 2020 Title V Renewal Application. 201.2 tons per 12-month period VOC emission limit meets BACT in Subpart H of the PM2.5 SIP Three-Dimensional Printing[c] - 0.00 - 1.83E-01 2020 Title V Renewal Application Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 3-2 2017 Actual Emissions[a] PTE Emissions Source Category NOx VOC NOx VOC PTE Reference Waste Solvent and Fuel Reclamation - 2.07E-01 - 1.71 2020 Title V Renewal Application Wastewater Treatment - 1.95E-01 - 12.0 2020 Title V Renewal Application [a] Emissions are from the 2017 Annual Emissions Inventory submitted to UDAQ April 10, 2018 (CH2M, 2018). [b] Some or all of the PTE emissions are included in the 201.2 tons per 12-month rolling period VOC emission limit, which includes chemical stripping, painting operations, and solvent cleaning operations subject to 40 Code of Federal Regulations (CFR) Part 63 Subpart GG. [c] A RACT analysis was not provided for metal plating and three-dimensional printing source categories because emissions associated with these source categories are so low. BACT = best available control technology PM2.5 = particulate matter less than 2.5 microns in aerodynamic equivalent diameter Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-1 4. RACT Determination RACT analysis for the source categories with VOC and NOx emissions in Table 3-1 are presented in this section. 4.1 Approach The following steps as provided by UDAQ were adhered to in determining RACT for the NOX and VOC emitting emission units at Hill AFB:  Step One—Identify All Available Control Technologies. A thorough search on the EPA’s RACT/BACT/lowest achievable emission rate (LAER) Clearinghouse (RBLC) and federal/state/local new source review permits.  Step Two—Eliminate Technically Infeasible Control Technologies. Technically feasible option means a technology that is available and applicable to the permittee’s operations. This demonstration should show, based on physical, chemical, and engineering principles, that technical difficulties would preclude the successful use of the control option on the emission unit under review. Technically infeasible control options are then eliminated from further consideration in the RACT analysis.  Step Three—Rank Remaining Control Technologies Based on Capture and Control Effectiveness. This ranking should include control efficiencies, expected emission rates, or expected emissions reductions.  Step Four—Evaluate Remaining Control Technologies on Economic, Energy, and Environmental Feasibility. The factors considered while evaluating the most effective control options are energy impacts, environmental impacts, and economic impacts. If the top control option is not selected as RACT, evaluate the next most effective control option.  Step Five—Select RACT. The final step in the process is to select the RACT level control based on the analysis provided in the previous four steps. 4.2 RACT Analyses by Source Category 4.2.1 Chemical Stripping This section discusses the RACT analysis for chemical stripping activities at Hill AFB. The largest chemical stripping operation at Hill AFB consists of stripping tanks and rinse baths. Parts are soaked in heated and agitated tanks containing a mixture of methylene chloride and phenol and then moved by automatic hoist to a series of rinse baths. The tanks have floating water layers to act as barriers and minimize emissions. Cross-flow ventilation is used to vent emissions to exhaust stacks. Chemical stripping material may also be used as spot treatment on aircraft or parts. This localized treatment may occur either inside or outside the confines of a paint booth. 4.2.1.1 Step One – Identify All Available Control Technologies The RBLC identifies the following as possible VOC control technologies for chemical stripping activities at Hill AFB.  Use of immiscible solvents in tanks (for example, cover layer of water in tank)  Use of solvent application techniques that minimize emissions while providing high transfer efficiency  Good work practices, including proper handling of solvent and solvent-laden rags 4.2.1.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-2 4.2.1.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.1.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.1.5 Step Five – Select RACT Use of immiscible solvents in tanks and compliance with maximum achievable control technology (MACT ) standards, voluntary VOC limitations, and good work practices are identified RACT for depainting and chemical stripping. Cleaning operations and depainting (chemical) operations subject to National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart GG also comply with the MACT standards set forth within these regulations. Hill AFB also complies with the RACT standards within the control technologies guidelines document Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations (EPA, 1997) for activities relating to the cleaning of nonaerospace vehicles or components. Compliance with these requirements have been identified as BACT in previous permitting actions. This voluntary RACT application satisfies the requirements of BACT for controls of VOC emissions for the cleaning of nonaerospace vehicles and components. In addition, Hill AFB complies with the following pre-approved BACT determination conditions, which incorporate flexibility provisions, for chemical stripping, as detailed in DAQE-AN0101210200A-09:  VOC emissions shall not exceed 201.2 tons per rolling 12-month period from painting equipment or operations, solvent uses associated with paint booths, and chemical depainting operations that fall into categories A, B, C, D, E, F, and G at Hill AFB main Base and Little Mountain sites (Categories: A: Cleaning Operations Subject to NESHAP GG, B: Primer and Topcoat Application Operations Subject to NESHAP GG, C: Depainting (Chemical) Operations Subject to NESHAP GG, D: Specialty Coating Application Operations to Aerospace Vehicles or Components, E: Surface Coating Application Operations not Subject to NESHAP GG, F: Specialty Coating Application Operations to non-Aerospace Vehicles or Components, G: Depainting (Chemical) operations not Subject to NESHAP GG.) 4.2.2 Degreasers This section discusses the RACT analysis for degreasers at Hill AFB. Both cold cleaning and vapor degreasing methods are used at Hill AFB. Cold cleaning is the most commonly used degreasing method. The process involves manually cleaning and degreasing small parts in a solvent bath. Each part is placed in the bath, soaked, removed, and allowed to dry. Where feasible, Hill AFB uses aqueous-based degreasing agents. Vapor degreasing typically uses heated solvent vapors in a closed cabinet to clean metal components. Condensation coils are used to condense solvent vapors. Metal parts are suspended above the heated solvent and solvent vapors are allowed to condense on the metal parts. The condensed solvents are then returned to the tank. 4.2.2.1 Step One – Identify All Available Control Technologies The RBLC identifies the following as possible VOC control technologies for various source categories at Hill AFB.  Use of tight-fitting cover when equipment is not in use to reduce VOC emissions  Good operating and maintenance practices to minimize evaporative losses Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-3 4.2.2.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.2.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.2.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.2.5 Step Five – Select RACT Use of tight-fitting covers and good operating and maintenance practices to minimize emissions is considered to be BACT for degreasers. In addition, compliance with Utah Administrative Code R307-335-4 and -5 is considered to be a best available control measure (BACM) for degreasers. Furthermore, Hill AFB complies with the pre-approved BACT determination, as detailed in DAQE-AN101210228-12, for flexibility provisions for the following types of degreasers:  Open Top Vapor Degreasing (non-NESHAP) operations: - Units to be equipped with a cover that can be opened and closed without disturbing the vapor zone. Covers are to be kept closed except when processing workloads through degreaser. - One of the control devices listed within the permit will be installed. - Solvent carryout will be minimized. - Parts will be sprayed only in or below the vapor level. - Ventilation fans will not be used near degreaser opening, nor provide exhaust ventilation exceeding 20 cubic meters per minute per square meter (65 cubic feet per minute per square foot) in degreaser open area, unless necessary to meet state and federal occupational, health, and safety requirements. The exhaust ventilation flow will be measured using EPA Reference Methods 1 and 2 of 40 CFR Part 60, or by EPA-approved equivalent state methods. - Porous or absorbent materials, such as cloth, leather, wood, or rope will not be degreased. - Workloads will not be allowed to occupy more than half the degreaser’s open top area. - Solvent will not be visually detectable in water existing the water separator. - Safety switches will be installed as detailed within the permit. - Control device specified will meet the applicable requirements of R307-335-4 and -5.  Modified Immersion Cold Cleaners (non-NESHAP) operations: - Waste or used solvent to be stored in covered containers. Waste solvents or waste materials that contain solvents will be disposed of by recycling, reclaiming, by incineration in an incinerator approved to process hazardous materials, or by an alternate means approved by the Director. - Hill AFB will drain solvent-cleaned parts for 15 seconds or until dripping has stopped, whichever is longer. Parts having cavities or blind holes will be tipped or rotated while draining. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-4 - If the solvent volatility is greater than 4.3 kilopascals (33 millimeters [mm] of mercury or 0.6 pound per square inch) measured at 38 degrees Celsius (°C [100°F]), or if solvent is heated above 50°C (120°F), then one of the listed control devices will be used:  A cover, which will remain closed except during actual loading, unloading, or handling of parts in cleaner.  Solvent spray, which will be a solid fluid stream at a pressure that does not cause excessive splashing and may not be a fine, atomized, or shower-type spray.  Modified Remote Reservoir Cold Cleaning (non-NESHAP) operations: - Waste or used solvent to be stored in covered containers. Waste solvents or waste materials that contain solvents will be disposed of by recycling, reclaiming, by incineration in an incinerator approved to process hazardous materials, or by an alternate means approved by the Director. - Hill AFB will drain solvent -cleaned parts for 15 seconds or until dripping has stopped, whichever is longer. Parts having cavities or blind holes will be tipped or rotated while draining. - Hill AFB’s remote reservoir batch cold solvent cleaning machines will employ a tightly fitting cover over the solvent sump that will be closed at all times except during the cleaning of parts. - Tanks, containers, and all associated equipment will be maintained in good operating condition and leaks will be repaired immediately or the degreaser will be shut down. - If used, the solvent spray will be a solid fluid stream at a pressure that does not cause excessive splashing and may not be a fine, atomized, or shower-type spray. 4.2.3 External Combustion This section discusses the RACT analysis for external combustion units at Hill AFB. External combustion units located at Hill AFB range from industrial natural gas-fired boilers (capable of operating with fuel oil No. 2 as an alternative fuel) to common residential hot-water heaters. These boilers provide both process steam and comfort heat. Typical boiler operations consist of heating a closed loop water system with make-up water feed and chemical addition to prevent biological growth and reduce scaling. Air and fuel is fed into a firing chamber and combusted, heating the water to produce steam for process and space heating purposes. 4.2.3.1 Units Greater Than or Equal to 2 and Less Than 5 MMBtu 4.2.3.1.1 Step One – Identify All Available Control Technologies The RBLC identifies the following as possible NOx and VOC control technologies for external combustion sources, greater than 2 million British thermal units (MMBtu) and less than 5 MMBTU at Hill AFB, including boilers, process heaters, air handlers, and curing and burnout ovens used to burn off coating and debris from metal parts. Available control technologies are provided in Table 4-1. Table 4-1. Available Control Technologies for External Combustion Sources Greater Than or Equal to 2 MMBtu and Less Than 5 MMBtu at Hill AFB Source Category Control Technology Description Pollutants Controlled External Combustion Updated NOx Burners (Low/Ultra-low NOx) Natural gas burner designed to reduce NOx emission generation to the lowest rate achievable (30 ppmv for low-NOx burner and 9 ppmv for ultra-low NOx burner). NOx External Combustion Flue Gas Recirculation A portion of cool exhaust gases are recirculated back to the combustion zone to lower the flame temperature and reduce NOx formation. NOx Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-5 Source Category Control Technology Description Pollutants Controlled External Combustion Good Combustion Practices/NSPS and NESHAP Standards Following the manufacturer’s recommendations for fuel and air mixture and burner operation and complying with applicable NSPS and NESHAP standards. NOx and VOC External Combustion Use of Only Pipeline Quality Natural Gas as Fuel Natural gas combustion, except during curtailment, when combined with good combustion practices generates less emissions than other fuels. NOx and VOC External Combustion Operating Limitations Limiting the operation of a source where practical to eliminate excess emissions. NOx and VOC Note: The control technologies identified are consistent with those presented in the BACT determinations prepared and submitted as a part of recent Hill AFB permitting actions. NSPS = new source performance standards ppmv = part(s) per million by volume 4.2.3.1.2 Step Two – Eliminate Technically Infeasible Controls Table 4-2 lists the control technologies not technically feasible for external combustion sources greater than or equal to 2 MMBtu and less than 5 MMBTU at Hill AFB. Table 4-2. Technically Infeasible Control Technologies for External Combustion Sources Greater Than or Equal to 2 MMBtu and Less Than 5 MMBtu at Hill AFB Source Category Control Technology Reasons for Being Technically Infeasible External Combustion Use of Only Pipeline Quality Natural Gas as Fuel The sole use of only pipeline quality natural gas is also infeasible because the Air Force’s readi ness requirements specified in Air Force Manual 32-1068 (United States Air Force [USAF], 2020) dictate that the boilers must have an alternate fuel source for redundancy to continue the mission in times of fuel shortages or curtailment. For this reason, use of only pipeline quality natural gas is not technically feasible, however the units will run on natural gas except in times of curtailment or shortage. External Combustion Operating Limitations Limiting the allowable hours of operation could undermine the mission of the facility and compromise national security. Therefore, runtime limitations are not technically feasible. 4.2.3.1.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all remaining control technologies are technically feasible and currently implemented at Hill AFB. 4.2.3.1.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable as all remaining technically feasible control technologies identified are already implemented at Hill AFB. For those external combustion units that are not already equipped with low-NOx or ultra-low NOx burners, those units did meet BACT when they were permitted. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-6 4.2.3.1.5 Step Five – Select RACT The use of low-NOx burners, ultra-low NOx burners, flue gas recirculation, pipeline quality natural gas, and good combustion practices meet or exceed RACT for external combustion units greater than or equal to 2 MMBtu and less than 5 MMBtu. In addition, new, reconstructed, or modified Hill AFB boilers comply with Utah Rule R307-315, NOx Emissions for Natural Gas-Fired Boilers, Steam Generators, and Process Heaters, 2.5–5 MMBtu. For these units, these rules represent RACT. 4.2.3.2 Units Greater Than or Equal to 5 MMBtu 4.2.3.2.1 Step One – Identify All Available Control Technologies The RBLC identifies the following as possible NOx and VOC control technologies for external combustion sources greater than or equal to 5 MMBtu at Hill AFB. Available control technologies are provided in Table 4-3. Table 4-3. Available Control Technologies for External Combustion Sources Greater Than or Equal to 5 MMBtu at Hill AFB Source Category Control Technology Description Pollutants Controlled External Combustion Updated NOx Burners (Low/Ultra-low NOx) Natural gas burner designed to reduce NOx emission generation to the lowest rate achievable (30 ppmv for low- NOx burner and 9 ppmv for ultra-low NOx burner). NOx External Combustion Flue Gas Recirculation A portion of cool exhaust gases are recirculated back to the combustion zone to lower the flame temperature and reduce NOx formation. NOx External Combustion Good Combustion Practices/NSPS and NESHAP Standards Following the manufacturer’s recommendations for fuel and air mixture and burner operation and complying with applicable NSPS and NESHAP standards. NOx and VOC External Combustion Use of Only Pipeline Quality Natural Gas as Fuel Natural gas combustion, except during curtailment, when combined with good combustion practices generates less emissions than other fuels. NOx and VOC External Combustion Operating Limitations Limiting the operation of a source where practical to eliminate excess emissions. NOx and VOC Note: The control technologies identified are consistent with those presented in the BACT determinations prepared and submitted as a part of recent Hill AFB permitting actions. 4.2.3.2.2 Step Two – Eliminate Technically Infeasible Controls Table 4-4 lists the control technologies not technically feasible for operations at Hill AFB. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-7 Table 4-4. Technically Infeasible Control Technologies for External Combustion Sources Greater Than or Equal to 5 MMBtu at Hill AFB Source Category Control Technology Reasons for Being Technically Infeasible External Combustion Use of Only Pipeline Quality Natural Gas as Fuel The sole use of only pipeline quality natural gas is also infeasible because the Air Forces’ readiness requirements specified in Air Force Manual 32-1068 (USAF, 2020) dictate that the boilers must have an alternate fuel source for redundancy to continue the mission in times of fuel shortages or curtailment. For this reason, use of only pipeline quality natural gas is not technically feasible; however the units will run on natural gas except in times of curtailment or shortage. External Combustion Operating Limitations Limiting the allowable hours of operation could undermine the mission of the facility and compromise national security. Therefore, runtime limitations are not technically feasible. hr = hour(s) 4.2.3.2.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all remaining control technologies are technically feasible and currently implemented at Hill AFB. 4.2.3.2.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all remaining technically feasible control technologies identified are already implemented at Hill AFB. 4.2.3.2.5 Step Five – Select RACT The use of low-NOx burners, ultra-low NOx burners, flue gas recirculation, pipeline quality natural gas, and good combustion practices meets or exceeds RACT for external combustion units greater than or equal to 5 MMBtu. In addition, new, reconstructed, or modified Hill AFB boilers comply with R307-316, NOx Emissions for Natural Gas-Fired Boilers, Steam Generator, and Process Heaters, greater than 5 MMBtu. For these units, these rules represent RACT. In addition, Hill AFB is to meet the following pre-approved RACT/BACT determination for air handlers in accordance with DAQE-AN101210237-15:  The combined consumption of natural gas in the air handling equipment rated greater than or equal to 5 MMBtu/hr and less than or equal to 20 MMBtu/hr shall not exceed 450 million cubic feet (mmcf) of natural gas consumed per rolling 12-month period. Hill AFB is to also meet the following pre-approved RACT/BACT determination for flexibility provisions for air handlers in accordance with DAQE-AN101210237-15:  Hill AFB is allowed to add or modify any air handler rated greater than or equal to 5 MMBtu/hr and less than or equal to 20 MMBtu/hr equipped with a low-NOx burner, provided that each of the following conditions are met: - The proposed addition or modification does not cause an increase in the currently established Basewide limit of 450 mmcf of natural gas consumed per rolling 12-month period for air handlers rated greater than or equal to 5 MMBtu/hr and less than or equal to 20 MMBtu/hr. - The new or modified equipment must meet the requirements listed in the permit as BACT. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-8 For boilers, Hill AFB is to meet the following pre-approved RACT/BACT determination for boilers in accordance with DAQE -AN101210245-16:  The combined heat input to all boilers as defined in the permit (except those classified as exempt and grandfathered) shall not exceed 2.76E12 BTU per rolling 12-month period.  Visible emissions shall be no greater than 10% opacity for all boilers (except those classified as exempt and grandfathered) as defined in the permit.  For boilers with capacities of 50 MMBtu per hour or greater, emissions of NOx shall not exceed the product of 0.09 pound/MMBtu rated capacity of the unit in MMBtu/hr. All grandfathered boiler units at Hill AFB are currently in the process of being replaced. 4.2.4 Building 507 Melt Furnaces This section discusses the RACT analysis for the metal melt furnaces at Hill AFB. Hill AFB uses three natural gas-fired metal melt furnaces each less than 5 MMBtu to cast lead, aluminum, brass (zinc/copper alloy), and kirksite (lead/zinc/copper alloy) parts. 4.2.4.1 Step One – Identify All Available Control Technologies The RBLC identifies possible NOx and VOC control technologies for melt furnaces less than 5 MMBtu at Hill AFB. Available control technologies are provided in Table 4-5. Table 4-5. Available Control Technologies for Melt Furnaces Less Than 5 MMBtu at Hill AFB Source Category Control Technology Description Pollutants Controlled External Combustion Selective Catalytic Reduction A catalyst and an injection of a reductant are used to convert NOx in the exhaust to water and nitrogen. The use of a catalyst allows for the redox reaction to take place at exhaust temperatures between 440 and 840°F. NOx External Combustion Selective Noncatalytic Reduction An injection of a reductant without the aid of a catalyst is used to convert NOx in the exhaust to water and nitrogen. Exhaust temperatures must range from 1,400 to 2,000°F to be effective. NOx External Combustion Updated NOx Burners (Low/Ultra-low NOx) Natural gas burner designed to reduce NOx emission generation to the lowest rate achievable (30 ppmv for low-NOx burner and 9 ppmv for ultra-low NOx burner). NOx External Combustion Flue Gas Recirculation A portion of cool exhaust gases are recirculated back to the combustion zone to lower the flame temperature and reduce NOx formation. NOx External Combustion Good Combustion Practices/NSPS and NESHAP Standards Following the manufacturer’s recommendations for fuel and air mixture and burner operation and complying with applicable NSPS and NESHAP standards. NOx and VOC External Combustion Use of Only Pipeline Quality Natural Gas as Fuel Natural gas combustion, except during curtailment, when combined with good combustion practices generates less emissions than other fuels. NOx and VOC External Combustion Operating Limitations Limiting the operation of a source where practical to eliminate excess emissions. NOx and VOC 4.2.4.2 Step Two – Eliminate Technically Infeasible Controls Table 4-6 lists the control technologies not technically feasible for melt furnaces less than 5 MMBtu at Hill AFB. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-9 Table 4-6. Technically Infeasible Control Technologies for Melt Furnaces Less Than 5 MMBtu at Hill AFB Source Category Control Technology Reasons for Being Technically Infeasible External Combustion Selective Catalytic Reduction Selective catalytic reduction requires exhaust gas temperature in a range of 500 to 1,200°F (Cleaver Brooks, 2010). Application of an SCR on a melt furnace with limited hours of operation is technically infeasible. External Combustion Selective Noncatalytic Reduction The Boiler Emissions Guide (Cleaver Brooks, 2010) indicates that post combustion methods such as selective noncatalytic reduction are generally not used on boilers with inputs of less than 100 MMBtu/hr. Hill AFB does not own or operate any boilers larger than 100 MMB tu/hr. External Combustion Use of Only Pipeline Quality Natural Gas as Fuel The sole use of only pipeline quality natural gas is also infeasible because the Air Force’s readi ness requirements specified in Air Force Manual 32-1068 (U SAF, 2020) dictate that the boilers must have an alternate fuel source for redundancy to continue the mission in times of fuel shortages or curtailment. For this reason, use of only pipeline quality natural gas is not technically feasible. External Combustion Operating Limitations Limiting the allowable hours of operation could undermine the mission of the facility and compromise national security. Therefore, runtime limitations are not technically feasible. SCR = selective catalyst reduction 4.2.4.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all remaining control technologies are technically feasible and currently implemented at Hill AFB. 4.2.4.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all remaining control technologies identified are feasible and already implemented at Hill AFB. The metal melt furnaces at Hill AFB met BACT at the time they were installed. The units have limited hours of operation and modification of the existing units to install flue gas recirculation or low -NOx or ultra-low NOx burners is not a cost- or technically effective option. 4.2.4.5 Step Five – Select RACT The use of good combustion practices meet or exceed RACT for melt furnaces less than 5 MMBtu. In addition, Hill AFB complies with the following pre-approved RACT/BACT determination fuel throughput limitations, as detailed in DAQE-AN0101210189-08:  Natural gas consumption from melt furnaces shall be no greater than 0.289 million standard cubic foot per calendar year combined total for all melt furnaces. 4.2.5 Fire Training This section discusses the RACT analysis for fire training activities at Hill AFB. Hill AFB conducts fire training exercises and drills at a training facility that allows open-area fires. The fuels used for fire training can include propane, dry wood, smoke fluid, and automobiles. 4.2.5.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies possible VOC and NOx control technologies for fire training activities at Hill AFB. It should be noted that there are no data available for firefighter training in Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-10 the RBL C, so similar process types were reviewed to evaluate processes similar to firefighter training. However, there were no BACT determinations for such similar combustion sources. Available control technologies currently in use at Hill AFB to control VOC and NOx emissions are the following:  Good operating procedures and combustion practices: Proper operation of firefighting equipment and use of good combustion practices reduce emissions.  Fuel limitations: Limiting fuel usage to the most favorable fuel type for a particular combustion unit. For example, propane is the fuel of use at the aircraft training facility, and the low sulfur content of propane reduces the potential for sulfur oxide (SOx) emissions, thus resulting in a lower potential for aggregation of sulfur containing compounds and in lower PM2.5 emissions. 4.2.5.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.5.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.5.4 Step Four – Evaluate Most Effective Control and Document Results All technically feasible control technologies identified are already implemented at Hill AFB. 4.2.5.5 Step Five – Select RACT Use of good operating procedures, combustion practices, and fuel limitations exceed RACT and constitute BACT for firefighter training activities. In addition, Hill AFB complies with the following pre-approved RACT/BACT determination fuel throughput limitations, as detailed in DAQE-AN101210272-20:  Fuel and material consumption shall not exceed the following limits: - 30,000 gallons of propane per rolling 12-month period - 18,000 pounds class A materials per rolling 12-month period - 8 automobiles per rolling 12-month period - 20 gallons of liquid smoke per rolling 12-month period 4.2.6 Fuel Storage Tanks This section discusses the RACT analysis for fuel storage tanks at Hill AFB. Hill AFB uses and stores jet A, fuel oil No. 2, and gasoline fuels in aboveground storage tanks and underground storage tanks, ranging in capacity from less than 500 gallons to greater than 2 million gallons. The fuel is used to fuel aircraft, power emergency generators, fuel personal and government vehicles, and fuel other equipment. Emissions from this category result from storage tank standing and working losses, including those resulting from dispensing facilities. 4.2.6.1 Tanks less than 500 Gallons Those tanks at Hill AFB less than 500 gallons are considered to be small fuel storage tanks and are not subject to permitting or notification requirements as detailed in DAQE -AN101210288-23. Therefore, these tanks are not included as a part of this RACT analysis. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-11 4.2.6.2 Tanks Greater than or Equal to 500 Gallons and less than 19,812 Gallons 4.2.6.2.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for various source categories at Hill AFB:  Good design and operating practices  Use of submerged fill  Fixed roof tanks  Low vapor pressure fuel  White or aluminum exterior surfaces  Use of Stage 1 Vapor Recovery Systems 4.2.6.2.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed above for control of emissions are technically feasible. 4.2.6.2.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.6.2.4 Step Four – Evaluate Most Effective Control and Document Results All technically feasible control technologies identified are already implemented at Hill AFB. 4.2.6.2.5 Step Five – Select RACT Use of Stage I vapor recovery, fixed roof tanks equipped with a submerged fill pipe, tanks with uninsulated exterior surfaces exposed to the sun painted white, beige/sandstone aluminum or other DoD-mandated color, and good design and operating practices is considered to meet or exceed RACT for tanks greater than or equal to 500 gallons and less than 19,812 gallons. In addition, Hill AFB complies with the following pre-approved RACT/BACT determination fuel throughput limitations for fuel storage tanks, as detailed in DAQE-AN101210288-23:  Aboveground and underground fuel storage tanks with a capacity greater than or equal to 500 gallons and less than or equal to 19,812 gallons, the total combined capacity of in-service fuel storage tanks shall not exceed the following limits: - 770,000 gallons combined capacity for diesel tanks - 123,000 gallons combined capacity for gasoline tanks - 600,000 gallons combined capacity for jet fuel tanks  Flexibility provisions – Hill AFB is allowed to add or modify an aboveground or underground fuel storage tank, provided the fuel storage capacity is less than 19,812 gallons and the capacity limitations are not exceeded. The new or modified fuel storage tanks shall be horizontal fixed roof tanks or better with submerged fill. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-12 4.2.6.3 Tanks Greater than or Equal to 19,812 Gallons 4.2.6.3.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for various source categories at Hill AFB.  Good design and operating practices  Use of submerged fill  Fixed roof tanks less than 25,000 gallons  Low vapor pressure fuel (below 40 CFR Part 60 Subpart Kb threshold)  White or aluminum exterior surfaces  Use of Stage 1 Vapor Recovery Systems  Internal or external floating roof for tanks greater than or equal to 25,000 gallons  Dual rim seals for tanks greater than or equal to 25,000 gallons  Tank venting to a control device for tanks greater than or equal to 25,000 gallons 4.2.6.3.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.6.3.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.6.3.4 Step Four – Evaluate Most Effective Control and Document Result Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.6.3.5 Step Five – Select RACT Use of Stage I vapor recovery, low vapor pressure fuel (where possible), fixed roof tanks equipped with a submerged fill pipe, tanks with uninsulated exterior surfaces exposed to the sun painted white, beige/sandstone aluminum or other DoD-mandated color, and good design and operating practices are considered to exceed RACT and meet BACT for tanks greater than or equal to 19,812 gallons and less than 25,000 gallons. For tanks greater than or equal to 25,000 gallons, use of internal or external floating roofs, low vapor pressure fuel (where possible), and uninsulated exterior surfaces exposed to the sun will be white, beige/sandstone, aluminum, or other DoD-mandated color; dual rim seals; and good design and operating practices are considered to exceed RACT and meet BACT for tanks greater than or equal to 25,000 gallons. Hill AFB will also comply with NSPS Subpart Kb requirements, when applicable. In addition, Hill AFB will comply with the applicable requirements of R307-328, Gasoline Transfer and Storage. In addition, Hill AFB complies with the following pre-approved RACT/BACT determination fuel throughput limitations for fuel storage tanks, as detailed in DAQE-AN101210288-23:  Aboveground and underground fuel storage tanks with a capacity greater than 19,812 gallons, the total combined capacity of in-service fuel storage tanks shall not exceed the following limits: - 7,500,000 gallons combined capacity for diesel tanks - 642,000 gallons combined capacity for gasoline tanks - 102,000,000 gallons combined capacity for jet fuel tanks Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-13 4.2.7 Internal Combustion This section discusses the RACT analysis for internal combustion units at Hill AFB. Internal combustion processes include primary and emergency reciprocating internal combustion compression ignition (CI) engines, spark reciprocating internal combustion engines (ICEs) and internal combustion and turbine engine test stands. The primary fuels used for these sources include fuel oil No. 2, natural gas, landfill gas, and gasoline. 4.2.7.1 Units Less Than or Equal to 1,700 kW 4.2.7.1.1 Step One – Identify All Available Control Technologies The RBLC was reviewed to identify possible VOC and NOx control technologies for the ICEs less than 1,700 kilowatts (kW) at Hill AFB. In addition to the RBLC, other sources including control equipment vendors, published literature, and previous UDAQ BACT determinations for diesel-fired emergency generators were reviewed. The following is a list of control technologies identified:  Good combustion, operating, and maintenance practices  SCR for nonemergency units  Use of diesel fuel with a fuel sulfur content no greater than 15 parts per million (ppm) (0.0015%) by weight  Limiting hours of operation in accordance with NSPS Subpart IIII to less than 500 hours annual for readiness (maintenance and testing) for emergency generators  Use of a tier-certified engine 4.2.7.1.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.7.1.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.7.1.4 Step Four – Evaluate Most Effective Control and Document Results Based on the review of control technologies, all of the control technologies listed are technically feasible; however, it is not economically feasible or in some applications practical to retrofit existing Hill AFB generators with SCRs. While selective catalytic reduction is designed to reduce NOx emissions for diesel generators, retrofitting a generator may affect the performance and power output of the engine. In some applications at Hill AFB, this may present significant issues and impair the mission. Furthermore, generators in use at Hill AFB of this size are for emergency use only and SCRs are not considered technically feasible for emergency units. All generators at Hill AFB do meet BACT when installed, and all technically feasible control technologies identified, are already implemented at Hill AFB. 4.2.7.1.5 Step Five – Select RACT Use of good combustion, maintenance, and operating practices; ultra-low sulfur diesel (0.0015% by weight); a limit on hours of operation for maintenance and testing operations; and use of a tier-certified engine are considered to meet or exceed RACT for ICEs less than or equal to 1,700 kW. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-14 In addition, Hill AFB complies with the following pre-approved RACT/BACT determination for flexibility provisions for emergency generators in accordance with DAQE-AN0121175-06:  The permittee shall not exceed 8,670 combined hours of maintenance-related operations per rolling 12-month period for all the limited use power supply units combined. No single limited use power supply unit shall exceed 500 hours of maintenance-related operation per rolling 12-month period unless otherwise specified.  Visible emissions from diesel-fired limited use power supply units shall be no greater than 20% opacity except for a period not exceeding 3 minutes in any hour. 4.2.7.2 Units Larger Than 1,700 kW 4.2.7.2.1 Step One – Identify All Available Control Technologies The RBLC was reviewed to identify possible VOC and NOx control technologies for the ICEs greater than 1,700 kW at Hill AFB. In addition to the RBLC, other sources including control equipment vendors, published literature, and previous UDAQ BACT determinations for diesel-fired emergency generators were reviewed. The following is a list of control technologies identified:  Good combustion, operating, and maintenance practices  Use of diesel fuel with a fuel sulfur content no greater than 15 ppm (0.0015%) by weight  Limiting hours of operation in accordance with NSPS Subpart IIII to less than 500 hours annual for readiness (maintenance and testing) for emergency generators  Use of a tier-certified engine  SCR for nonemergency units 4.2.7.2.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible; however, SCR is not technically feasible for those emergency units greater than 1,700 kW. 4.2.7.2.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all remaining control technologies are technically feasible and currently implemented at Hill AFB. 4.2.7.2.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all remaining technically feasible control technologies identified are already implemented at Hill AFB. 4.2.7.2.5 Step Five – Select RACT Use of good combustion, maintenance, and operating practices; ultra -low sulfur diesel (0.0015% by weight); a limit on hours of operation for maintenance and testing operations; and use of a tier-certified engine are considered to meet or exceed RACT for ICEs greater than 1,700 kW. 4.2.8 Engine Test Stands Hill AFB does have engine load test stands for load testing and testing of generators that have come into Hill AFB for rework. These activities are permitted in DAQE -AN101210261-18. The engines coming in for rework are field-ready deployable assets and are used in the field and not on Base at Hill AFB. Furthermore, in most instances, the engines coming in for work have a National Security exemption and are used to support the mission. As such, these engine test stands are not discussed in this RACT analysis. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-15 4.2.9 Landfill Gas Generators 4.2.9.1 Step One – Identify All Available Control Technologies The RBLC identifies the following as possible VOC and NOx control technologies for the ICEs less than 1,700 kW combusting landfill gas at Hill AFB.  Good combustion, operating, and maintenance practices  SCR for nonemergency units  Use of diesel fuel with a fuel sulfur content no greater than 15 ppm (0.0015%) by weight  Limiting hours of operation in accordance with NSPS Subpart IIII to less than 500 hours annual for readiness (maintenance and testing) for emergency generators  Use of a tier-certified engine 4.2.9.2 Step Two – Eliminate Technically Infeasible Controls All identified technologies listed in Step One for control of emissions are technically feasible with the exception of SCR. This technology is designed to reduce NOx emission from diesel generators by about 85%. This technology does not perform well with variable fuel sources and poisoning of catalysts frequently occurs when halogenated compounds are present in the fuel source. Halogenated compounds are often present in the landfill gas, and thus SCR is not technically feasible for use on these engines. 4.2.9.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all remaining control technologies are technically feasible and currently implemented at Hill AFB. 4.2.9.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all remaining technically feasible control technologies identified are already implemented at Hill AFB. 4.2.9.5 Step Five – Select RACT Use of good combustion, maintenance, and operating practices, including operation at high excess air for lean-burn engines, which results in lower combustion temperatures and thus lower NOx emissions, and a limit on hours of operation for maintenance and testing operations is considered to meet or exceed RACT for landfill gas ICEs less than 1,700 kW. In addition, based on the review of control technologies and the pre-approved BACT as documented in DAQE-AN101210251-17, Hill AFB has determined the following meets or exceeds RACT for landfill gas ICEs less than 1,700 kW:  Good combustion, maintenance, and operating practices  Lean-burn ICEs designed to be operated at high excess air; thus resulting in lower combustion temperatures and lower NOx emissions.  Visible emissions limitation  Compliance with 40 CFR Part 60 Subpart JJJJ ‘Standards of Performance for Stationary Spark Ignition Internal Combustion Engines’ requirements  Compliance with 40 CFR Part 63 Subpart ZZZZ ‘National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines’ requirements Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-16 Hill AFB complies with the following pre-approved RACT/BACT determination emission limitations for landfill gas generators in accordance with DAQE-AN101210251-17:  Visible emissions shall be no greater than 10% opacity.  Emissions of carbon monoxide (CO) shall be no greater than 3.3 grams per brake horsepower (bhp)-hr from each of the 814 bhp and 1,148 bhp lean-burn engines. Emissions of CO shall be no greater than 2.5 grams/bhp-hr from the 1,350 bhp lean-burn engine.  Emissions of NOx shall be no greater than 2 grams/bhp-hr from each of the 814 bhp and 1,148 bhp lean-burn engines. Emissions of NOx shall be no greater than 1 grams/bhp-hr from the 1,350 bhp lean-burn engine.  Permittee shall ensure that 10% or more of the gross heat input to the affected emission units on an annual basis shall be from the combustion of landfill gas. In addition, the permittee shall operate the affected emission units in a manner that reasonably minimizes hazard air pollutant emissions. 4.2.10 Jet Engine Testing This section discusses the RACT analysis for jet engine testing activities at Hill AFB. As a part of aircraft rework activities, Hill AFB has to test jet engines. It should be noted that these are mobile sources and add-on controls are not feasible for said sources. The engine testing facilities contain noise-control systems and an exhaust system that vents jet (gas turbine) engine exhaust directly to the atmosphere. Engine tests range in duration from brief starts to several hours. Each test cycle consists of operating the engine at different power settings, or modes, for set durations. Jet engine test cell personnel record test durations, which are used to calculate emissions from engine testing. 4.2.10.1 Step One – Identify All Available Control Technologies Recent permitting review identifies the following as possible VOC and NOx control technologies for jet engine testing activities at Hill AFB: Good operating procedures, namely following proper testing operations to minimize VOC and NOx emissions while testing engines. 4.2.10.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.10.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.10.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.10.5 Step Five – Select RACT Use of good operating procedures and compliance with pre-approved emissions and visual emissions limitations meet or exceed RACT for jet engine testing. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-17 In addition, Hill AFB complies with the following pre-approved RACT/BACT determination emission limitations and visual emissions limitations for jet engine testing, as detailed in DAQE -AN101210223-12:  The total emissions from all the jet engine testing, auxiliary power testing, and engine pickling operations on the Base, combined, shall not exceed the following emission limits in tons per rolling 12-month period: particulate matter less than 10 microns in aerodynamic equivalent diameter (PM10) = 4.5, sulfur dioxide = 8.1, NOx = 64, CO = 48.0, VOC = 24.  Visible emissions, from jet engine testing and auxiliary power testing, shall be no greater than 20% opacity except for a period not exceeding 1 minute in any hour. 4.2.11 Liquid Calibration Units This section discusses the RACT analysis for liquid calibration units at Hill AFB. Located throughout the Base are various liquid calibration systems and associated equipment, including test stands and atomizers, used for testing and calibrating fluid flow components such as pumps, meters, valves, and fuel system components. Components are placed in test stands and calibration fluid is pumped through them for calibration or to test function. Following testing, components are reassembled and remaining calibration fluid is purged and reused or sent offsite as used oil. 4.2.11.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for liquid calibration units at Hill AFB: Good operating procedures, namely operating equipment as designed and intended to minimize emissions of VOCs. 4.2.11.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.11.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.11.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.11.5 Step Five – Select RACT Use of good operating procedures and compliance with pre-approved emissions limitations meet or exceed RACT for liquid calibration units. In addition, Hill AFB complies with the following pre-approved RACT/BACT determination emission limitations and visual emissions limitations for liquid calibration units, as detailed in DAQE- AN101210225-12:  Flexibility Provisions – Hill AFB is allowed to add or modify any liquid calibration system provided each of the following conditions are met: - The total amount of VOC emissions generated by the liquid calibration systems shall not exceed 10 tons per rolling 12-month period. - The new or modified equipment must meet the requirements listed in the permit as BACT. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-18 4.2.12 Miscellaneous Armaments Firing This section discusses the RACT analysis for miscellaneous armaments firing at Hill AFB. Hill AFB operates small arms firing facilities for training and testing purposes. These facilities can be operated as a firing range or as a testing location for various small combustion activities, including squib, igniter, and impulse cartridge testing. The indoor facilities are equipped with control devices (for example, cartridge filters) to reduce emissions. 4.2.12.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC and NOx control technologies for miscellaneous armaments firing at Hill AFB: Operating limitations, such as limitations on the operation of a source where practical to eliminate excess emissions of NOx and VOCs. 4.2.12.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.12.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.12.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.12.5 Step Five – Select RACT Use of good operating procedures and compliance with pre-approved emissions limitations meet or exceed RACT for miscellaneous armaments firing. In addition, Hill AFB complies with the following pre-approved BACT determination conditions for miscellaneous armaments firing, as detailed in DAQE-AN101210249-17:  The combined net explosive weight (NEW) of all miscellaneous munitions tested (Building 1642) shall be no greater than 1,000 pounds per rolling 12-month period. This limit applies to all munitions with a NEW of 5 pounds or more.  Test firing at the indoor test range (Building 746) shall be limited to two 20-mm guns in 1 hour or one 25-mm gun in 1 hour or one 30-mm gun in 1 hour. The 12-month rolling maximum shall be 50,000 rounds of 20-mm cartridges, 20,000 rounds of 25-mm cartridges, and 20,000 rounds of 30-mm cartridges. 4.2.13 Nondestructive Inspection This section discusses the RACT analysis for nondestructive inspection activities at Hill AFB. Inspection processes include leak and surface testing using fluorescent penetrant inspection and magnetic particle inspection. Fluorescent penetrant inspection uses three tanks that contain inspection penetrant, penetrant emulsifier, and wet developer. 4.2.13.1 Step One – Identify All Available Control Technologies The CARB BACT Clearinghouse and recent permitting review identifies the following as possible control technologies for nondestructive inspection (NDI) activities at Hill AFB. The RBLC was reviewed as well, Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-19 however, no category was available specific to NDI processes, so similar processes were evaluated. No BACT determinations for NDI processes or those similar to NDI processes were found:  Proper operation and maintenance practices – Such activities will reduce VOC emissions by ensuring proper quantity of penetrant is sprayed and proper quantity of emulsifier is used.  Closed covers on VOC-containing equipment when not in use – Will reduce VOC volatilization when the process is not in use. 4.2.13.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.13.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.13.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.13.5 Step Five – Select RACT Using proper operation and maintenance practices and maintaining closed covers on VOC-containing equipment are considered to exceed RACT and meet BACT for NDI activities. In addition, Hill AFB complies with the following pre-approved BACT conditions for NDI activities, as detailed in DAQE-AN101210275-21:  The following material consumption limits shall not be exceeded: - 760 gallons of penetrant per rolling 12-month period. - 424 gallons of emulsifier per rolling 12-month period.  The spray enclosure for penetrant operations shall remained closed when in automated spray mode use. 4.2.14 Paint Gun Cleaning This section discusses the RACT analysis for paint gun cleaning activities at Hill AFB. Paint gun cleaning operations use a solvent to clean paint guns after use. The solvent is either applied through flush or immersion cleaning. At Hill AFB, these cleaning operations are done either in paint booths or at paint gun cleaning stations. 4.2.14.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for paint gun cleaning at Hill AFB:  Good work practices, including proper handling of solvent  Use of cover on equipment - Equipment is covered when not in use to reduce VOC emissions Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-20 4.2.14.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.14.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.14.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.14.5 Step Five – Select RACT Use of good work practices, including proper handling of solvent, and use of cover on equipment when not in use, are considered to exceed RACT or meet BACT for paint gun cleaning activities. Furthermore, compliance with Aerospace NESHAP, R307-350, Miscellaneous Metal Part and Product Coatings, and R307-355, Aerospace Manufacture and Rework Facilities, meets BACM. In addition, Hill AFB complies with the following pre-approved BACT determination conditions, which incorporate flexibility provisions, for NDI activities, as detailed in DAQE -AN0101210200A-09:  VOC emissions shall not exceed 201.2 tons per rolling 12-month period from painting equipment or operations, solvent uses associated with paint booths, and chemical depainting operations that fall into categories A, B, C, D, E, F, and G at Hill AFB main Base and Little Mountain sites. (Categories: A: Cleaning Operations Subject to NESHAP GG, B: Primer and Topcoat Application Operations Subject to NESHAP GG, C: Depainting (Chemical) Operations Subject to NESHAP GG, D: Specialty Coating Application Operations to Aerospace Vehicles or Components, E: Surface Coating Application Operations not Subject to NESHAP GG, F: Specialty Coating Application Operations to non-Aerospace Vehicles or Components, G: Depainting (Chemical) operations not Subject to NESHAP GG.) 4.2.15 Rocket Motor Testing This section discusses the RACT analysis for rocket motor testing activities at Hill AFB. Hill AFB test fires rocket motors at an indoor testing facility. The rocket motors are mounted inside a containment cell for testing and exhaust is vented through a stack. 4.2.15.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC and NOx control technologies for rocket motor testing activities at Hill AFB: Operating limitations, including limitations on the operation of a source where practical to eliminate excess emissions of NOx and VOCs, and during no- burn and clearing index conditions. 4.2.15.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.15.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-21 4.2.15.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.15.5 Step Five – Select RACT Use of good operating procedures, including compliance with pre-approved emissions and material throughput limitations, meets or exceeds RACT for rocket motor testing. In addition, Hill AFB complies with the following pre-approved RACT/BACT determination conditions for rocket motor testing, as detailed in DAQE-AN101210249-17:  The combined NEW of all rocket motors tested in the Rocket Motor Test Facility (Building 11647) shall be no greater than 19,600 pounds per rolling 12-month period.  From November 1 through March 1 (or current UDAQ no-burn season date range): - 665 pounds of NEW per day on unrestricted action burn days (or current UDAQ terminology for days where there are no restrictions on the use of solid fuel burning devices) - 399 pounds of NEW per day on voluntary action burn days (or current UDAQ terminology for days where voluntary reductions are in place for the use of solid fuel burning devices) - No test firings will be allowed on mandatory action burn days (or current UDAQ terminology for days where solid fuel burning devices may not be used)  From March 2 through October 31 (or current date range outside of the UDAQ no-burn season): - 665 pounds of NEW per day on days with a clearing index 500 and above - 399 pounds of NEW per day on days with a clearing index between 500 and 200 - No test firings will be allowed on days with a clearing index 200 and below 4.2.16 Site Remediation This section discusses the RACT analysis for site remediation activities at Hill AFB. Hill AFB has several ongoing site remediation projects that use remedial technologies such as soil vapor extraction and air stripping to remediate the contaminated media. The remedial activities underway at Hill AFB are being performed under Comprehensive Environmental Response, Compensation, and Liability Act. 4.2.16.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for site remediation activities at Hill AFB:  Good operating and maintenance procedures  Compliance with R307-401-15 requirements 4.2.16.2 Step Two – Eliminate Technically Infeasible Control Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.16.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-22 4.2.16.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.16.5 Step Five – Select RACT Use of good operating practices and compliance with R307-401-15 requirements are considered to meet or exceed RACT for site remediation activities. 4.2.17 Surface Coating This section discusses the RACT analysis for surface coating activities at Hill AFB. Most surface coating operations at Hill AFB are done in paint booths and are spray- or roller-applied to equipment and aircraft. Solvents may be used in conjunction with paints and coatings to thin the coating before application and for surface coating cleanup activities. 4.2.17.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies possible VOC control technologies for surface coating activities at Hill AFB. Available control technologies are provided in Table 4-7. Table 4-7. Available Control Technologies for Surface Coating Activities at Hill AFB Source Category Control Technology Description Pollutants Controlled Surface Coating High Efficiency Means of Application Use of HVLP spray guns, hand application, or other low-pressure means of coating to maximize transfer efficiency. VOC Surface Coating Use of Low VOC Materials Using materials with low VOC content, both coatings, solvents, and other inputs. VOC Surface Coating Activated Carbon Adsorbs VOC emitted from paint booths. VOC Surface Coating Regenerative Thermal Oxidizer A combustion device that controls VOCs by converting the emissions into carbon dioxide and water through the use of heat before exhausting them to the atmosphere. VOC Surface Coating Operating Restrictions/Good Work Practices/NESHAP and UDAQ Rule Standards Limiting the operation of a source where practical to eliminate excess emissions. Minimizing VOC emissions while cleaning, mixing, storing materials, including keeping containers shut. This includes complying with applicable NESHAP and UDAQ rule standards. UDAQ rules meet BACM. VOC HVLP = high volume low pressure 4.2.17.2 Step Two – Eliminate Technically Infeasible Controls Table 4-8 lists the control technologies not technically feasible for operations at Hill AFB. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-23 Table 4-8. Technically Infeasible Control Technologies for Surface Coating at Hill AFB Source Category Control Technology Reasons for Being Technically Infeasible Surface Coating Activated Carbon While activated carbon is widely used to control VOC emissions and pilot scale projects have been implemented with modest success on small automotive size paint booths, it is not used at large aerospace manufacturing and rework facilities. For a control to be feasible, it must have a practical potential for application and this has not been demonstrated in industry or research and development testing for facilities with booths as large and with comparable usage rates as Hill AFB. Surface Coating Regenerative Thermal Oxidizer Regenerative thermal oxidizers work best when the VOC concentration is low. Hill AFB coatings fall outside the optimum range of the regenerative thermal oxidizer and appropriate for use at Hill AFB. 4.2.17.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all remaining control technologies are technically feasible and currently implemented at Hill AFB. 4.2.17.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all remaining technically feasible control technologies identified are already implemented at Hill AFB. 4.2.17.5 Step Five – Select RACT Operating restrictions, good work practices, use of application methods with a high transfer efficiency, and use of low VOC-containing materials are considered to meet or exceed RACT for surface coating. Cleaning operations and primer and topcoat application operations subject to NESHAP GG comply with the MACT standards set forth within these regulations. Hill AFB also complies with the RACT standards within the control technologies guidelines document Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations (EPA, 1997) for activities relating to the application of specialty coatings on nonaerospace vehicles or components. This voluntary RACT application satisfies the requirements of BACT for controls of VOC emissions for the surface coating of nonaerospace vehicles and components. For surface coating operations not subject to NESHAP GG, activities comply with the RACT standards -which meet BACM -- described in the most recent versions of R307-342, Sealants and Adhesives, R307-348, Magnet Wire Coatings, R307-350, Miscellaneous Metal Parts and Products Coatings, R307-352, Metal Container, Closure and Coil Coatings, R307-355 Aerospace Manufacture and Rework Facilities, and R307-361, Architectural Coatings. For those processes not subject to the NESHAP and not subject to the RACT standards of the control techniques guidance detailed above, Hill AFB complies with the VOC limitations as outlined in DAQE-AN0101210200A-09. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-24 In addition, Hill AFB complies with the following pre-approved BACT determination conditions, which incorporate flexibility provisions, for surface coating, as detailed in DAQE-AN0101210200A-09:  VOC emissions shall not exceed 201.2 tons per rolling 12-month period from painting equipment or operations, solvent uses associated with paint booths, and chemical depainting operations that fall into categories A, B, C, D, E, F, and G at Hill AFB main Base and Little Mountain sites (Categories: A: Cleaning Operations Subject to NESHAP GG, B: Primer and Topcoat Application Operations Subject to NESHAP GG, C: Depainting (Chemical) Operations Subject to NESHAP GG, D: Specialty Coating Application Operations to Aerospace Vehicles or Components, E: Surface Coating Application Operations not Subject to NESHAP GG, F: Specialty Coating Application Operations to non-Aerospace Vehicles or Components, G: Depainting (Chemical) operations not Subject to NESHAP GG.) Furthermore, Hill AFB complies with the requirement in the PM2.5 SIP that states the VOC emissions from painting and chemical stripping operations shall not exceed 0.58 ton per day. 4.2.18 Waste Fuel Reclamation This section discusses the RACT analysis for waste fuel reclamation activities at Hill AFB. Jet A fuel is reclaimed from aircraft during fuel system purging, testing, and maintenance. Before depot maintenance, fuel systems are purged of all fuel as a safety precaution. Once the scheduled maintenance is complete, the aircraft fuel system is tested again for leaks and overall integrity before the aircraft is cleared for flight. 4.2.18.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for waste fuel reclamation at Hill AFB:  Operating restrictions and procedures – Limiting the operation of a source where practical to eliminate excess emissions and proper equipment operations. 4.2.18.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.18.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.18.4 Step Four – Evaluate Most Effective Control and Document Results All technically feasible control technologies identified are already implemented at Hill AFB. 4.2.18.5 Step Five – Select RACT Use of proper operating procedures and maintenance of equipment, along with compliance with the fuel throughput conditions outlined within the permit are considered to meet or exceed RACT for waste fuel reclamation. In addition, Hill AFB complies with the following pre-approved BACT determination conditions for waste fuel reclamation, as detailed in DAQE-AN101210250-17 :  Proper operation and maintenance of equipment  Extraction of JP-5, JP-6, JP-8, JP-10 or Jet A fuels (or equivalent fuels to be determined by the Director) no greater than 170,820 gallons per rolling 12-month period Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-25 4.2.19 Waste Solvent Reclamation This section discusses the RACT analysis for waste solvent reclamation activities at Hill AFB. Hill AFB operates a reclaiming unit that is electrically heated and has a water-cooled condenser to reclaim used solvents. The system is able to operate continuously or in batches. 4.2.19.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible VOC control technologies for waste solvent reclamation at Hill AFB:  Use of a Control Device – Each emission unit is to be equipped with a water-cooled condenser, refrigerated chiller, carbon adsorption, or other device that reduces VOC emissions from the unit.  Operating Restrictions and Procedures - Limiting the operation of a source where practical to eliminate excess emissions and proper equipment operations, including use of a cover that shall remain closed except during set up of reclamation operations or when adding or removing solvent. Waste or used solvent also to be kept in closed containers. 4.2.19.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.19.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.19.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.19.5 Step Five – Select RACT Use of operating restrictions and good operating procedures, and use of a control device, such as a chiller as detailed in DAQE-AN0101210215-11, are considered to meet or exceed RACT for waste fuel reclamation. 4.2.20 Wastewater Treatment This section discusses the RACT analysis for wastewater treatment activities at Hill AFB. The Hill AFB industrial wastewater treatment plant (IWTP) treats industrial wastewater that contains a variety of organic compounds. In 2019, a wastewater sludge dryer was installed at the IWTP. This equipment is used to dry sludge to reduce the sludge volume prior to offsite disposal. 4.2.20.1 Step One – Identify All Available Control Technologies The RBLC and recent permitting review identifies the following as possible control technologies for various source categories at Hill AFB:  Proper operation and maintenance of the equipment  For the sludge dryer, BACT consists of using a steam heat exchanger for drying and a wet scrubber Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 4-26 4.2.20.2 Step Two – Eliminate Technically Infeasible Controls Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible. 4.2.20.3 Step Three – Rank Remaining Control Technologies by Control Effectiveness Not applicable because all identified technologies listed in Step One for control of emissions are technically feasible and currently implemented at Hill AFB. 4.2.20.4 Step Four – Evaluate Most Effective Control and Document Results Not applicable because all technically feasible control technologies identified are already implemented at Hill AFB. 4.2.20.5 Step Five – Select RACT Proper operation and maintenance of equipment, compliance with emissions limitations, and for the sludge dryer, use of a steam heat exchanger for drying and a wet scrubber meets or exceeds RACT for wastewater treatment. In addition, Hill AFB complies with the following pre-approved BACT determination conditions for wastewater treatment, as detailed in DAQE-AN101210262-19: For the Air Stripper towers:  The emissions of VOCs shall be no greater than 12.01 tons per rolling 12-month period. For the Sludge Dryer:  The scrubber shall operate at all times that the sludge dryer is in operation. The scrubber shall operate within the provisional compliant pressure drop range determined by operational experience. The provisional compliant pressure drop rang shall be posted near the pressure drop monitor and shall be included in the corresponding Operation and Maintenance Plan. The dryer shall cease operation if an excursion of more than 2 inches of water column outside the provisional compliant pressure drop range occurs.  Visible emissions from the sludge dryer wet scrubber shall be no greater than 20% opacity. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f 5-1 5. References CH2M. 2018. Hill Air Force Base – Main Base 2017 Annual Criteria and Hazardous Air Pollutant Emission Inventory. March. Cleaver Brooks. 2010. Boiler Emissions Guide. CB-7435. United States Air Force (USAF). 2020. Air Force Manual 32-1068, Heating Systems and Unfired Pressure Vessels. 16 June. U.S. Environmental Protection Agency (EPA). 1997. Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations. December. U.S. Environmental Protection Agency (EPA). 2018. “Implementation of the 2015 National Ambient Air Quality Standards for Ozone: Nonattainment Area State Implementation Plan Requirements.” Federal Register . Vol. 83, No. 234. 6 December. Utah Division of Air Quality (UDAQ). 2023. Serious Ozone Nonattainment Area Designation – Potential Impact to Hill Air Force Base. Communication. 31 May. Appendix A List of Approval Orders by Source Category Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f A-1 Table A-1. List of Applicable Approval Orders by Source Category Source Category Approval Order Number Chemical Stripping DAQE-AN0101210200A-09 Degreasers DAQE-AN101210228-12 External Combustion: Air Handlers DAQE-AN101210237-15 External Combustion: Boilers DAQE-AN101210245-16 External Combustion: Building 507 Melt Furnaces DAQE-AN0101210189-08 External Combustion: Curing and Burnout Ovens DAQE-AN101210261-18 External Combustion: Hydrazine Thermal Oxidizer DAQE-AN101210233-14 Fire Training DAQE-AN101210272-20 Fuel Storage DAQE-AN101210288-23 Internal Combustion: Emergency Generators DAQE-AN0121175-06 Internal Combustion: Engine Test Stand DAQE-AN101210261-18 Internal Combustion: Landfill Gas Generators DAQE-AN101210251-17 Jet Engine Testing DAQE-AN101210223-12 Liquid Calibration Systems DAQE-AN101210225-12 Metal Plating DAQE-AN0101210214-11 Miscellaneous Armaments Firing DAQE-AN101210249-17 Nondestructive Inspection DAQE-AN101210275-21 Paint Gun Cleaning DAQE-AN0101210200A-09 Rocket Motor Testing DAQE-AN101210249-17 Surface Coating DAQE-AN0101210200A-09 Waste Fuel Reclamation DAQE-AN101210250-17 Waste Solvent Reclamation DAQE-AN0101210215-11 Wastewater Treatment: Air Stripper Towers DAQE-AN101210262-19 Wastewater Treatment: Sludge Dryer DAQE-AN101210262-19 Appendix B RBLC Search Results Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f B-1 Table B-1. RBLC Search Results for Fuel Storage Tanks RBLC ID Tank Description VOC Control Determination IN-0158 550 gal ultra-low sulfur diesel tank. Good design and operating practices. IN-0273 HFR tanks storing diesel fuel. Capacities: 650 gal, 5,000 gal. Use of good design and operating practices. Each tank shall use a fixed roof. LA-0309 600 gal gasoline tank. Submerged fill. LA-0314 1,000 gal gasoline tank. Submerged fill. OK-0154 2,800 gal diesel tank. Fixed roof tank. TX-0728 10,708 gal diesel tank. Low vapor pressure fuel, submerged fill, white tank. TX-0799 Fuel tanks of various capacities. Fixed roof tanks, submerged fill, white or aluminum exterior surfaces. TX-0825 HFR tanks storing products with a vapor pressure < 0.1 psia. Capacities: 546 gal, 2,016 gal, 2,982 gal, 9,996 gal, 12,600 gal. Painted white, submerged fill. < = less than BACT = best available control technology gal = gallon(s) HFR = ID = identification LAER = lowest achievable emission rate psia = pound(s) per square inch absolute RACT = reasonable available control technology RBLC = RACT/BACT/LAER Clearinghouse VOC = volatile organic compound Table B-2. RBLC Search Results for Internal Combustion Engines RBLC ID Generator Size (kW) NOx Control Determination LA- 0317 1,750 Comply with 40 CFR 60 Subpart IIII and 40 CFR 63 Subpart ZZZZ. LA- 0308 2,000 Good combustion and maintenance practices and compliance with NSPS 40 CFR 60. Subpart IIII MI- 0423 2,179 Good combustion practices and meeting NSPS IIII requirements. MD- 0042 2,250 Limit on operating hours, use of ultra-low sulfur fuel and good combustion practices. OH- 0352 2,250 Purchase engine certified to the standards in NSPS Subpart IIII. LA- 0313 1,923 Compliance with 40 CFR 63 Subpart ZZZZ and NSPS 40 CFR 60 Subpart IIII, good combustion practices. use of ultra-low sulfur diesel fuel. LA- 0288 2,000 Comply with 40 CFR 60 Subpart IIII; operate the engine in accordance with the engine manufacturer’s instructions or written procedures designed to maximize combustion efficiency and minimize fuel usage. LA- 0296 2,000 Compliance with 40 CFR 60 Subpart IIII; operating the engine in accordance with the engine manufacturer’s instructions or written procedures (consistent with safe operation) designed to maximize combustion efficiency and minimize fuel usage. Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f B-2 RBLC ID Generator Size (kW) NOx Control Determination LA- 0309 2,179 Comply with 40 CFR 60 Subpart IIII. LA- 0316 2,500 Comply with 40 CFR 60 Subpart IIII. CFR = Code of Federal Regulations kW = kilowatt(s) NOx = nitrogen oxides NSPS = New Source Performance Standards Hill Air Force Base Reasonable Available Control Technology Analysis 230815094046_1e4a034f B-3 Table B-3. RBLC Search Results for Large Boilers Greater Than 5 MMBtu RBLC ID Permit Issuance Date Boiler Capacity (MMBtu/hr) Pollutant Control Determination AR-0167 12/01/20 40 NOx Ultra-low NOx burners and good combustion practices OH-0387 9/20/22 45.6 NOx Ultra-low NOx burners, good combustion practices, and the use of natural gas MI-0454 12/20/22 50 NOx Low-NOx burners or FGR along with good combustion practices IN-0359 3/30/23 53.1 NOx Low-NOx burners and good combustion practices FL-0371 6/07/21 60 NOx Low-NOx burners KS-0041 10/30/19 69 NOx Ultra-low NOx Burners IN-0359 3/30/23 53.1 SOx, PM10, PM2.5, VOC Good combustion practices, and the use of pipeline quality natural gas AR-0168 3/17/21 58 SOx, PM10, PM2.5, VOC Combustion of Natural gas and Good Combustion Practice MI-0452 6/23/22 61.5 SOx, PM10, PM2.5 Good combustion practices, and the use of pipeline quality natural gas MI-0452 6/23/22 61.5 VOC Good combustion practices AR-0168 3/17/21 64 & 66 CO Good operating practices OH-0387 9/20/22 45.6 CO Good combustion practices and the use of natural gas BACT = best available control technology CO = carbon monoxide FGR = flue gas recirculation hr = hour(s) ID = identification LAER = lowest achievable emission rate MMBtu = million British thermal unit(s) NOx = nitrogen oxides PM2.5 = particulate matter less than 2.5 microns in aerodynamic equivalent diameter PM10 = particulate matter less than 10 microns in aerodynamic equivalent diameter RACT = reasonable available control technology RBLC = RACT/BACT/LAER Clearinghouse SOx = sulfur oxides VOC = volatile organic compound