DAQ-2025-000171

1

DAQC-CI107900001-24
Site ID 10790 (B1)

MEMORANDUM

TO: FILE – BRIGHAM YOUNG UNIVERSITY – Main Campus

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: December 20, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: August 26, 2024

SOURCE LOCATION: B-340 ASB
Brigham Young University
Provo, UT 84602
DIRECTIONS: The Environmental Health & Safety Office is
located in the Chemicals Management Building on
the east side of the campus off 900 East and 1100
North.

SOURCE CONTACTS: Brian Harris, Environmental Manager
385-225-7767, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Central Heating Plant (CHP): A Solar Titan 130 combustion
turbine with attached heat recovery unit (HRU) was installed to
replace 4 of the hot water generators. The HRU uses heat
extracted from the turbine exhaust to generate hot water within
the CHP. The turbine also generates electricity used by the
campus. The combined turbine and HRU (with duct burners) is
referred to as the cogen unit. Excess electricity generated can be
sold on the grid. The two 192 MMBtu/hr boilers (natural gas,
fuel oil backup) are now backup to the cogen unit and only
needed when the cogen unit is down. The new plant includes the
turbine, HRU duct burners (utilized when campus hot water
demand is greater than what the Titan 130 exhaust can generate,
mainly in winter months when campus hot water energy demand
is high), HRU selective catalytic reduction (SCR) and oxidation
catalyst for carbon monoxide, volatile organic compound, and
formaldehyde control.

0 0
2

University laundry: The dry cleaning machines now use iso-
paraffin hydrocarbon (IPH) as solvent. The facility is also
equipped with two 8.0 MMBtu/hr low NOx boilers which
provide heat for comfort heating, clothing presses, and clothing
dryers. Emissions from each boiler are vented through roof vents
on the top of the building.

University press building: A short-run printing plant produces
catalogues, course schedules, and the school newspaper using 2
sheet and web fed presses. Soy-based quickset inks are used.
These inks are adsorbed by the substrate and emit only negligible
levels of VOC's in the atmosphere. The majority of the facility's
VOC/HAP emissions are generated during the cleaning of ink-
stained presses and other equipment with cleaning solvents. No
emissions controls are used. The building also has 4 Lochinvar
PBN 1000 natural gas boilers (1 MMBtu/hr each) which provide
hot water for use in nearby buildings.

Paint booths: There are 4 paint booths and several smaller
booths on campus. Overspray and VOC emissions from the
Brewster Paint Shop booth are drawn through a bank of paint
particulate arrester pads at a design rate of 12,000 ACFM. The
paint collects on the filter pads and the VOCs are vented to
ambient through a 4'x3' circular stack located on the roof of the
building. Overspray and VOC emissions from the Auto Shop
Paint booth are drawn through a bank of paint particulate arrester
pads at a design rate of 2,850 ACFM. The paint collects on the
filter pads and the VOCs are vented to ambient through a 5'x2'
circular stack on the roof of the shop. Overspray and VOC
emissions from the Physical Facilities North booth are drawn
through a bank of paint particulate arrester pads at a design rate
of 5,966 ACFM. The paint collects on the filter pads and the
VOCs are vented to ambient through a 10'x2' circular stack on
the roof of the building. The fourth booth is located in the Snell
Building and is of the same design as listed above.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN107900021-23, dated
May 24, 2023

NSPS (Part 60) -Db: Standards of Performance for Industrial-
Commercial-Institutional Steam Generating Units,
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,
NSPS (Part 60) -KKKK: Standards of Performance for
Stationary Combustion Turbines,
NESHAP (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.
3

SOURCE EVALUATION:

Name of Permittee:

Permitted Location:
Brigham Young University
Main Campus

105 CMB Attn: Environmental Manager B-340 ASB Brigham Young University
Provo, UT 84602 Provo, UT 84602

SIC Code: 8221: (Colleges, Universities, & Professional Schools)

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]
4

Status: Out of compliance with condition I.8 for failure to submit required notifications. In
compliance will all other conditions in Section I. No further action is currently
recommended. No limits appear to have been exceeded. No modifications have been made
to equipment or process. Records are maintained and kept as required. Regular
maintenance is conducted. 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 Main Campus
BYU Main Campus
II.A.2 Cogen Unit
One (1) Combustion Turbine
Fuel type: Natural Gas
Maximum turbine rating: 16.2 megawatt (MW) | (170 MMBtu/hr)
Location: Central Heating Plant

Heat Recovery Unit (HRU)
Associated Duct Burners
Fuel type: Natural Gas
Maximum heat input: 85 MMBtu/hr
Controls: SCR and Oxidation Catalyst
NSPS: Subpart KKKK
II.A.3 Two (2) Boilers (**NEW**)
Fuel type: Natural gas
Maximum heat input capacity: 8.0 MMBTU/hr (each)
Location: University Laundry Building
Controls: Low NOx burner, oxygen trim, and flue gas
recirculation
II.A.4 Two (2) Boilers (Unit #4 & Unit #6)
Fuel type: Natural gas with fuel oil as a backup fuel
Maximum heat input capacity: 192.0 MMBTU/hr (each)
Location: Central Heating Plant
NSPS: Subpart Db
5

II.A.5 Boilers*
Fuel type: Natural Gas
Maximum heat input capacity: Each less than 5.0 MMBTU/hr
Location: Various buildings

*This equipment is listed for informational purposes only.
II.A.6 Dry Cleaning Equipment
Three (3) dry cleaning units utilizing iso-paraffin hydrocarbon (IPH) as solvent
II.A.7 Teaching Kilns*
Fuel type: Natural gas
Location: East of Building #66

*Listed for informational purposes only.
II.A.8 Four (4) Paint Booths
Locations: Brewster Building
Auto Shop
Snell Building
Auxiliary Services Building
Associated controls: Particulate arrestor filters
II.A.9 Small Paint Booths
Paint booths using spray cans for minor painting/teaching.

The paint booths are located at several locations at the BYU Campus: B73- East of Snell Building,
Brewster Building, Clyde Building, Fletcher Building, Harris Fine Arts Center, Monte L Bean
Building, Stephen L Richards Building, University Press Building, Wilkinson Building Student
Center, Museum of Art, IT Building.
II.A.10 Bio-Safety Laboratory
Associated controls: HEPA filtering system controls emissions from the
containment hood exhaust stack.
II.A.11 Printing Equipment
II.A.12 Six Fuel Storage Tanks
Location: Central Heating Plant
Capacity: 30,000 gallons each (three tanks)
Fuel type: Fuel oil
6

Location: Broadcast Building
Capacity: 20,000 gallons (one tank)
Fuel type: Fuel oil

Location: Music Hall (**NEW**)
Capacity: 225 gallons (one tank)
Fuel type: Diesel

Location: Chemicals Management Building (**NEW**)
Capacity: 374 gallons (one tank)
Fuel type: Diesel
II.A.13 One (1) Cyclonic Dust Collector
Location: Snell Building

This dust collector was installed prior to November 29, 1969 and has no permit requirements.
II.A.14 Two (2) Baghouse Dust Collectors*
Location: Brewster Carpentry Shop
Flow Rate: Max of 20,000 cfm
Location: Auxiliary Services Building

*Note: This equipment vents inside the building.
II.A.15 Diesel-Fired Emergency Generators <200 Hp

Location Maximum Engine Rating (hp)

Miller Park Baseball Fields (26 hp)
Wyview Telephone Node (67 hp)
Wyview Park (67 hp)
West Substation (69 hp)
Helaman Halls Telephone Node (75 hp)
Ellsworth Building (99 hp)
J. Reuben Clarke Law Building (145 hp)
Brimhall Building (150 hp)
Music Hall (198 hp) (**NEW**)
II.A.16 Diesel-Fired Emergency Generators 200-350 Hp
Location Maximum Engine Rating (hp)

Bean Life Science Museum (324 hp)
Conference Center (201 hp)
7

Harman Continuing Education Building (324 hp)
Information Technology Building (250 hp)
Wilkinson Center (268 hp)
Indoor Practice Facility (308 hp)
Life Science Greenhouse (324 hp)
LaVell Edwards Stadium (324 hp)
Chemicals Management Building (324 hp) (**NEW**)
Smoot Administration Building #1 (335 hp)
Smoot Administration Building #2 (335 hp)
Cannon Center (352 hp)
II.A.17 Diesel-Fired Emergency Generators 350-600 Hp
Location Maximum Engine Rating (hp)

Jesse Knight Building (380 hp)
Joseph F. Smith Building (450 hp)
Marriott Center (464 hp)
Auxiliary Services Laundry Building (464 hp)
II.A.18 Diesel-Fired Emergency Generators 600-2000 Hp
Location Maximum Engine Rating (hp)

Tanner Building (755 hp)
Clyde Engineering Building (755 hp)
Kimball Tower (755 hp)
Student Health Center (804 hp)
New Engineering Building (1490 hp)
Benson Building #1 (1005 hp)
Benson Building #2 (1005 hp)
Heritage Hall Complex #1 (1220 hp)
Heritage Hall Complex #2 (1220 hp)
II.A.19 Diesel-Fired Emergency Generators >2000 Hp
Location Maximum Engine Rating (hp)

Broadcast Building #1 (2922 hp)
Broadcast Building #2 (2922 hp)
Physical Plant Central Heating (2220 hp)
Talmage Building #1 (2220 hp)
Talmage Building #2 (2220 hp)
Talmage Building #3 (2220 hp)
Life Science Building (2220 hp)
II.A.20 Portable Emergency Generators*
Diesel and propane fired emergency generators that are moved to various locations on campus as
needed.
8
*This equipment is listed for informational purposes only.
Status: In Compliance. Equipment observed during the inspection was consistent with that listed.

Additional information:

II.A.2 – Cogen Unit – The turbine is a Solar Titan 130. The Cogen unit equipment operates
continuously 8,760 hours per year. All electricity produced is sent to the power grid. Only heat
produced by the unit is used on campus. The unit is equipped with a Rockwell Automation-brand
CEMS to monitor urea use through the catalyst.

II.A.4 – Two (2) Boilers (Unit #4 and Unit #6) – These are Volcano-brand boilers that
were manufactured in 1992.

II.A.6 – Dry Cleaning Equipment –There are two Ipura-brand dry cleaning machines and one
Columbia USA-brand.

II.A.8 – Four (4) Paint Booths –
○ Brewster Building’s paint booth is equipped with a magnehelic gauge to notify the source
when the particulate filters need to be changed.

○ Auto Shop’s paint booth is equipped with a magnehelic gauge to notify the source when the
particulate filters need to be changed. The Auto Shop’s paint booth is also a downdraft
booth that is equipped with a baking function to cure paints in less time.

○ Snell Building’s paint booth is a project-based booth that uses only aerosol spray can paint.

○ Auxiliary Services Building is gone. It has been replaced with the Physical Facilities
North building. This booth is a project-based booth that uses only aerosol can paint and
is equipped with a magnehelic gauge to notify the source when the particulate filters
need to be changed.

○ The source uses a Herkules-brand paint gun washer to wash the paint guns. The unit also
recycles the cleaning solvent.

II.A.11 – Printing Equipment – The print shop operates a three-color Roland press and a five-
color Heidelberg press.
II.A.15 through II.A.19 – The source maintains a detailed list of each emergency generator listed in
the equipment list.

II.B Requirements and Limitations

II.B.1 Campus Wide Limitations and Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:
9
A. Cogen Unit (Combustion turbine and HRU duct burners) - 10% opacity

B. All natural gas fueled boilers equal to or greater than 5.0 MMBTU/hr - 10% opacity

C. All paint booth exhaust stacks - 10% opacity

D. All baghouse exhaust stacks - 10% opacity

E. All cyclonic separator exhaust stacks - 20% opacity

F. All print shop equipment exhaust stacks - 10% opacity

G. All diesel engines - 20% opacity

H. All other emission points - 20% opacity

[R307-305-3]
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.2 Central Heating Plant.
II.B.2.a The owner/operator shall be limited to the following consumption/operating conditions:

A. Unit #4 shall not exceed 151,373 MMBtu/yr of heat input per calendar year*

B. Unit #6 shall not exceed 151,373 MMBtu/yr of heat input per calendar year*

C. The Duct Burner shall not exceed 365,292 MMBtu/yr heat input per calendar year*

D. The Combustion Turbine bypass shall not exceed 297,840 MMBtu/yr heat input per
calendar year*

E. Fuel oil usage shall not exceed 90,000 gallons per calendar year**

*Calendar year is defined as January 1st through December 31st

**This limitation shall not apply during times of natural gas curtailment.

[R307-401-8]
II.B.2.a.1 Compliance with these limitations shall be determined on an annual basis. Based on the first day
of each month, a new monthly total shall be calculated. Monthly calculations shall be made no
10
later than 20 days after the end of each calendar month. Monthly totals for January through
December shall determine annual compliance. Records of fuel oil consumption shall be kept for
all periods when the Central Heating Plant is in operation. Consumption of fuel oil shall be
determined by examination of each fuel supplier's billing records along with supervisor
monitoring and maintaining operations logs showing which day(s) fuel oil was used. The records
of consumption shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. Records were reviewed at the time of inspection. Records reported
the following consumption/operating totals for the 2023 calendar year:

21,450 MMBtu of heat input for Unit #4
17,951 MMBtu of heat input for Unit #6
16,999 MMBtu of heat input for the Duct Burner
87,350 MMBtu for the Combustion Turbine bypass
0 gallons of fuel oil
II.B.2.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations (all ppmdv @ 15% O2 dry) :

CHP Boilers Pollutant lb/hr ppmdv
Boiler #4 NOx 19.2 36
Boiler #6 NOx 19.2 36
CHP CoGen Operation Pollutant lb/hr ppmdv
HRU Stack (Duct Burner + Turbine): NOx 2.3 2.5
CO 1.6 3.0
CHP CoGen Operation Pollutant lb/hr ppmdv lb/mmbtu
Bypass Stack: NOx 9.2 15.0 0.054
CO 9.4 25.0 0.055

Testing to show compliance with the emission limitations stated in the above condition shall be
performed as specified below:

CHP
Testing Test
Emission Point Pollutant Status Frequency
Boiler #4 Stack NOx * #
Boiler #6 Stack NOx * #
HRU Stack NOx ** ##
CO ** #
Bypass Stack NOx ** ##
CO ** #

Testing Status

* The initial testing has already been performed.
** Initial testing shall be performed within 180 days of the start of the first winter season
11
(November - February) of the CoGen plant startup.
# The test shall be performed at least once every 3 years based on the date of the last
stack test.
## The test shall be performed as per the schedule contained in 40 CFR 60 Subpart KKKK
subsequent to the initial compliance test - at least once every year if the previous
Compliance test exceeds 75% of the NOx emission limit or once every 2 years if the
previous compliance test is less than or equal to 75% of the NOx emission limit (no
more than 26 calendar months following the previous performance test).

[R307-401]

Status: Out of Compliance. Stack tests were conducted February 23 and 24, 2022. Test
results were accepted by DAQ (DAQC-1354-22). Boilers #4 and #6 were stack tested
January 10 and 11, 2023, but results were not submitted to DAQ. Those results were
submitted to DAQ on November 1, 2024. The DAQ stack test reviewer found an issue with
testing duration and issued a compliance advisory (DAQC-1139-24). Results were as
follows:

Boiler #4: 13.1 lb/hr, 31.2 ppmdv
Boiler #6: 13.9 lb/hr, 33.3 ppmdv
Bypass Stack NOx: 0.037 lb/mmBtu, 10.103 ppmdv, 6.251 lb/hr
Bypass Stack CO: 0.0067 lb/mmBtu, 2.597 ppmdv, 0.990 lb/hr
HRU Stack NOx: 2.297 ppmdv, 1.930 lb/hr
HRU Stack CO: 1.040 ppmdv, 0.532 lb/hr
II.B.2.c A. Notification

Testing shall be performed between November 1 and February 28/29. A source test protocol shall
be submitted to the Director by October 1, with notification of actual testing at least 10 days
prior to conducting any emission testing required under any part of UAC, R307. The owner or
operator shall notify the Director of the date, time and place of such testing and shall submit a
source test protocol to the Director. The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. If directed by the Director, the
owner/operator shall attend a pretest conference. The pretest conference shall include
representation from the owner/operator, the tester, and the Director.

B. Reporting

Upon completion of the DAQ accepted testing methods, the owner/operator shall submit a copy
of the results from each performance test as conducted to the Director within 60 days after the
test has been completed.

C. Sample Location

The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved testing method, as acceptable to the Director. An Occupational
Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)
12

approved access shall be provided to the test location.

D. Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2 or other EPA-approved testing method, as acceptable to the
Director.

E. Carbon Monoxide (CO)

40 CFR 60, Appendix A, Method 10, or other EPA approved test method, as acceptable to the
Director.

F. Nitrogen Oxides (NOx)

40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing method,
as acceptable to 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. New Source Operation (Combustion Turbine & Duct Burner)

For the combustion turbine, the production rate during the initial compliance test shall be no less
than 90% of the production rate listed in this AO. If 90% of the maximum AO allowable
production rate has not been achieved at the time of the test, the following procedure shall be
followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of
the tested achieved rate, but not more than the maximum allowable production rate.
This new allowable maximum production rate shall remain in effect until successfully
tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing
at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is
successful. This process may be repeated until the maximum AO production rate
is achieved.

For the duct burner, the production rate during the initial compliance test shall be no less than
90% of the production rate achieved to date.

I. Existing Source Operation

For an existing source/emission point, the production rate during all compliance testing shall be
13

no less than 90% of the average production achieved in the previous three years.

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
procedures to be used. A pretest conference shall be held, if directed by the Director.

[R307-165, R307-401-8]

Status: Out of Compliance. Test protocol has been reviewed and approved by DAQ
(DAQC-1593-21 and DAQC-1373-22) but results were not submitted for the test of
Boilers #4 and #6.
II.B.2.d The owner/operator shall burn natural gas as fuel in the CoGen Unit. The sulfur emissions shall
not exceed 0.06 lb SO2/MMBtu heat input. [40 CFR 60 Subpart KKKK, R307-401-8]
II.B.2.d.1 The owner/operator shall monitor the total sulfur content of the fuel being fired in the CoGen
Unit, except as provided in 40 CFR 60 Subpart 60.4365. The sulfur content of the fuel shall be
determined using total sulfur methods described in 40 CFR 60 Subpart 60.4415. [R307-401-8]
II.B.2.d.2 Records of fuel sulfur content shall be maintained by the owner/operator and made available to
the Director or Director's representative upon request. [R307-401-8]

Status: In Compliance. Natural Gas usage records are kept by the source. All natural gas
is purchased through Enbridge Gas (formerly Dominion Energy) and meets the sulfur
content requirement.
II.B.3 Federal Combustion Turbine Limitations and Requirements
II.B.3.a If the owner/operator supplies more than one third of the gas turbine potential electrical output
capacity to any power distribution system for sale, the turbine will be considered as a utility unit
and will be classified as an unaffected unit by the Acid Rain Program regulations, except for 40
CFR 72.2 through 72.7 and 72.10 through 72.13. An Acid Rain permit will not be required, nor
acid rain emission monitoring and reporting, but the owner/operator shall be subject to submittal
of the New Unit Exemption form to the permitting authority by the end of the first calendar year
for which the exemption is to apply. [R307-415]

Status: Compliance not determined. The source is in compliance for filing the acid rain
exemption on April 2, 2019 (attached), but the inspection did not determine the amount of
electricity generated by the gas turbine that is sent to the grid.
II.B.4 Dry Cleaning Equipment
II.B.4.a Dry cleaning equipment shall not exceed 55.6 gallons of iso-paraffin hydrocarbon (IPH)
consumption per rolling 12-month period. At initial start-up, all dry cleaning equipment will be
filled to a volume of up to 175 gallons total of IPH. This initial fill volume shall not be included
in the rolling 12-month total. No other VOC or HAP emitting solvent shall be used for dry
cleaning application. [R307-401-8]
14

II.B.4.a.1 Compliance shall be determined on a rolling 12-month total. Based on the first day of each
month, a new 12-month total shall be calculated using data from the previous 12 months.
Monthly calculations shall be made no later than 20 days after the end of each calendar month.
Consumption shall be determined by examination of each supplier's billing records and use of
IPH each month. Records of consumption shall be kept for all periods when the dry cleaning
system is in operation. [R307-401-8]

Status: In Compliance. Observed records reported 11.5 gallons of iso-paraffin hydrocarbon
had been consumed in the 12-month period.
II.B.5 Paint Booth and Printing/Publishing Limitations
II.B.5.a The plant-wide emissions of VOCs and HAPs from the paint booths and printing/publishing
operations shall not exceed:

A. 16.00 tons per rolling 12-month period for VOCs

B. 0.30 tons per rolling 12-month period for Xylene

C. 3.42 tons per rolling 12-month period for any combination of HAPs not listed above.

Compliance with each limitation shall be determined on a rolling 12-month total. No later than
20 days after the end of each month, a new 12-month total shall be calculated using data from the
previous 12 months.

[R307-401-8]
II.B.5.a.1 The VOC and HAP emissions shall be determined by maintaining a record of VOC- and HAP-
emitting materials used each month. The record shall include the following data for each
material used:

A. Name of the VOC- and HAP- emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, toxics, isocyanates, etc.

B. Density of each material used (pounds per gallon)

C. Percent by weight of all VOC and HAP in each material used

D. Gallons of each VOC- and HAP-emitting material used

E. The amount of VOC and HAP emitted monthly by each material used shall be
calculated by the following procedure:

VOC = (% VOC by Weight/100) x [Density (lb/gal)] x Gal Consumed x 1 ton/2000 lb
HAP = (% HAP by Weight/100) x [Density (lb/gal)] x Gal Consumed x 1 ton/2000 lb
F. The amount of VOC or HAP emitted monthly from all materials used.
15

G. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC or
HAP emissions.

[R307-401-8]

Status: In Compliance. Records appear to be maintained and calculated as directed.
Observed records reported the following 12-month totals:

0.274 tons of VOC
0.013 tons of Xylene
0.073 tons of combined HAPs
II.B.5.b The paint booth locations at the Brewster Building, Auto Shop, Auxiliary Services Building, and
Snell Building shall be equipped with a paint arrestor particulate filter, or equivalent, to control
particulate emissions. All exhaust air from each of the paint booths shall be routed through its
particulate control system before being exhausted to the atmosphere. [R307-401-8]

Status: In Compliance. All observed paint booths were equipped with particulate filters.
II.B.6 Emergency Diesel Generator Requirements
II.B.6.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 engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.6.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:

1. The date the emergency engine was used

2. The duration of operation in hours

3. The reason for the emergency engine usage

[40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.6.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. Generators are tested once a month. Operation is logged as
required and each generator is equipped with a non-resettable hour meter. Records were
reviewed at the time of inspection. All generators operated under the 100-hour limits for
testing and maintenance.
16

II.B.6.b The sulfur content of any fuel oil burned in the stationary diesel engines on site shall not exceed
15 ppm by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. Fuel was purchased through Christensen Oil and is ultra-low
sulfur.
II.B.6.c 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. Fuel was purchased through Christensen 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.

NSPS (Part 60) -Db: Standards of Performance for Industrial-Commercial-Institutional Steam Generating
Units
Status: Out of compliance for failure to test in accordance with Subpart Db requirements. See status of
condition II.B.2.b for more information. This subpart is applicable to Boilers #4 and #6 (II.A.4).
Compliance with this subpart is satisfied by compliance with AO conditions II.B.2.a - A., B., and E. for
the NOx standards and AO condition II.B.2.a.1 for low sulfur fuel and hours operated on fuel oil. The
boilers did not run on fuel oil in 2023. See the 2019 inspection memo (DAQC-0651-2019) for a more
detailed evaluation of this subpart.
NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units
Status: Not Applicable. The two 12.6 MMBtu/hr boilers which were on the previous AO have been
replaced by the two 8.0 MMBtu/hr boilers listed as item II.A.3.
NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
Status: In Compliance. This subpart is applicable to 21 of the 41 emergency generators. Compliance
with this subpart is satisfied by maintaining copies of manufacturer's specification of emission standards
and tier ratings, maintaining and operating the engines in accordance with manufacturer's instructions,
use of low sulfur diesel fuel, and not exceeding 100 hours per year for non-emergency use. The source
confirmed they operate the generators in accordance with manufacturer's instructions with
maintenance being conducted per the manufacturer's specification. Each engine is equipped with a
non-resettable hour meter with use being tracked and categorized.
17

NSPS (Part 60) -KKKK: Standards of Performance for Stationary Combustion Turbines

Status: In Compliance. This subpart is applicable to the turbine and heat recovery unit (II.A.2).
Compliance with this subpart is satisfied by conducting stack testing in accordance with AO condition
II.B.2.b and meeting the sulfur requirements in AO conditions II.B.2.d, II.B.2.d.1, and II.B.2.d.2.
NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines.
Status: In Compliance. This subpart is applicable to 20 of the 41 emergency generators. Compliance
with this subpart is satisfied by maintaining and operating the engines in accordance with
manufacturer's instructions, use of low sulfur diesel fuel, and not exceeding 100 hours per year for
non-emergency use. The source confirmed they operate the generators in accordance with
manufacturer's instructions with maintenance being conducted per the manufacturer's specification.
Each engine is equipped with a non-resettable hour meter with use being tracked and categorized.

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. This area source rule is applicable to diesel fuel used at the source location
for boilers #4 and #6 and the emergency generator engines. Diesel fuel was purchased through
Christensen Oil and was certified ultra-low sulfur.
Stationary Sources [R307-210]

Status: In Compliance. This area source rule is applicable per Subparts Db, IIII, and KKKK.
Applicable subpart requirements are satisfied by compliance with Section III of the AO.
National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This area source rule is applicable per R307-214-2. Sources Subject to Part
63. (77) 40 CFR Part 63 Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion Engines.
Subpart ZZZZ requirements are satisfied by compliance with Section III of the AO.
Solvent Cleaning [R307-304]

Status: Not Applicable. R307-304-3(1) states that the requirements of R307-304 do not apply to
the operations that are subject to R307-342 through R307-347 and R307-349 through R307-355.
The source is subject to R307-342, R307-343, R307-350, R307-351, and R307-354. Each of these
rules contain their own solvent cleaning requirements.
18

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. This area source rule is satisfied by compliance with AO condition II.B.1.a.
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. See status of the remaining area source rules for additional information.
Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. The source has several parts cleaners which are maintained by Safety
Kleen, and use Safety Kleen solvent that meets the VOC standard. All observed parts washers
were closed and had posted instructions.
Adhesives and Sealants [R307-342]

Status: In Compliance. The source maintains a spreadsheet of all VOC-containing products. VOC
content is included in the spreadsheet. Applicable products meet the designated limits.
Davis and Salt Lake Counties and Ozone Nonattainment Areas: Emissions Standards for Wood Furniture
Manufacturing Operations [R307-343]
Status: In Compliance. The source maintains a spreadsheet of all VOC-containing products. VOC
content is included in the spreadsheet. Applicable products meet the designated limits.
Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. The source maintains a spreadsheet of all VOC-containing products. VOC
content is included in the spreadsheet. Applicable products meet the designated limits.
Graphic Arts [R307-351]

Status: In Compliance. The source maintains a spreadsheet of all VOC-containing products. VOC
content is included in the spreadsheet. Applicable products meet the designated limits.
19

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Brigham Young University
– Main Campus. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN107900021-23, dated May 24, 2023, is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 118451.00
Carbon Monoxide 56.24 10.281
Nitrogen Oxides 66.55 37.908
Particulate Matter - PM10 15.80 5.457
Particulate Matter - PM2.5 14.40 5.445
Sulfur Dioxide 0.63 0.568
Volatile Organic Compounds 14.95 4.562

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN107900021-23,
dated May 24, 2023, the overall status is: Out of Compliance.
Out of compliance with condition II.B.2.b for failing to submit
stack test results and failing to test for the required time. The
facility appears to be otherwise well maintained and properly
operated. The majority of records were provided at the time of
inspection for review, the remainder were emailed. Ongoing
compliance action is still in process for compliance advisory
DAQC-1139-24.

HPV STATUS: Not Applicable.
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

Acetaldehyde (CAS #75070) 536 2
Acrolein (CAS #107028) 8
Benzene (Including Benzene From Gasoline) (CAS #71432) 618 2.6
Formaldehyde (CAS #50000) 922 94
Generic HAPs (CAS #GHAPS) 2502
Hexane (CAS #110543) 2260 2274
Metal HAPs (CAS #MHAPS) 8 3.4
Propylene Dichloride (1,2-Dichloropropane) (CAS #78875) 0
Propylene Oxide (CAS #75569) 1708
Selenium & Compounds (CAS #253) 0 0
Toluene (CAS #108883) 434 26.8
Xylenes (Isomers And Mixture) (CAS #1330207) 600 13.4
20

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal. May want to contact Brian Harris prior to
visit, his office is in a secure building with key card access.
Confirm follow-up stack testing was conducted to confirm
compliance with Subpart Db.

NSR RECOMMENDATIONS: Confirm for II.A.3 if the boilers are new or if only new burners
were installed in the existing boilers.

Evaluate the solvent-based parts washers on campus for
inclusion on the equipment list.

AO condition II.B.1.a should include a 20% opacity limit for
when the 192 MMBtu/hr boilers (II.A.2) are fired on fuel oil.

Evaluate removing the opacity limits for AO condition II.B.1.a –
D. and E. as this equipment vents internally.

The Auxiliary Services Building, and associated paint booth, are
gone. Update II.A.8 to remove the Auxiliary Services Building.

Evaluate moving the Snell Building’s paint booth to II.A.9 as it
uses only spray cans for student projects.

Add the Physical Facilities North paint booth to II.A.9 as it uses
only spray cans for student projects.

ATTACHMENTS: VEO Form, Acid Rain Exemption, Natural Gas Sulfur Content
Explanation, Email
Jared James <[e-mail]>
Air Quality Inspection
Brian Harris <[e-mail]>Mon, Aug 26, 2024 at 11:02 AM
To: Jared James <[e-mail]>
Cc: Brian Harris <[e-mail]>
Hi Jared,

It was a pleasure to meet you this morning. You requested to see the completed New Unit Exemption form mentioned in
II.B.3.a of our BYU Approval Order (DAQE-AN107900021-23).

Please find attached the letter BYU sent to Bryce Bird April 2, 2019 regarding the New Unit Exemption form including the
attached completed and signed New Unti Exemption form for BYU, along with the Certified Mail Receipts showing that the
New Unit Exemption form was submitted to the EPA, the EPA Region VIII, and the Utah Div. of Air Quality.

Sincerely,
Brian Harris
[Quoted text hidden]
CoGen New Unit Exemption for DAQ.pdf
8213K
10/2/24, 2:34 PM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permmsgid=msg-f:1808470390979328895&simpl=msg-f:1808470390979328895 1/1
Jared James <[e-mail]>
Audit Follow Up
2 messages
Brian Harris <[e-mail]>Thu, Sep 5, 2024 at 1:51 PM
To: "Jared James ([e-mail])" <[e-mail]>
Cc: Brian Harris <[e-mail]>
Hi Jared,

During our recent audit, we discussed the sulfur content in the natural gas which is purchased and used by Brigham
Young University in the Central Heat Plant, and in other locations across campus.

Enbridge Gas (formerly Dominion Energy) has shared their Tariff Sheet which outlines the sulfur content in the natural
gas, that they distribute to BYU and other customers. The fuel quality characteristics in this current Tariff Sheet…specify
the maximum total sulfur content. Here is the link to Enbridge’s Tariff Sheet.

Utah (cdn-dominionenergy-prd-001.azureedge.net)

The gas quality specifications may be found starting on page 93 of the pdf and the sulfur limit found on the top of page 94.

Here is a quick summary of what the Tariff Sheet entails; “Enbridge Gas may refuse to accept gas that does not conform
to the specifications listed below and other requirements set forth in this Tariff;
8. Total Sulfur. The gas shall not contain more than 5 grains of total sulfur per 1,000 standard cubic feet (MSCF) of 8.4
parts per million by volume (ppmv), of which not more than 2 grains shall be mercaptan sulfur.”

Again, it was a pleasure to meet you and to show you around BYU.

Sincerely,
Brian Harris

Jared James <[e-mail]>Mon, Sep 9, 2024 at 7:58 AM
To: Brian Harris <[e-mail]>
This is great, thanks Brian!
[Quoted text hidden]
10/2/24, 2:50 PM State of Utah Mail - Audit Follow Up
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1809386976630928973&simpl=msg-f:180938697663092897…1/2
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
10/2/24, 2:50 PM State of Utah Mail - Audit Follow Up
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1809386976630928973&simpl=msg-f:180938697663092897…2/2
Jared James <[e-mail]>
Air Quality Inspection
3 messages
Jared James <[e-mail]>Wed, Oct 2, 2024 at 11:58 AM
To: Brian Harris <[e-mail]>
Hi Brian
I'm reviewing all the information from our inspection at the end of August, and I've got stack test results for the HRU and
Bypass but not for boilers #4 and #6. I found a protocol acceptance letter (DAQC-1373-22) but no results for the actual
test. Would you send me the test results for the boiler stack test please (just the summary page would be great)? Thanks!
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
Brian Harris <[e-mail]>Wed, Oct 2, 2024 at 1:51 PM
To: Jared James <[e-mail]>
Hi Jared,

Please find attached the Stack Tests Summary of Results for Boilers 4&6. I’ve also included the Cover Page and
Certificate of Report Integrity.

Please let me know if you need anything else.

Sincerely,
Brian Harris

From: Jared James <[e-mail]>
Sent: Wednesday, October 2, 2024 11:58 AM
To: Brian Harris <[e-mail]>
Subject: Air Quality Inspection

Hi Brian

10/31/24, 3:13 PM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-a:r4628327401327578204&simpl=msg-a:r-766787143834921…1/2
I'm reviewing all the information from our inspection at the end of August, and I've got stack test results for the HRU and
Bypass but not for boilers #4 and #6. I found a protocol acceptance letter (DAQC-1373-22) but no results for the actual
test. Would you send me the test results for the boiler stack test please (just the summary page would be great)? Thanks!

--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
[Quoted text hidden]
Stack Test Summary of Results for Boiers 4 & 6.pdf
45K
Jared James <[e-mail]>Wed, Oct 2, 2024 at 2:29 PM
To: Brian Harris <[e-mail]>
Thanks Brian!
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
10/31/24, 3:13 PM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-a:r4628327401327578204&simpl=msg-a:r-766787143834921…2/2