DAQ-2024-011007

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DAQC-CI129600001-24
Site ID 12960 (B1)

MEMORANDUM

TO: FILE – DIXIE REGIONAL MEDICAL CENTER

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: September 23, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County

INSPECTION DATE: August 15, 2024

SOURCE LOCATION: 1380 East Medical Center Dr.
St. George, UT 84790
DIRECTIONS: Maintenance office is located in the basement near entrance 4.

SOURCE CONTACTS: George McGee, Facilities and Plant Operations Manager
435-688-4295 [e-mail]

Mike Cummings, Maintenance & Facilities
435-251-2015

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: The Dixie Regional Medical Center operates three buildings.
The main hospital has four dual-fuel steam boilers and six water
heaters used for heating and hot water production. These boilers
operate on natural gas with diesel as a back-up fuel. There are
four emergency diesel generators that are used as backup units
when there is no electrical power from the power supply grid.
The Health and Performance Center and the Cancer Center each
have an emergency generator and various boilers all less than 5
MMBtu/hr each.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129600001-18, dated
November 29, 2018
NSPS (Part 60) Dc: Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,
NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Dixie Regional Medical Center
36 South State Street Attn: John Thomas 1380 East Medical Center Dr.
Salt Lake City, UT 84111 St. George, UT 84790

SIC Code: 8062: (General Medical & Surgical Hospitals)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process. Records are kept and were provided for review during the inspection. Maintenance is conducted following a PM schedule and as needed. No reportable breakdowns have occurred since the previous inspection. A 2023 emissions inventory was submitted to DAQ.

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Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Dixie Regional Medical Center
II.A.2 Diesel Storage Tanks Maximum Capacity: 63,840 gallons (combined, excludes generator sub tanks)
II.A.3 Main Hospital
II.A.4 Three (3) Dual-fuel Steam Boilers Max Rating: 12.6 MMBtu/hr (each) Fuel: Natural gas and fuel oil Burner: 30 ppm NOx Control: Flue gas re-circulation NSPS/MACT Applicability: 40 CFR 60 Subpart Dc
II.A.5 Dual-fuel Steam Boiler (new) Max Rating; 20.4 MMBtu/hr Fuel: Natural gas and fuel oil Burner: 9 ppm NOx NSPS/MACT Applicability: 40 CFR 60 Subpart Dc
II.A.6 Six (6) Hot Water Heaters (new) Max Rating: 6 MMBtu/hr (each) Fuel: Natural gas
II.A.7 Two (2) Emergency Generator Engines (new) Max Engine Rating: 1,645 kW (2,206 HP) each Fuel: Diesel Model Year: 2017 NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.8 Two (2) Emergency Generator Engines Max Engine Rating: 1,120 kW (1,502 HP) each Fuel: Diesel Model Year: 2002 NSPS/MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.9 Various heaters less than 5 MMBtu/hr each For informational purposes only
II.A.10 Health and Performance Center
II.A.11 Emergency Generator Engine Max Engine Rating: 1,112 kW (1,490 HP) Fuel: Diesel Model Year: 2008 NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.12 Various heaters less than 5 MMBtu/hr each For informational purposes only
II.A.13 Cancer Center

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II.A.14 Emergency Generator Engine (new) Max Engine Rating: 1,656 kW (2,220 HP) Fuel: Diesel Model Year: 2017 NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.15 Various heaters less than 5 MMBtu/hr each For informational purposes only
Status: In Compliance. Equipment observed on-site was consistent with that listed.
II.B Requirements and Limitations
II.B.1 Site-Wide Requirement II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the specified values at the exhaust stack: A. All boilers when fired on natural gas and propane - 10% opacity B. All emergency generator engines and boilers when fired on diesel - 20% opacity. [R307-201- 3, R307-401-8] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. No visible emissions were observed from any point during the inspection. II.B.2 Boiler Requirements II.B.2.a The owner/operator shall use natural gas as the primary fuel in all dual-fuel boilers. [R307-401-8] Status: In Compliance. Fuel is used as specified. II.B.2.b The owner/operator shall limit fuel oil usage in all dual-fuel boilers to 48 hours each, per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the dual-fuel boilers during periods of natural gas curtailment, gas supply interruption, or startups. [R307-401-8] II.B.2.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting fuel oil usage in each dual-fuel boiler shall be kept in a log and shall include the following: A. The date fuel oil was used B. The duration of operation in hours C. The reason for fuel oil usage. [R307-401-8] Status: In Compliance. The boilers operate on diesel fuel for maintenance test 30 minutes per month for a total of six hours each during the corresponding 12-month period. II.B.3 Emergency Generator Engine Requirement

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II.B.3.a The owner/operator shall not operate each emergency generator 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.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date 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] II.B.3.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter on each emergency generator engine on site. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. All six generators operated approximately 8 hours for testing and maintenance during the 12-month period. Each engine is equipped with a non-resettable hour meter. A log is kept with the required information. II.B.4 Fuel Requirements II.B.4.a The sulfur content of any fuel oil or diesel burned shall not exceed 15 ppm by weight. [R307-401-8] II.B.4.a.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of fuels shall be either the owner/operator's own testing, or test reports from the fuel marketer. [R307-203-1] Status: In Compliance. Fuel is supplied by Thomas Petroleum and was ultra-low sulfur. The source tests the diesel fuel annually for quality maintenance. The last test reported a sulfur content of 8.9 ppm.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units

Status: In Compliance. The source combusted 141,638.8 dekatherms of natural gas in the 12-month
period. The source operated each boiler on diesel fuel for six hours during the 12-month period for
testing and maintenance. The source is required to submit a semi-annual report summarizing diesel
usage for those six months. The report was submitted to DAQ July 18, 2024, and can be found in the
source file (Archive Document Search DAQ-2024-010678).

NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. Generators are maintained by Wheeler Machinery Co. They appear to be well
maintained. Records are kept. The generators are tested for less than the 100 hour per year limit.
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MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. The generators operate on ultra-low sulfur diesel fuel. The generators appear to
be well maintained. Each generator is equipped with a non-resettable hour meter.

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. Diesel fuel is ultra-low sulfur.

Standards of Performance for New Stationary Sources [R307-210]

Status: In Compliance. See NSPS (part 60), DC and IIII.
National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. See MACT (Part 63), ZZZZ.
EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Dixie Regional Medical Center. A
comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN129600001-18, dated
November 29, 2018, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 66005.00
Carbon Monoxide 32.38 6.871
Nitrogen Oxides 23.04 2.438
Particulate Matter - PM10 3.98 0.602
Particulate Matter - PM2.5 3.98 0.601
Sulfur Dioxide 1.20 0.157
Volatile Organic Compounds 2.00 0.464

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 8 0.56
Formaldehyde (CAS #50000) 83 6.92
Generic HAPs (CAS #GHAPS) 40
Hexane (CAS #110543) 1964 165.3
Toluene (CAS #108883) 6 0.44

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PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129600001-18,
dated November 29, 2018, the overall status is: In Compliance.
The facility appeared to be well maintained and operated
properly. Records were made available during the inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Natural Gas Record, and Email
Natural Gas Usage RRH/HPC Cancer Center
JUL 8242 616.3
AUG 8221 810.2
SEP 8152 728.6
OCT 9735 850.2
NOV 11777 920
DEC 14055 1114.4
JAN 13764 899.6
FEB 12568 863.5
MAR 13007 741.2
APR 12001 829.2
MAY 11332 762.1
JUN 8946 703.5
TOTAL 131800 9838.8
Jared James <[e-mail]>
Natural Gas Data St George Hospital
1 message
George McGee <[e-mail]>Thu, Aug 15, 2024 at 2:14 PM
To: "[e-mail]" <[e-mail]>
Jared, Here is the data you asked for.
George

George R. McGee, CHFM
Manager Of Facilities and Plant Operations
SGRH
Office at River Road Campus [phone]
Cell [phone]
[e-mail]

NOTICE: This e-mail is for the sole use of the intended recipient and may contain confidential and privileged information.
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e-mail and its contents.
GAS DTH 2023-2024.xlsx
18K
9/23/24, 4:10 PM State of Utah Mail - Natural Gas Data St George Hospital
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1807485886562495573&simpl=msg-f:1807485886562495573 1/1