DAQ-2025-000134

1

DAQC-1270-24
Site ID 11706(B1)

MEMORANDUM

TO: FILE – CITY OF OGDEN – Army National Guard

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: December 30, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County, AIRS #05700102
INSPECTION DATE: November 27, 2024

SOURCE LOCATION: The Army National Guard uses building 11C at 968 West 400
North at the Business Depot Ogden. Building 11C bay 2 houses
a command that depends on and manages the emergency
generator in Bay 1. Take I-15 Exit 344 for 12th Street, head east
to Depot Drive, turn left and go to 600 North, turn left and go
west to the open gate for building 11C go to the east side south
end of building.

SOURCE CONTACT(S): Joel Yoder: 801-476-3850

OPERATING STATUS: Generator was not operating at the time of inspection, but is in
an operational state.

PROCESS DESCRIPTION: The Caterpillar diesel generator is in bay 1 of building 11C and
supports activities in bay 2 (11C-2) JLTC. The standby generator
operates when power to bay 2 of the building is interrupted.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-845-97, dated August 29, 1997.

SOURCE INSPECTION
EVALUATION:

General Conditions:

1. This AO applies to the following company:

Facility Location
Defense Logistics Agency, Bldg. 11C-2
500 West 12th Street
Ogden, Utah 84407-500
Phone Number: [phone]
Fax Number: [phone]

* - ) - # )
2

The equipment listed below in this AO shall be operated at the following location:

PLANT LOCATION:
Universal Transverse Mercator (UTM) Coordinate System:
4,539.058 kilometers Northing; 415.892 kilometers Easting; Zone 12

Status: In compliance. Previous information about the address is carried over from the last full
inspection in 2016. That information is as follows:

The above address is the generic Ogden depot address. The Defense Logistics Agency no longer
has a role at the facility. The JLTC no longer operates at the site. The Army National Guard
leases the building from the City of Ogden. The facility’s current phone number is 801-476-3850.
The building address is as follows:

968 West 400 North
Bldg. 11C Bay 2
Ogden, Utah 84404

2. Definitions of terms, abbreviations, and references used in this AO conform to those used in the Utah
Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of Federal Regulations (40
CFR). These definitions take precedence unless specifically defined otherwise herein.

3. Defense Logistics Agency shall operate the Standby generator rated at 620 kW at Building #11C-2
according to the terms and conditions of this AO as requested in the Notice of Intent dated June 18,
1997.

Status: In compliance. The emergency diesel generator is located in building 11C-2. The generator
operates according to the conditions listed within this AO.

4. A copy of this AO shall be posted on site. The AO shall be available to the employees who operate
the air emission producing equipment. These employees shall receive proper instruction as to their
responsibilities in operating the equipment according to all of the relevant conditions listed below.

Status: In compliance. A copy of the AO was found onsite at the time of inspection.

5. The approved installations shall consist of the following equipment or equivalent*:

Diesel Powered Standby Generator at Building #11C-2
Make: Caterpillar*
Model: 3408 Industrial
Maximum Rated Power: 620 kW

Status: In compliance. The generator was observed to be onsite at the time of inspection.

3

Limitations and Tests Procedures

6. Visible emissions from the following emission points shall not exceed the following value:

A. All diesel engines - 20% opacity

Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR
60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use
procedures similar to Method 9, but the requirement for observations to be made at 15-second
intervals over a six-minute period shall not apply. Any time interval with no visible emissions shall
not be included.

Status: In Compliance. No visible emissions were observed at the time of inspection.

7. The approved standby generators shall meet the following limitations:

A. Maximum rated capacity of the diesel engine not to exceed 620 kW(463 hp)

B. Operation shall exceed 100 hours per generator per 12-month period

Operation includes periods when the generator is operated for testing/maintenance. Compliance with
this limitation shall be determined either by installation of an hour meter on each generator or by
recording hours on an operations log. The operations log shall include monthly recordings of the
hours of operation and calculated total hours of operation per month, and per 12 consecutive month
period. On the first working day of each month a new total shall be calculated and recorded. Records
of engine hours shall be kept for all periods when the plant is in operation. Records of engine hours
shall be made available to the executive secretary or her representative upon request and shall include
a period of two years ending with the date of the request. Engine hours of operation shall be
determined by examination of maintenance records, which shall be kept on site.

Status: In compliance. The rolling 12-month total the generator operated from November 2023 to
October 2024, was 6 hours. Hours of operation are kept by CAT Wheeler since they
conduct the testing for this generator. A report of the operation runtime and reason for
operation for each visit is sent to the staff at the Army Depot. They are scheduled to visit
every month to test the generator. They have not had to operate this generator other than
for testing in the last 3 years.

Fuels

8. The sulfur content of any fuel oil or diesel burned shall not exceed 0.05 percent by weight. Sulfur
content shall be decided by ASTM Method D-4294-89, or approved equivalent. The sulfur content
shall be tested if directed by the executive secretary.

Status: Compliance not determined. Fuel is provided by CAT Wheeler when they run the generator
for monthly testing. Source didn’t provide an invoice on the fuel that stated the explicit
sulfur content. Source confirmed at the time of inspection that the fuel CAT Wheeler uses is
purchased from a source in the state of Utah.

4

Records & Miscellaneous

9. All installations and facilities authorized by this AO shall be adequately and properly maintained.
Maintenance records shall be maintained while the plant is in operation. A copy of all manufacturers'
operating instructions for pollution emitting equipment shall be kept on site. These instructions shall
be available to all employees who operate the equipment and shall be made available to compliance
inspectors upon their request.

Status: In compliance. Source maintains records of maintenance from CAT Wheeler when they
conduct monthly testing and maintenance. There is also a tag that is attached to the start up
box that shows the date of last inspection.

10. The owner/operator shall comply with R307-1-3.5, UAC. This rule addresses emission inventory
reporting requirements.

Status: In compliance. Emission Inventory is not required. R307-1-3.5 is now R307-150.

11. The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses unavoidable breakdown
reporting requirements. Any breakdown lasting longer than two hours shall be reported to the
executive secretary within three hours of the breakdown if reasonable, but in no case longer than 18
hours after the beginning of the breakdown. During times other than normal office hours, breakdowns
for any period longer than two hours shall be initially reported to the Environmental Health
Emergency Response Coordinator. Within seven calendar days of the beginning of any breakdown
lasting longer than two hours, a written report shall be submitted to the executive secretary. The
owner/operator shall calculate/estimate the excess emissions (amount above AO limits) whenever a
breakdown occurs. The total of excess emissions per calendar year shall be reported to the executive
secretary with the inventory submittal, as directed by the executive secretary.

Status: In compliance. No breakdowns have occurred. R307-1-4.7 is now R307-107.

12. All records referenced in this AO, which are required to be kept by the owner/operator, shall be made
available to the executive secretary or her representative upon request and shall include a period of
two years ending with the date of the request. All records shall be kept for a period of two years . A
summary of those records that is required as part of this AO is included herein. This summary shall be
not considered to be an additional requirement, but shall be considered as an informational source
only. The condition that requires that these records to be kept as part of the compliance with this AO
is listed following the individual record. Examples of records to be kept at this source shall include
the following as applicable:

A. Maintenance records (Condition number 10)
B. Emission inventory (Condition number 11)
C. Upset, breakdown episodes (Condition number 12)
D. Hours of operation (Condition number 8B)

Status: In compliance. Records are maintained as required. No Emission Inventory is required at
this source.

40 CFR Part 63 Subpart A: General Provisions

Status: Compliance with subpart A is determined by compliance with applicable federal subparts.
In Compliance with Subpart ZZZZ.
5

40 CFR Part 63 Subpart ZZZZ–National Emission Standards for Hazardous Air for Stationary
Reciprocating Internal Combustion Engines (RICE)

1. 40 CFR 63.6585 Am I Subject to this Subpart?

Status: In compliance. The existing 403 hp emergency generator is subject to the rule. Since this
generator is operated by the U.S. Army, they could apply for an exemption to Subpart
ZZZZ. To this date there has been no notification made for an exemption to Subpart ZZZZ
based on this possible exemption.

2. 40 CFR 63.6660(b) and (c) must keep each record readily accessible for five years in hard copy or
electronic form.

Status: In compliance. The generator operated for 6 hours over the past rolling 12 months. Source
maintains records of operation and has the generator maintained by CAT Wheeler. This
was viewed onsite at the time of inspection.

EMISSION INVENTORY: Emissions from the generator are expected to be below the minor
source threshold based on previous evaluation. The permitted
generators expected emissions:

Pollutants Ton/Year
PM10 0.9
SO2 0.18
NOx 0.96
CO 0.22
VOC 0.03

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance with conditions listed within the AO. The
generator is operational, however it only operates for testing and
hasn’t been used for emergency situations in years. At the time
of inspection information was given to Joel Yoder, who oversees
this generator, on how to apply for either a Small Source
Exemption or a permit revocation. Contact information was
provided on how to start with that process.

RECOMMENDATION FOR
NEXT INSPECTION: Check to see if the source has filed for a Small Source
Exemption or Permit Revocation. If so, inspection may not be
required at this facility any longer.

NSR RECOMMENDATION: This permit should be submitted for a 10-Year Review if the
source maintains the permit as is. Otherwise, the source should
be recommended to file for a Small Source Exemption or a
Permit Revocation.

ATTACHMENTS: None