DAQ-2025-000651

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DAQC-CI112950001-25
Site ID 11295 (B1)
MEMORANDUM

TO: FILE – SALT LAKE COUNTY – Salt Palace Convention Center

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: January 27, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: January 16, 2025

SOURCE LOCATION: 100 South West Temple Salt Lake City, UT 84101

SOURCE CONTACTS: James Willis, Chief Engineer
801-550-8535 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection

PROCESS DESCRIPTION: Salt Palace Convention Center operates two 20MMBtu/hr boilers
with flue gas recirculation to control NOx emissions for the
boiler exhaust duct into the main combustion chamber, two 12.6
MMBtu/hr boilers, and three Emergency Engines.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN112950006-21, dated July 16,
2021
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) A: General Provisions,
MACT (Part 63) -A : General Provisions,
MACT (Part 63) JJJJJJ : National Emission Standards for
Hazardous Air Pollutants for Industrial, Commercial, and
Institutional Boilers Area Sources,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Salt Lake County - Salt Palace Convention Center
100 South West Temple 100 South West Temple
Salt Lake City, UT 84101 Salt Lake City, UT 84101

SIC Code: 7389: (Business Services, NEC)
* - ) - # )
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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 breakdowns have occurred since the previous inspection. Records are maintained as required. No notification of the new equipment was made as that new emergency generator was found unapproved during a compliance inspection. An Emission Inventory is required at this source and was submitted for 2023 by the April 15, 2024, deadline. See the attachments section for a copy of the Emission Inventory.

Section II: SPECIAL PROVISIONS

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

II.A.1 Salt Palace Convention Center
II.A.2 Emergency Generator Engine One (1) 284 kW (379 hp) generator engine Fuel: diesel Manufacture date: pre-2008 MACT Subpart ZZZZ
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II.A.3 Emergency Generator Engine One (1) 200 kW (267 hp) generator engine (new) Fuel: diesel Manufacture date: 2018 NSPS Subpart IIII MACT Subpart ZZZZ
II.A.4 Emergency Generator Engine One (1) 100 kW (134 hp) generator engine Fuel: diesel Manufacture date: 2006 NSPS Subpart IIII MACT Subpart ZZZZ
II.A.5 Boilers Two (2) 20 MMBtu/hr (600 hp) boilers with flue gas recirculation Fuel: natural gas, diesel fuel NSPS Subpart Dc MACT Subpart JJJJJJ
II.A.6 Boilers Two (2) 12.6 MMBtu/hr boilers Fuel: natural gas NSPS Subpart Dc
II.A.7 Boilers Various boilers rated at less than 5 MMBtu/hr each Fuel: natural gas
Status: In Compliance. No unapproved equipment was observed at the time of inspection. Additional information carried over from previous inspections and gathered at the time of inspection are as follows: II.A.2 284 kW generator is an Onan emergency generator installed in 1994 and is located in Hall 1. II.A.3 200 kW generator is a Generac emergency generator installed in 2019 and is located in Hall 1. II.A.4 100 kW generator is a Cummins emergency generator installed after June 12, 2006, and is located in Hall 5 . II.A.7- various boilers rated below 5 MMBtu/hr, there is only one boiler rated below 5 MMBtu/hr onsite, which was installed in 2024. It is rated at 3.9MMBtu and has a low NOx burner installed.

II.B Requirements and Limitations
II.B.1 Site-Wide Requirements II.B.1.a Visible emissions shall not exceed 10% opacity for boilers and 20% opacity for the generator engines. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-305-3] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attachments section for additional information.

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II.B.1.b The following operational limits shall not be exceeded: A. 2,088 hours of operation per 12.6 MMBTU/hr boiler each, per rolling 12-month period B. 76 hours of boiler operation on diesel fuel per boiler, per rolling 12-month period. [R307-401-8] II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Operational limits shall be determined by SPCC. The records of operation shall be kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. [R307-401-8] Status: In Compliance. The rolling 12-month total from January 2024 to December 2024, for operation time for the 12.6 MMBtu/hr boilers are as follows: 242 and 229 hours of operation for the two boilers on natural gas. 0 hours of operation time on diesel fuel. Records are maintained electronically and are recorded daily. A monthly total is calculated by the 20th of each month. A copy of the log was viewed onsite at the time of inspection. II.B.1.c The owner/operator shall use only natural gas as a primary fuel in the 20 MMBtu/hr and the 12.6 MMBtu/hr boilers. The owner/operator shall use diesel fuel oil as a backup fuel in the 20 MMBtu/hr boilers. [R307-401-8] Status: In Compliance. Natural gas is the only fuel source used in both boilers. Both sets of boilers are capable of running diesel fuel if needed, but have not operated on diesel fuel since 2001. II.B.2 Emergency Generator Requirements II.B.2.a The owner/operator shall use the emergency generator engines only during the periods when electric power from the public utilities is interrupted, or for regular maintenance and testing of the engines. There is no time limit on the use of the engines during emergencies. [R307-401-8] Status: In Compliance. The emergency generators are only utilized in the case of emergency. Otherwise, they are operated monthly for testing and maintenance if no emergency use is required. II.B.2.b The 284 kW emergency generator engine shall not exceed 76 hours of operation per rolling 12-month period. The 200 kW and 100 kW emergency generator engines shall not exceed 100 hours of operation each per rolling 12-month period. [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 twentieth of each month using data from the previous 12 months. Records of 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 the operation C. The reason for the emergency generator engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]

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II.B.2.b.2 Records of hours of operation shall be determined by installing a non-resettable hour meter for each emergency generator engine. [R307-401-8] Status: In Compliance. The rolling 12-month total from January 2024 to December 2024, for generator hours are as follows: 100 kW generator: 10.7 hours 200 kW generator: 33.8 hours 284 kW generator: 29.8 hours Each generator is equipped with a non-resettable meter. Generator hours are recorded and stored in a log that updates the rolling monthly total by the 20th of each month. This was viewed onsite at the time of inspection. II.B.2.c The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each engine. [R307-401-8] Status: In Compliance. #2 diesel fuel is the only fuel utilized in the generators. II.B.2.d 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. [R307-401-8] II.B.2.d.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. According to the fuel certificate from Unified Fuel Supply, the fuel utilized onsite is classified as ULSD. This was viewed onsite at the time of 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) Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam
Generating Units

Status: In Compliance. The 12.6 MMBtu/hr and 24.5 MMBtu/hr boilers apply to this subpart. Both
boiler sets operate solely on natural gas. Neither set of boilers has operated on diesel fuel since 2001. The
24.5 MMBtu/hr boilers operated for about 4,000 hours within the last 12 months and the 12.6
MMBtu/hr boilers operated for 242 and 229 hours within the last rolling 12-month period. Records are
maintained as required by Subpart Dc.

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

Status: In Compliance. The 100 kW and 200 kW generators are applicable to this subpart as they were
installed after June 12, 2006. The 200 kW generator operated for 33.8 hours and the 100 kW generator
operated for 10.7 hours within the last rolling 12 month period. Both generators are equipped with a
non-resettable meter and are maintained according to manufacturer's specifications.
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NSPS (Part 60) A: General Provisions

Status: Compliance with subpart A is determined by compliance with applicable federal subparts. In
Compliance with Subparts Dc and IIII.

MACT (Part 63) -A: General Provisions

Status: Compliance with Subpart A is determined by compliance with applicable federal subparts. In
Compliance with Subpart ZZZZ and compliance not applicable with Subpart JJJJ.
MACT (Part 63) JJJJJJ : National Emission Standards for Hazardous Air Pollutants for Industrial,
Commercial, and Institutional Boilers Area Sources

Status: Not Applicable. None of the boilers onsite have operated on diesel fuel since 2001 and have
operated solely on natural gas, making them not applicable to this subpart.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. All three generators onsite are subject to this subpart. All generators operated
under the 100 hour limit within the previous rolling 12-month period, are equipped with non-resettable
meters, and are maintained according to manufacturer's specifications.
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. According to the fuel certificate from Unified Fuel Supply, the fuel utilized
onsite is classified as ULSD. This was viewed onsite at the time of inspection.

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

Status: In Compliance. R307-210 applies as this source is subject to NSPS Subparts Dc and IIII. See
Section III for compliance information regarding those subparts.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. R307-214 applies to this source as they are subject to MACT Part 63 Subpart
ZZZZ. See Section III for compliance information regarding Subpart ZZZZ.

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

Status: In Compliance. No visible emissions from the boilers exceeded opacity limits established
within this AO. See the attached VEO form for additional information.
NOx and CO Emission Controls for Natural Gas-Fired Boilers 2.0-5.0 MMBtu. [R307-315] Status: In Compliance. The boiler listed in II.A.7 applies to this rule, as it is rated at 3.9 MMBtu/hr. It was installed in 2024 after the compliance dated listed within the rule. The burner installed on the boiler is rated at 8 ppm for NOx and 120 ppm for CO. The information on the CO was obtained at the time of inspection. A picture of the NOx emission rate for the burner on the boiler can be found in the attachments section below. The source was made aware of the requirements of this rule going forward for this boiler.
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NOx and CO Emission Controls for Natural Gas-Fired Boilers Greater Than 5.0 MMBtu.[R307-316] Status: In Compliance. The two 12.6 MMBtu/hr and the two 24.5 MMBtu/hr boilers apply to this rule. Since these boilers were installed before the compliance date listed within the rule and have not undergone any modifications or burner replacements, they are currently in compliance. The source was notified at the time of inspection of the requirements of this rule moving forward should the boilers undergo replacements that would make them subject to the NOx and CO requirements in this rule.
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. The VOC emission rate from the 2023 Emission Inventory was 0.35 tons,
which is below the 0.84 tons for the Salt Palace's PTE.

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Salt Lake County - Salt Palace
Convention Center. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN112950006-21, dated July 16, 2021, is provided. The 2023 Emission Inventory is listed below
and can also be found in the attachments section.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 3124.00
Carbon Monoxide 10.23 4.69
Nitrogen Oxides 6.12 2.78
Particulate Matter - PM10 0.73 0.23
Particulate Matter - PM2.5 0.73 0.22
Sulfur Dioxide 0.63 0.02
Volatile Organic Compounds 0.84 0.35

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acetaldehyde (CAS #75070) 24 0
Benzene (Including Benzene From Gasoline) (CAS #71432) 28 0.15
Formaldehyde (CAS #50000) 34 4.34
Toluene (CAS #108883) 12 0.19
Xylenes (Isomers And Mixture) (CAS #1330207) 6 0

PREVIOUS ENFORCEMENT
ACTIONS: None within the past 5 years

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN112950006-21,
dated July 16, 2021, the overall status is: In Compliance. In
Compliance with the conditions listed within the AO. Records
were made available upon request or were provided within a
timely manner. The facility appears well maintained.

HPV STATUS: Not Applicable.

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RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the normal frequency

NSR RECOMMENDATIONS: II.A.7-Various boilers should be replaced to one boiler under 5
MMBtu/hr, as the source only has one boiler fitting that
requirement.

ATTACHMENTS: Applicable Supporting Documentation Included
2023 Emissions Inventory Report
Salt Lake County- Salt Palace (11295)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons,
excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)0.20211 0.02847 0.23058
PM10-FIL PM10 Filterable 0.0512 <.00001 0.0512
PM25-PRI PM2.5 Primary (Filt + Cond)0.20208 0.02642 0.22851
PM25-FIL PM2.5 Filterable 0.05117 <.00001 0.05117
PM-CON PM Condensible 0.15091 <.00001 0.15091
SO2 Sulfur Dioxide 0.02551 0.00042 0.02593
NOX Nitrogen Oxides 2.70611 0.07924 2.78535
VOC Volatile Organic Compounds 0.14719 0.20773 0.35492
CO Carbon Monoxide 2.23803 2.4586 4.69663
7439921 Lead 0.00001 <.00001 0.00001
NH3 Ammonia 0.08484 <.00001 0.08484

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC <.00001
107028 Acrolein (HAP)VOC <.00001
7440382 Arsenic (HAP)PM 0.00001
71432 Benzene (HAP)VOC 0.00007
7440417 Beryllium (HAP)PM <.00001
7440439 Cadmium (HAP)PM 0.00003
7440473 Chromium (HAP)PM 0.00004
7440484 Cobalt (HAP)PM <.00001
50000 Formaldehyde (HAP)VOC 0.00197
110543 Hexane (HAP)VOC 0.04736
7439965 Manganese (HAP)PM 0.00001
7439976 Mercury (HAP)- 0.00001
91203 Naphthalene (HAP)VOC 0.00002
7440020 Nickel (HAP)PM 0.00006
130498292 PAH, total (HAP)PM <.00001
7782492 Selenium (HAP)PM <.00001
108883 Toluene (HAP)VOC 0.00009
1330207 Xylenes (Mixed Isomers) (HAP)VOC <.00001
91576 2-Methylnaphthalene (HAP)PM <.00001

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
Jordan Garahana <[e-mail]>
Fw:
2 messages
James Willis <[e-mail]>Fri, Jan 17, 2025 at 9:57 AM
To: "[e-mail]" <[e-mail]>
Jordan,
Nox reading.
Thanks,
James
James Willis
Chief Engineer, Salt Palace Convention Center
801-550-
8535 | www.saltpalace.com | [e-mail]
100 South West Temple, Salt Lake City, Utah
84101Double Facility Gmail.jpg
From: bill taylor <[e-mail]>
Sent: Friday, January 17, 2025 9:54 AM
To: James Willis <[e-mail]>
Subject:

IMG_5695004.jpg
671K
Jordan Garahana <[e-mail]>Fri, Jan 17, 2025 at 10:14 AM
To: James Willis <[e-mail]>
Hey James,
Thanks for sending this over! This is what I was looking for.
Thanks,
Jordan
1/27/25, 2:58 PM State of Utah Mail - Fw:
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1821516024212346808&simpl=msg-f:182151602421234680…1/2
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
1/27/25, 2:58 PM State of Utah Mail - Fw:
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1821516024212346808&simpl=msg-f:182151602421234680…2/2