DAQ-2024-012082

RISK MANAGEMENT
ENVI RON MENTAL MANAGEMENT
December 3,2024
Chad Gilgen, Manager
Minor Source Compliance Section
Utah Div. of Air Quality
195 N. 1950 W.
Salt Lake City, UT 84144-4820
Dear Mr. Gilgen:
RE: Compliance Advisory - Brigham Young University - Main Campus - Boilers #4 and #6 Condition
11.8.2.c of Approval Order DAQE-AN107900021and 40 CFR 60.45b(f)(1)(iv) - Utah County
We received your recent letter notifying BYU that the Stack Testing Report for boilers #4 and #6 was not
submitted in a timely manner to the Utah Division of Air Quality (UDAQ). I sincerely apologize that the
2023 Stack Test Report for BYU Boilers f4 and #6 could not be found. BYU is committed to complying
with U DAQ requirements.
As you may know, TETCO performs BYU's stack testing and submits the completed final report to UDAQ
through the UDAQ reporting portal. Historically, TETCO has been a dependable and reliable consultant
and is known for submitting these reports before their actual due dates. I reviewed my past emails and
found an email (attached) dated January 27,2023, from Dean Kitchen at TETCO stating he had
"submitted the report to DAQ." I asked TETCO representatives if they received an email notification that
the Stack Test Report had been received after it had been entered into the online submission portal. I
was informed that the UDAQ reporting portal does not provide a confirmation email. lnstead, there is
only an innrnediate response on the computer screen that reads "Thanks for Submitting."
Based on the email, TETCO and BYU believe that the 2023 Stack Test Report was submitted on January
27,2023, before the deadline of February 77,2023. We, too, are concerned that, for some reason, this
report is not shown in the UDAQ system. Had BYU and TETCO believed or been notified that the report
was not submitted by the deadline, we would have made every effort to make sure that it was re-
submitted through the online portal, or we would have submitted an electronic copy or hard copy.
The first time we learned about the issue with the 2023 Stack Testing Report for Boilers #4 & #6 was in
an email from Kyle Greenberg (Environmental Scientist at UDAQ), dated November 1, 2024.1
immediately reached out to TETCO, and they were able to submit the information to Kyle Greenberg that
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same day (email attached). Once we became aware there was an issue with the report, we did not
hesitate to act. We immediately took action to correct the problem of the lost/missing report and
submitted it as requested by Kyle Greenberg, attached to the emailthread.
The recent letter also indicated that the stack test was not conducted with a three-run average l-hour
runs. We appreciate you bringing this to our attention.
BYU's Approval Order DAQE-AN107900027-23, Condition ll.B.2.lfor "Existing Source Operations" states
that "the source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and the
procedures to be used."
TETCO submitted the stack test protocol to UDAQ, specifying the EPA methodologies, the stack to be
tested, and the procedures to be used. This stack testing protocol for BYU was approved by UDAQ on
October 25,2022. The UDAQ approval letter (attached) states that the submitte.! protocol "has been
reviewed and found acceptable." TETCO used and followed the EPA methods and procedures outlined in
the protocol for stack testing boilers #4 and #5 on January 10-11, 2023. BYU has not received any prior
information from UDAQ notifying BYU that the approved protocol has been rescinded.
I asked TETCO to help me understand why the three-run average L-hour run was not conducted for the
stack test. TETCO responded that beginning in the early 2000s, UDAQ began allowing the single flow rate
test to "bracket" three runs, or sets, of gas concentration measurements. TETCO noticed that UDAQ
allowed this and started using the practice to save time. This allowed the tests to be completed in a
shorter time frame. TETCO also indicated that this same approved methodology has been used for other
stack testing, not only at BYU but at other locations as well. Had BYU and TETCO known that UDAQ did
not allow this type of testing or had the approved protocol been rescinded, BYU and TETCO would have
used the three-run average 1-hour stack test method.
The email we received from Kyle Greenberg on November L,2024, also referred to the same issue for of
a missing or lost 2024 Stack Test Report for the BYU Heat Recovery Unit and Bypass. We wish to state in
this letter that the same justifications listed above apply to this most recent stack test as well. BYU and
TETCO believed that the 2024 Stack Test Report was submitted and received by UDAQ through its online
portal on or before the deadline. Had we known earlier that this report was missing or lost, we would
have ensured its immediate resubmission. Once it was brought to our attention that the 2024 Stack Test
Report could not be found, we submitted it electronically the same day Kyle's email was received. While
Kyle's email did not mention or address the EPA testing methods used for stack testing the Heat
Recovery Unit and the Bypass, again, we feel that TETCO followed the EPA methods and procedures
outlined in the protocolthat was submitted and approved by UDAQ. Had BYU and TETCO known or been
notified that the submitted protocol was no longer acceptable, a new protocol would have been
submitted and followed for the 2024 Stack Test Report for the Heat Recovery Unit and Bypass.
We kindly ask UDAQ to forgo any enforcement action that may be considered since both BYU and TETCO
believed in good faith that the Stack Testing Reports were submitted and received by UDAQ through its
online reporting portal on or before the required due date. Once the issue that the reports were missing
or lost was brought to our attention, BYU and TETCO acted quickly to resubmit electronic copies on the
same day as the notification. Additionally, TETCO used EPA testing methods that were previously allowed
by UDAQ and clearly stated in the approved test protocol.
We appreciate you sharing with us the testing protocol mentioned in your most recent letter and plan to
work with TETCO to align BYU's future testing practices to those methods. As you know, BYU strives to
ensure a safe and healthy place for its students and the surrounding community. We appreciate your
support in these efforts and request the opportunity to further discuss this Compliance Advisory with
you, if there are any questions still left to be answered.
I look forward to hearing from you soon.
Sincerely,
q6^AH,affi^;
Brian L. Harris
Environmental Manager
cc: Utah County Health Department
From:
Sent:
To:
Subiect:
Attachments:
Bria n,
Dean Kitchen <[e-mail]>
Friday, January 27,2023 10:11 AM
Brian Harris
RE: Stack Test Report
Boilers 4 and 6 )an 2023.pdf
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I just submitted the report to DAQ, and here is an invoice.
Dean
From: Brian Harris <[e-mail]>
Sent: Friday ,27 January,2023 10:01 AM
To: Dean Kitchen <[e-mail]>
Subject: RE: Stack Test Report
Good morning Dean,
Thank you for taking care of the Stack testing for Boilers 4 & 6. We appreciate your help and expertise.
l've reviewed the report you attached and I found it to be thorough and accurate. I have no changes or
recommendations to make.
With regard to the payment, please provide me with an invoice for the testing and I will submit it to the Physical
Facilities for payment. Thank you!
Sincerely,
Brian L. Harris
BYU - Risk Management
Environmental Manager
1L2 Chemical Management Building
Provo, UT 84602
Brian [e-mail]
Office - 801..422.2804
From: Dean Kitchen <[e-mail]>
Sent: Friday, January 27 ,2423 8:49 AM
To: Brian Harris <brian [e-mail]>
Subject: Stack Test Report
Bria n,
Here is a copy of the stack test report. Please review and let me know of any changes. After any corrections, I will finalize
the report and send to DAQ thru the online portal.
The report is supposed to be sent to DAQ by February 11th.
The total cost for the project will be 57900. Let me know on a PO.
1
A<tA<-rl mar.f(
Brian Harris
Have a good weekend,
Dean
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Brian Harris
From:
Sent:
To:
Cc:
Subject:
Attachments:
Dean Kitchen <[e-mail]>
Friday, November 1, 2024 1:03 PM
'Kyle Greenberg'
Brian Harris; 'Jared James'
RE: Utah Division of Air Quality - Stack Test Reports - BYU - CENTRAL HEATING PLANT
BAGHOUSE BOILERS #4 AND #5 -HRU STACK (DUCT BURNER + TURBINE) AND BYPASS
STACK
HRU and Bypass Compliance Test February 2024 revl.pdf; BYU Boilers 4 and 6 Jan
2023.pdf
Kyte,
No probtem.
When the ontine portat first came out, I usuatty received an emait repty that a document was received. Then as
time went by, I stopped getting those emaits. Latety, atl I receive is an immediate response "Thanks for
Submitting..." with no identifying information.
Have a good weekend,
Dean
From: Kyle Greenberg <kgreenberg@uta h.gov>
Sent: Friday, 1 November,202412:58 PM
To: Dean Kitchen <[e-mail]>
Cc: Brian Ha rris <bria n_ha [e-mail] u>; Jared James <[e-mail]>
Subject: Re: Utah Division of Air Quality - Stack Test Reports - BYU - CENTRAL HEATING PLANT BAGHOUSE BOILERS #4
AND #6 -HRU STACK (DUCT BURNER + TURBINE) AND BYPASS STACK
Hi Dean,
ln this email thread wil,l, be fine. Thanks for getting this sorted out quickty.
Kyte
On Fri, Nov 1 ,2024 at12:42 PM Dean Kitchen <dean.kltehen@teteo:ut,com> wrote:
Kyte,
Do you want them on this email thread or via the ontine portat?
From: Kyle Greenberg <kgreenberg@uta h.sov>
Sent: Friday, 1 November,202410:49 AM
To: Brian Harris <brian [e-mail]>
Cc: Dean Kitchen <[e-mail]>; Jared James <[e-mail]>
Subject: Utah Division of Air Quality - Stack Test Reports - BYU - CENTRAL HEATING PLANT BAGHOUSE BOILERS #4 AND
#6 -HRU STACK (DUCT BURNER + TURBINE) AND BYPASS STACK
Mr. Harris:
l've been going through the DAQ records and it appear that the finial. Stack Test Reports were not
submitted for the fol.towing sources:
- Central Heating Ptant Baghouse Boiters #4 and #6
- HRU Stack (Duct Burner & Turbine) and Bypass Stack
l've attached copies of the pretest protocots for these tests for your records. Coul.d BYU ctarify what
happened with the final, reports and atso send in the reports so I can get them reviewed.
Thanks for your hel,p in this matter,
Kyte Greenberg
Kyle Greenberg
Enr,'ironmental Scientist I Minor Source Compliance
P: (SSs) So6-6Sgg
airqualit].utah.F,or
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Enrails to and fronr this email address may be considered public records and thus subject to Utah
GRAMA requirements.
A<tacf ,y.J7^rr
State of Utah
SPENCERJ. COX
Got'crnor
DEIDRE HBI.{DERSON
Lieutenont Governor
Department of
Environrnental Quality
KJmba.ly D, Shotloy
Exaculive Dlrcctot
DIVISION OF AIR QUALITY
Bryoo C, Bir.rl
Director .-_ _--l
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October 25,2022
Brian Harris
Bri gham Young University
Rislt Management Department
105 CBM
Pt'ovo, UT 84602
Mr'. Brian lIauis:
DAQC-1373-22
site ID lToeo (84)
Re: Brigham Young University - Main Campus - Boiler fH & Boiler #6 - Protocol Review and
Test Date Confinnation - Utah County
The testing protocol for Boiler #4 & Boiler #6 at Brigham Young University Main Campus i1
Utah County,IJtah, dated Octotl er 18,202?, has been reviewed and found acceptable. ihe agreed
upon test date is January 9-L1,2023.
Acceptance of a ptotocol does not relieve the owner/operator and the testing contr.actor fi.om strict
adherence to all applicable EPA methods, Utah Division of Air Quality (DAQ policies, Utah Air
Quality Rules (UAQR), and tnethods approved by the Director. Any deviation fiom EpA
methods, DAQ poticies, UAQI! and methods approved by the Director must be addressed
separately dtrd express written consent given prior to commencement of testing.
The DAQ requires that all test reports include a statement stating that:
Testing was conducted while the sonrce was operating at the rate and/or cond.itions
specifi.ed iu the applicable approval order, operating permit, or federal regulation.
During testing, the source combusted fuels, used raw materials, and rnaintained
process conditions represcntative of normal operutions, and operated undef such
othel relevant conrlitions specified by the Director.
Based on infonnation and belief formed after reasonable inquiry, the statements
and information containecl in the report,are truq accuratg and cornplete.
195 Norrt 19.t0 Wssr . Sall Lake City, UT
Mniling Addnrs: P,O. Box I 448n, Satt T.ake City, UT 841 I 44820I'elephonc (801) 5364000 . Fax [phone] . T,D.D, (B0l) 903-3978
t*w.lctt.t,tal, gov
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