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Home My WebLink AboutDAQ-2024-0109901 DAQC-CI127240001-24 Site ID 12724 (B1) MEMORANDUM TO: FILE – SALT LAKE CITY DEPARTMENT OF PUBLIC UTILITIES – Water Reclamation Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: September 4, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: August 7, 2024 SOURCE LOCATION: 1367 West 2300 North Salt Lake City, UT 84116 DIRECTIONS: The main entrance is located on 2300 North and is gated. Terry Price's office is located at the admin building located at 2020 North Redwood Road. SOURCE CONTACTS: Terrence (Terry) Price, Compliance Manager 801-799-4041, terrence.price@slc.gov Michael Tucker, Plant Engineer 801-799-4005, michael.tucker@slc.gov OPERATING STATUS: Operating normally except that the two 1,215 BHP generator engines are being rebuilt and are not currently operational, therefore, two temporary boilers are on site to maintain temperature in the digesters. PROCESS DESCRIPTION: The Salt Lake City Water Reclamation Facility is a publicly owned water treatment facility. Treatment begins with automated mechanical screening, followed by grit removal, then primary clarification where the flow is split evenly to four 135-foot clarifiers. The flow continues on to eight 165-foot diameter trickling filters with a recirculation rate of approximately 2.5:1. Trickling filter effluent is then split between six secondary clarifiers for secondary sludge removal before being disinfected with chlorine and discharged to the receiving stream. Solids recovered from primary and secondary treatment units are thickened in two gravity thickeners before being pumped to one of four heated anaerobic digesters. The digested solids are then pumped to a storage tank where they are gravity fed to sludge drying beds as necessary. 0 0 2 The dried solids are currently being disposed of at E.T. Technologies where they are blended with native soils used for capping landfill cells. To control emissions, the source is limited to using digester or NG gases on the Waukesha engines and comfort heaters and #2 diesel or better in the emergency generators. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN127240007-18, dated December 17, 2018 MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Salt Lake City Department of Public Utilities Water Reclamation Facility 1365 West 2300 North 1367 West 2300 North Salt Lake City, UT 84116 Salt Lake City, UT 84116 SIC Code: 4952: (Sewerage Systems) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] 3 I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process other than two temporary boilers. Records are kept for the required time and were made available for review during the inspection. Regular maintenance is conducted following a PM schedule. No reportable breakdowns have occurred since the previous inspection. A 2023 emission inventory was submitted to DAQ. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Water Reclamation Facility II.A.2 One (1) Boiler Fuel: Natural Gas and/or Digester Gas Rating: 4.4 MMBtu/hr II.A.3 Two (2) Generator Engine Sets Rating: 1,215 BHP Each Model: L5790GLD Fuel: Digester or Natural Gas MACT Applicability: Subpart ZZZZ II.A.4 One (1) Emergency Generator Engine (Installed in 1980) Rating: 800 kW Fuel: Diesel II.A.5 One (1) Emergency Generator Engine (Installed in 1980) Rating: 820 kW Fuel: Diesel II.A.6 One (1) Emergency Generator Engine Rating: 2000 kW Fuel: Diesel II.A.7 Two (2) Digester Gas Flares Flow Rate: 500 scfm each II.A.8 Miscellaneous Heaters Combined Rating: 5.7 MMBtu/hr Fuel: Natural Gas Status: In Compliance. The equipment observed on site was consistent with that listed except two temporary boilers. 4 II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions to exceed the following: A. All natural gas or digester gas combustion exhausts - 10% opacity B. All diesel engines exhausts - 20% opacity C. All other points - 20% opacity. [R307-305-3, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3] Status: In Compliance. No visible emissions were observed from any point during the inspection. II.B.1.b The owner/operator shall not allow emissions to the atmosphere to exceed the following from the indicated emission points: Source: Two (2) Generators Engine Sets, as listed in II.A.3 Pollutant Rate (g/bhp-hr) CO 2.8 NOx 1.5. [R307-401-8] II.B.1.b.1 Stack testing to show compliance with the emission limitations shall be performed as specified below: A. Testing Pollutant Status Frequency CO * # NOx * # Testing Status * Initial compliance testing was performed to establish the emission factors values. # Testing, using portable analyzer, is required any time a new baseline (air to fuel ratio) is set due to annual maintenance and repairs. B. Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to Minor Source NSR: Compliance Section. 5 The source test protocol shall be approved by the Director prior to performing the tests. The source test protocol shall outline the proposed tests methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. C. Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1A, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. D. Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director. E. Nitrogen Oxides (NOx) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other testing methods approved by the Director. F. Carbon Monoxide (CO) 40 CFR 60, Appendix A, Method 10, or other testing methods approved by the Director. G. Calculations To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. H. Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. [R307- 165, R307-401-8] Status: In Compliance. The stack test was conducted August 28-29, 2018. Stack test results were received, reviewed, and accepted by DAQ (DAQC-0528-19, dated April 16, 2019). The source is having the two generators rebuilt, and stated that they plan on stack testing them when that is completed. II.B.1.c The owner/operator shall operate the following equipment with the associated fuels: A. Boilers: Digester or Natural Gas B. Waukesha Engines: Digester or Natural Gas C. Comfort Heating: Natural Gas. [R307-401-8] Status: In Compliance. Fuel is used as outlined. II.B.2 Emergency Generator Engine Requirements 6 II.B.2.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. During the corresponding 12-month period, the 800 kW generator operated 1.5 hours, the 820 kW generator operated 8 hours, and the 2000 kW generator operated 23 hours. II.B.2.b Records of hours of operation shall be determined by an operator log. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. Maintenance staff record run times on a log sheet which is later transferred to an electronic spreadsheet. II.B.2.c The sulfur content of diesel fuel burned in the stationary diesel engines on site shall not exceed 15 ppm by weight. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.c.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by test reports from the diesel fuel marketer. [R307-203-1] Status: In Compliance. Diesel fuel is supplied by Salt Lake City Fleet Services which was purchased through Sinclair Oil and is Ultra-low Sulfur. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. Emergency generators are operated less than the 100-hour limit for testing and maintenance. Ultra-low sulfur diesel fuel is used to power the generators. Regular maintenance is conducted. The two generators that operate on natural gas or digester gas are being rebuilt. They have not operated in the last year. Stack testing is planned for when the rebuild is complete. 7 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Ultra-low sulfur diesel fuel is purchased through Sinclair Oil. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. See status for MACT (Part 63), ZZZZ. Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. No visible emissions were observed from any point during the inspection. EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided from Salt Lake City Department of Public Utilities – Water Reclamation Facility. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN127240007-18, dated December 17, 2018, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 62964.00 Carbon Monoxide 41.97 36.838 Nitrogen Oxides 38.04 9.783 Particulate Matter - PM10 0.86 0.567 Particulate Matter - PM2.5 0.86 0.567 Sulfur Dioxide 5.75 0.008 Volatile Organic Compounds 14.33 0.006 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Benzene (Including Benzene From Gasoline) (CAS #71432) 2200 58 Generic HAPs (CAS #GHAPS) 2600 Phenol (CAS #108952) 3400 2 Toluene (CAS #108883) 3600 26 Xylenes (Isomers And Mixture) (CAS #1330207) 2200 12 8 PREVIOUS ENFORCEMENT ACTIONS: None in the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN127240007-18, dated December 17, 2018, the overall status is: In Compliance. Records were made available for review during the inspection. The facility appeared to be well maintained and properly operated. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. May want to contact Terry Price prior to visit, since the source is gated and his office is offsite. NSR RECOMMENDATIONS: The source is building an expansion and will most likely need a new AO, as they are also looking into upgrading generators and boilers. ATTACHMENTS: VEO Form.