HomeMy WebLinkAboutDAQ-2024-0114081
DAQC-CI160650001-24
Site ID 16065 (B1)
MEMORANDUM
TO: FILE – INTERMOUNTAIN HEALTHCARE – Primary Children's Lehi Hospital
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Susan Weisenberg, Environmental Scientist
DATE: February 20, 2024
SUBJECT: PARTIAL COMPLIANCE EVALUATION, Minor, Utah County
INSPECTION DATE: January 30, 2024
SOURCE LOCATION: 2250 North Miller Campus Drive
Lehi, UT 84043
DIRECTIONS: Take I-15 Exit 283 to Triumph Boulevard (UT-194). The Central
Utility Plant is located in the southeast corner of the hospital
parking lot. See the attached map.
SOURCE CONTACTS: Jim Blankenau, Environmental Engineer
801-484-6114
OPERATING STATUS: The permitted equipment was installed. The boilers will be fully
operating when the hospital opens for the public.
PROCESS DESCRIPTION: Intermountain Healthcare (IHC) operates the Primary Children's
Lehi Hospital, which is a full-service hospital connected to a
medical office building. The facility contains a Central Utility
Plant that houses dual fuel boilers, emergency diesel generators,
and fuel storage tanks.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN160650001-22, dated
April 11, 2022.
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
R307-203 Emission Standards: Sulfur Content of Fuels
Emission Standards
R307-210 Stationary Sources
R307-214 National Emission Standards for Hazardous Air
Pollutants
R307-305 Nonattainment and Maintenance Areas for PM10
2
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Intermountain Healthcare
Primary Children's Lehi Hospital
36 South State Street 2250 North Miller Campus Drive
Salt Lake City, UT 84111 Lehi, UT 84043
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 for Conditions 1.2 through 1.7. Not in Compliance for I.8
Notification Requirement. No modifications to the equipment or the processes were
3
observed for the recently installed boilers and emergency generators. All of the required
records were submitted upon request. Maintenance will be performed as required by the
contracting companies. IHC is in the process of submitting a NOI to request changing the
generator testing limits. The equipment had not yet been started at the time of this
inspection. A startup notification for the equipment will be submitted after the hospital is
fully functioning. No compliance action is recommended at this time.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Primary Children's Lehi Hospital
II.A.2 Two (2) Steam Boilers
Rating: 7 MMBtu/hr, each
Fuel: Natural Gas
Secondary Fuel: ULSD
II.A.3 Five (5) Condensing Hot Water Boilers
Rating: 6 MMBtu/hr, each
Fuel: Natural Gas
Secondary Fuel: ULSD
II.A.4 Four (4) Emergency Generator Engines
Rating: 1,000 kW, each
Fuel: ULSD
II.A.5 Two (2) Underground Storage Tanks
Capacity: 25,000 gallons, each
Content: ULSD
Listed for Informational Purposes
Status: In Compliance. The equipment has been installed as described and will be
operational when the hospital has opened to the public.
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 emissions points to
exceed the following values:
A. All boilers when fired on natural gas- 10% opacity
B. Emergency generators engines and boilers when fired on diesel- 20% opacity.
[R307-305-3, R307-401-8]
Status: Not Observed. The permitted equipment was not operating at the time of this
inspection.
4
II.B.1.a.1 Opacity observations of emissions from any stationary source on site shall be conducted
according to 40 CFR 60, Appendix A, Method 9. [R307-305-3]
Status: Not Observed. The permitted equipment was not operating at the time of this
inspection.
II.B.1.b The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ,
R307-401-8]
Status: In Compliance. Christensen Oil Company certifies the diesel fuel as ULSD #2 15
ppm. See the attached invoices.
II.B.1.b.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-203]
Status: In Compliance. Only Ultralow Sulfur Diesel fuel is purchased for use. Christensen
Oil Company supplies the fuel and certifies the product as ULSD. See the attached invoices.
II.B.2 Boiler Requirement
II.B.2.a The owner/operator shall use natural gas as the primary fuel and #2 diesel fuel oil as backup fuel
in each of the dual-fired boilers. [R307-401-8]
Status: In Compliance. The boilers will be operated using natural gas. #2 diesel fuel will
only be used as a backup fuel in the event of a Dominion Gas scarcity event that would
cause a curtailment.
II.B.2.b The owner/operator shall not burn fuel oil in each of the dual-fuel boilers for more than 48 hours,
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. [40 CFR 63 Subpart JJJJJJ, R307-401-8]
Status: Not Observed. The boilers at this facility had not yet started operating. The
48-hour, 12-month rolling total limit for fuel oil use during testing and maintenance was
discussed with the facility site manager. The boilers are exempt from JJJJJJ provided that
fuel oil is only used during times of emergency natural gas curtailment and that the
48-hour limit for testing and maintenance is never exceeded. See the attached DAQ
Engineering Review, Comment #3 for additional information.
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 diesel fuel was burned
B. The duration of operation on diesel fuel, in hours
5
C. The reason for diesel fuel usage. [R307-401-8]
Status: Not Observed. The boilers had not yet started operating at the time of this
inspection. This requirement was reviewed during the inspection with the IHC
Environmental Engineer. A blank log form was submitted as an example of future record
keeping.
II.B.3 Emergency Engines
II.B.3.a The owner/operator shall install an emergency engine with a manufacturer's specification of
emission rate of 4.4 g/hp-hr or less for NOx. [R307-401-8]
Status: In Compliance. The engines installed have a Cummins certification meeting this
standard. See the attached equipment form submitted with the NOI for this AO. The
manufacturer plates were observed during this site visit and they were consistent with the
submitted information.
II.B.3.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the
manufacturer's specification of the emission rate. The record shall be kept for the life of the
equipment. [R307-401-8]
Status: In Compliance. Records of the manufacturer's specification shall be kept for the
life of the engines.
II.B.3.b The owner/operator shall not operate each 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 engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
Status: Not Observed. The emergency engines have not yet been tested or otherwise
operated at the time of this inspection. The 100-hour, 12-month rolling total limit for each
engine was discussed with IHC Environmental Engineer.
II.B.3.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 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 60 Subpart ZZZZ, R307-401-8] Status: Not Observed. The emergency engines had not yet been tested at the time of this inspection. Cummins Contractors will be used for routine inspections and maintenance following the required schedules.
II.B.3.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
Status: In Compliance. Non-resettable hour meters have been installed on all four
emergency engines.
6
II.B.3.c The owner/operator shall perform maintenance and testing of the emergency generator engines in
accordance with the following:
A. The owner/operator shall not operate the engines for maintenance and testing
operations before 7:00 AM or after 7:00 PM each day;
B. The owner/operator shall not operate more than one (1) emergency generator engine
at any one time during maintenance and testing operations;
C. The owner/operator shall not test each generator more than once per week. [R307-410]
Status: Not Observed. This condition was discussed with IHC's Environmental Engineer,
Jim Blankenau. Mr. Blankenau stated that the hospital would need to test the engines at
approximately 6:00 am or earlier in the morning. He also stated that the engines are
sequenced together in a manner that necessitates that they test simultaneously. Alan
Humpherys and David Prey of DAQ were reportedly contacted on February 1, 2024, in
order to discuss the IHC hospital emergency engine testing requirements. A NOI to modify
the AO to change the testing restrictions of this condition is currently being prepared. See
the attached email correspondence.
II.B.3.c.1 To determine compliance with the maintenance and testing requirements, the owner/operator
shall record the date and the time of the day that the maintenance and testing was performed, and
the generator that was maintained and tested. The owner/operator shall maintain records of the
maintenance and testing on a daily basis. [R307-401-8]
Status: Not Observed. The emergency engines have not yet been tested or otherwise
operated at the time of this inspection. The record keeping requirements for testing and
maintenance were discussed with the IHC staff at the time of this inspection.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including
UAC R307.
NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
Status: Not Observed. The engines have not yet been tested or otherwise operated at the time of this
inspection. A maintenance program with the manufacturer contractor has been scheduled.
MACT (Part 63) JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial,
Commercial, and Institutional Boilers Area Sources
Status: Not Applicable at this time. The boilers will only operate on fuel oil during times of emergency
natural gas curtailment. The 48-hour, 12-month rolling total testing and maintenance limit currently
exempts the boilers from this subpart.
7
MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: Not Observed. The boilers were not yet operating at the time of this inspection. Record keeping
and maintenance requirements have been discussed and will be reportedly adhered to as established by
this subpart.
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. Compliance for this rule is addressed by Conditions II.B.1.b and II.B.1.b.1 of
the current AO. All diesel fuel purchased by IHC has been certified by Christensen Oil as meeting
the ULSD standards.
National Emission Standards for Stationary Sources [R307-210]
Status: In Compliance. NSPS Subpart IIII has been incorporated by the State of Utah Rules and
have been addressed by the AO Conditions II.B.3.b and II.B.3.b.1.
National Emission Standards for Hazardous Air Pollutants [R307-214]
Status: In Compliance. MACT Subpart ZZZZ has been incorporated by the State of Utah Rules and
have been addressed by the AO Conditions II.B.1.b, II.B.3.b, and II.B.3.b.1.
Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]
Status: Not Observed. The requirements of this standard will be met by the opacity limits of
Condition II.B.1.a. The boilers and the emergency generators were not operating at the time of this
inspection.
EMISSION INVENTORY:
This facility has not yet been required to submit an Emissions Inventory. The emissions listed below are
an estimate of the total potential emissions (PTE) from Intermountain Healthcare – Primary Children's
Lehi Hospital on the Approval Order (AO) DAQE-AN160650001-22, dated April 11, 2022. PTE are
supplied for supplemental purposes only.
Criteria Pollutant PTE tons/yr
CO2 Equivalent 24840.00
Carbon Monoxide 18.92
Nitrogen Oxides 10.59
Particulate Matter - PM10 0.87
Particulate Matter - PM2.5 0.87
Sulfur Dioxide 2.29
Volatile Organic Compounds 1.05
8
Hazardous Air Pollutant PTE lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 4
Formaldehyde (CAS #50000) 29
Generic HAPs (CAS #GHAPS) 16
Hexane (CAS #110543) 676
Toluene (CAS #108883) 3
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: IHC Primary Children's Hospital was out of compliance for
Condition 1.8 for failure to submit an initial startup notification.
No compliance action is recommended at this time. This facility
should be considered to be otherwise in compliance with the
observable conditions of the AO DAQE-AN160650001-22,
dated April 11, 2022, at the time of this inspection.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect during the next inspection year to observe the boiler
operations and to review testing/maintenance records. Check for
a new AO modification to change Condition II.B.3.c.A,
regarding the testing times for the emergency generators. IHC
would like to test earlier in the day than the current limit. A
scheduled inspection is recommended to obtain access to the
Central Utility Plant and to ensure that the correct utility plant
contact personnel are available.
NSR RECOMMENDATIONS: Review this facility’s request to change the emergency
generators testing procedures.
ATTACHMENTS: VEO form, hospital facility map, email correspondence, example
generator record, DAQ Engineering Review Records, diesel fuel
invoices.
2/20/24, 6:35 PM State of Utah Mail - Primary Children's Lehi Documents
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1789802259101557282%7Cmsg-f:1789802259101557282&…1/2
Susan Weisenberg <sweisenberg@utah.gov>
Primary Children's Lehi Documents
1 message
Jim Blankenau <James.Blankenau@imail.org>Fri, Feb 2, 2024 at 8:40 AM
To: Susan Weisenberg <sweisenberg@utah.gov>
Cc: Ken Casper <KEN.CASPER@imail.org>
Susan,
Attached is the invoice documenting low-sulfur diesel was delivered and our generator log.
Also, yesterday I spoke with Alan Humpherys and David Prey at the UDAQ to discuss the hours for testing and the
sequence of operation for testing. Based on those discussions, I will be preparing an NOI to amend our permit to allow us
to test earlier in the day and test all generators at the same time.
If you have any questions, please let me know.
Thanks, Jim
Jim Blankenau, P.G.
Environmental Engineer
Intermountain Health, Canyons
383 W. Vine Street (4th floor), Murray, UT 84124
Mobile: 801.484.6114
NOTICE: This e-mail is for the sole use of the intended recipient and may contain confidential and privileged information.
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2 attachments
Generator - 02 Monthly Test Record.xlsx
32K
Intermountain Healthcare Monthly Generator Test Record
**Standards Referenced: EC 02.05.07; NFPA 110 (2010)
Facility Name: Date
Generator No. or Name: Engine Hours
Rated Nameplate Capacity: kW Pwr Factor: Min. Exhaust Temp.
oF
Rated Voltage: Tested by:
Key Results
kW Output % of Cap. Hz Reading
Oil Press. psi
Transfer Time sec. Run Time min. Exhaust Temp.
oF
Weekly Generator Inspection Performed? Remote Annunciators Passed Test?
Battery Visual State OK? Battery Type: Maintenance Free Vented
Cell 1 Cell 2 Cell 3 Cell 4 Cell 5 Cell 6
Cell 8 Cell 9 Cell 10 Cell 11 Cell 12 Cell 13
Engine Start Time TimeTemperature Stabilizes
Cool Down Start Time Stop Time
How Was Test Started?*NOTE: See Generator and ATS Testing Procedure for instructions.
Which ATS Used to Start Test:*NOTE: Enter "NA" if no ATS was used.
ATS # Yes/No ATS # Yes/No ATS # Yes/No
Did ATS Transfer?
Generator Output
Voltage Output Amperage Output
A Phase A Phase
B Phase B Phase
C Phase C Phase
Water Temperature oF
Exhaust Temperature
Single oF Left oF Right oF
System Restored to Normal Operating Condition?
Notes:
Revised 23 June 2021
480v 3 phase
208v 3 phase
240v 1 phase
Cell 14
Cell 7
Conductance / Specific
Gravity:
*NOTE: If 30% of capacity or Min. Exhaust Temp. is not achieved, you MUST perform an annual load bank.
Intermountain Healthcare Monthly Generator Test Record
**Standards Referenced: EC 02.05.07; NFPA 110 (2010)
Facility Name: Date
Generator No. or Name: Engine Hours
Rated Nameplate Capacity: kW Pwr Factor: Min. Exhaust Temp.
oF
Rated Voltage: Tested by:
Key Results
kW Output % of Cap. Hz Reading
Oil Press. psi
Transfer Time sec. Run Time min. Exhaust Temp.
oF
Weekly Generator Inspection Performed? Remote Annunciators Passed Test?
Battery Visual State OK? Battery Type: Maintenance Free Vented
Cell 1 Cell 2 Cell 3 Cell 4 Cell 5 Cell 6
Cell 8 Cell 9 Cell 10 Cell 11 Cell 12 Cell 13
Engine Start Time TimeTemperature Stabilizes
Cool Down Start Time Stop Time
How Was Test Started?*NOTE: See Generator and ATS Testing Procedure for instructions.
Which ATS Used to Start Test:*NOTE: Enter "NA" if no ATS was used.
ATS # Yes/No ATS # Yes/No ATS # Yes/No
Did ATS Transfer?
Generator Output
Voltage Output Amperage Output
A Phase A Phase
B Phase B Phase
C Phase C Phase
Water Temperature oF
Exhaust Temperature
Single oF Left oF Right oF
System Restored to Normal Operating Condition?
Notes:
Revised 23 June 2021
480v 3 phase
208v 3 phase
240v 1 phase
Cell 14
Cell 7
Conductance / Specific
Gravity:
*NOTE: If 30% of capacity or Min. Exhaust Temp. is not achieved, you MUST perform an annual load bank.