DAQ-2024-007119

1
DAQC-CI120900001-24
Site ID 12090 (B1)

MEMORANDUM

TO: FILE – REGENCE BLUE CROSS BLUE SHIELD OF UTAH – Data Center

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: March 21, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: February 15, 2024

SOURCE LOCATION: 2890 East Cottonwood Parkway
Salt Lake City, UT 84121
DIRECTIONS: Door is locked and staff is minimal. Call when you arrive to
have them meet you.

SOURCE CONTACTS: Jon Fetzer, Facilities Manager
385-261-6413 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Regence BCBS owns and operates 2 standby generators that
provide power for the insurance office during power outages.
The company also operates 4 boilers: two 2.0 MMBtu/hr boilers
on the east side of the building, and two 1.6 MMBtu/hr boilers
on the west side of the building. These were replaced in 2021.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-ANSR01209000002-11, dated
August 9, 2011
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Regence Blue Cross Blue Shield of Utah - Data
Center

2890 East Cottonwood Parkway 2890 East Cottonwood Parkway
Salt Lake City, UT 84121 Salt Lake City, UT 84121

SIC Code: 6324: (Hospital & Medical Service Plans)

2
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]

Status: In Compliance. No limits set forth in this AO appear to have been exceeded.
Modifications to the equipment do not require submission of an NOI or a new AO. See
Section II below for more details. The equipment appeared to be properly operated and
maintained according to manufacturer recommendations. Records are kept as required
and were made available after the inspection. No breakdowns have been reported since the
previous inspection. This source is not required to submit an emissions report at this time.

Section II: SPECIAL PROVISIONS

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

II.A.1 Regence Blue Cross Blue Shield of Utah Data Center

II.A.2 Boilers
Two (2) rated at 2.0 MMBtu/hr - each
Two (2) rated at 2.25 MMBtu/hr - each
Fuel: natural gas

For information purposes

II.A.3 Emergency Generator Engines
Two (2) rated at 1,500 kW - each
Fuel: diesel or fuel oil

Status: In Compliance. No unapproved equipment was observed at the time of
inspection. Note: the boilers were replaced in 2021. The new boilers have
ratings of 2 MMBtu/hr in the east building and 1.6 MMBtu/hr in the west
building. Since the boilers are still rated at < 5 MMBtu/hr, no NOI is
necessary.
3
II.B Requirements and Limitations

II.B.1 The Regence Blue Cross Blue Shield of Utah Data Center plant shall be subject to the
following.

II.B.1.a Visible emissions from the following emission points (except where indicated otherwise) shall
not exceed the following values:

All boilers - 10% opacity
All other points - 20% opacity

Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

II.B.1.b The sulfur content of any fuel oil burned shall not exceed:

0.0015 percent by weight for fuel oils consumed in any equipment.

The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of other fuels shall be either by Regence Blue Cross Blue Shield of Utah's own
testing or test reports from the fuel marketer. [R307-401-8]

Status: In Compliance. The fuel is sourced by Rhinehart and is #2 dyed ultra-low sulfur
diesel. See the attached email correspondence with the source.

II.B.1.c Regence Blue Cross Blue Shield of Utah shall notify the Executive Secretary in writing when the
installation of the additional emergency generator engine has been completed and is operational.
To ensure proper credit when notifying the Executive Secretary, send your correspondence to the
Executive Secretary, attn: Compliance Section.

If the construction and/or installation have not been completed within 18 months from the date of
this AO, the Executive Secretary shall be notified in writing on the status of the construction
and/or installation. At that time, the Executive Secretary shall require documentation of the
continuous construction and/or installation of the operation and may revoke the AO.
[R307-401-18]

Status: In Compliance. The additional generator has been documented in place on all
inspection memos since 2012.
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.

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

Status: In Compliance. The emergency 1,500 kW generators are located in adjoining out buildings near
the back southern facing parking lot; they were manufactured February 12, 1996, and April 4, 1995,
and are Cat 3516 generators. Stationary RICE located at area sources of HAP emissions must comply
with Table 2d to subpart ZZZZ of MACT (Part 63), which requires annual maintenance of hoses, oil,
belts, and filters, and the use of ultra-low sulfur fuel. Both generators were run for 4.5 hours of
maintenance from January 2023 - December 2023. See the attached logs from the source.
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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. The fuel is sourced by Rhinehart and is #2 dyed ultra-low sulfur diesel. See
the attached email correspondence with the source.

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

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subpart ZZZZ. See Section III above for more information.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Regence Blue
Cross Blue Shield of Utah - Data Center on the Approval Order (AO) DAQE-ANSR0120900002-11,
dated August 9, 2011. The following information was supplied for supplemental purposes only.

Pollutant Tons/yr

Carbon Monoxide 1.65
Nitrogen Oxides 10.08
Particulate Matter - PM10 0.84
Sulfur Dioxide 0.02
Volatile Organic Compounds 0.26

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO)
DAQE-ANSR0120900002-11, dated August 9, 2011: In
compliance at the time of inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at typical frequency. Safety glasses are required PPE for
this inspection.

NSR RECOMMENDATIONS: If any updates to other equipment are made in the future, also
update the boilers to match the ratings of the replacements made
in 2021.

ATTACHMENTS: VEO form, email correspondence, generator maintenance
2/27/24, 2:40 PM State of Utah Mail - 12090 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r3773000357653190992&simpl=msg-a:r-10127271394562…1/2
Daniel Riddle <[e-mail]>
12090 - Follow up to air quality inspection
2 messages
Daniel Riddle <[e-mail]>Thu, Feb 15, 2024 at 1:05 PM
To: [e-mail]
Cc: [e-mail]
Jon,
Thank you for taking the time to meet today for your air quality inspection. As discussed, here are the records I will require to complete my inspection
report:
1. Per 40 CFR Part 63 Subpart ZZZZ - (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-ZZZZ) - total hours of
maintenance for the emergency generators from January - December 2023
2. Proof of ULSD purchase for use in diesel generators
Please provide me with these records by February 22, 2024.
Additionally, when searching through our database, I see no submission of a Notice of Intent in 2020 or 2021 to replace your boilers, so since you are
working with unpermitted equipment, you are out of compliance. Per Condition I.3 of your Approval Order/permit, any modification to the equipment
needs to be approved by the Division of Air Quality before it occurs. I will be writing a Compliance Advisory and from there we will determine the next
steps. In the meantime, to get into compliance you can begin work on a Notice of Intent to submit to the DAQ permitting - here is the link for that form,
as well as the option to schedule a pre-NOI meeting for assistance on what you'll need to submit. (https://deq.utah.gov/air-quality/air-quality-permitting
)
Let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Fetzer, Jon <[e-mail]>Thu, Feb 15, 2024 at 1:18 PM
To: Daniel Riddle <[e-mail]>
Cc: "Hebert, Mike" <[e-mail]>
Adding Ken Shepardson as I will be out of office starting 2/16 until 2/27.

Daniel,
We will work on getting this over to you.

Thanks!

Jon Fetzer
Facilities Manager- C&W at CAMBIA HEALTH SOLUTIONS
Direct: [phone]
2/27/24, 2:40 PM State of Utah Mail - 12090 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r3773000357653190992&simpl=msg-a:r-10127271394562…2/2
[e-mail]
[e-mail]
2890 E Cottonwood PKWY,
Salt Lake City, Utah 84121| United States
cushmanwakefield.com
LinkedIn | Facebook | Twitter | YouTube | Google+ | Instagram

From: Daniel Riddle <[e-mail]>
Sent: Thursday, February 15, 2024 1:06 PM
To: Fetzer, Jon <[e-mail]>
Cc: Hebert, Mike <[e-mail]>
Subject: 12090 - Follow up to air quality inspection

This message is from an EXTERNAL email address - Please only click links and attachments if you're sure they are safe.
[Quoted text hidden]
IMPORTANT NOTICE: This communication, including any attachment, contains information that may be confidential or privileged, and is intended
solely for the entity or individual to whom it is addressed. If you are not the intended recipient, you should delete this message and are hereby
notified that any disclosure, copying, or distribution of this message is strictly prohibited. Nothing in this email, including any attachment, is intended
to be a legally binding signature.
2/27/24, 2:41 PM State of Utah Mail - RE: 12090 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1791074293423498056&simpl=msg-f:17910742934234980…1/5
Daniel Riddle <[e-mail]>
RE: 12090 Follow up to air quality inspection
8 messages
Shepardson, Ken <[e-mail]>Fri, Feb 16, 2024 at 9:39 AM
To: "[e-mail]" <[e-mail]>
Cc: "Fetzer, Jon" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
Hello!

We reached out to our partner Wheeler, and we are grateful Caden was able to help us out. Please see attached
screenshots showing about 4.5 hours of maintenance run time on each generator. Caden also added the following…

“We reached out to Rhinehart about the fuel. They said they used #2 dyed ultra-low sulfur diesel. I'll see if we can get any
documentation on it, but I hope that helps.”

Is this good enough for what you require, or do we need more information or need to display it differently?

Thanks!

Ken Shepardson
Lead Operating Engineer- C&W at CAMBIA HEALTH SOLUTIONS
Direct: [phone]
[e-mail]
[e-mail]
2890 E Cottonwood PKWY,
Salt Lake City, Utah 84121| United States
cushmanwakefield.com
LinkedIn | Facebook | Twitter | YouTube | Google+ | Instagram

2/27/24, 2:41 PM State of Utah Mail - RE: 12090 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1791074293423498056&simpl=msg-f:17910742934234980…2/5
IMPORTANT NOTICE: This communication, including any attachment, contains information that may be confidential or
privileged, and is intended solely for the entity or individual to whom it is addressed. If you are not the intended recipient,
you should delete this message and are hereby notified that any disclosure, copying, or distribution of this message is
strictly prohibited. Nothing in this email, including any attachment, is intended to be a legally binding signature.
2 attachments
Screenshot 2024-02-15 161111.jpg
173K
Screenshot 2024-02-15 161151.jpg
198K
Shepardson, Ken <[e-mail]>Wed, Feb 21, 2024 at 7:30 AM
To: "[e-mail]" <[e-mail]>
Cc: "Fetzer, Jon" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
Good morning Daniel! I just wanted to follow up as we have not heard back and the deadline you gave us for the end of
this week is approaching. We would like to know if we need to get additional information or if what we have provided you
is within your parameters.

Thanks!

Ken Shepardson
Lead Operating Engineer- C&W at CAMBIA HEALTH SOLUTIONS
Direct: [phone]
[e-mail]
[e-mail]
2890 E Cottonwood PKWY,
2/27/24, 2:41 PM State of Utah Mail - RE: 12090 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1791074293423498056&simpl=msg-f:17910742934234980…3/5
Salt Lake City, Utah 84121| United States
cushmanwakefield.com
LinkedIn | Facebook | Twitter | YouTube | Google+ | Instagram

[Quoted text hidden]
[Quoted text hidden]
Daniel Riddle <[e-mail]>Fri, Feb 23, 2024 at 10:47 AM
To: "Shepardson, Ken" <[e-mail]>
Cc: "Fetzer, Jon" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
Ken - sorry for the late response - I was ill following the holiday. This should satisfy the requirements for ZZZZ and ULSD,
thank you.
[Quoted text hidden]
Shepardson, Ken <[e-mail]>Fri, Feb 23, 2024 at 10:55 AM
To: Daniel Riddle <[e-mail]>
Cc: "Fetzer, Jon" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
Thank you! Sorry to hear you were ill, I’m glad you’re feeling better! Have a good weekend!

Thanks!

Ken Shepardson
Lead Operating Engineer- C&W at CAMBIA HEALTH SOLUTIONS
Direct: [phone]
[e-mail]
[e-mail]
2890 E Cottonwood PKWY,
Salt Lake City, Utah 84121| United States
cushmanwakefield.com
LinkedIn | Facebook | Twitter | YouTube | Google+ | Instagram

From: Daniel Riddle <[e-mail]>
Sent: Friday, February 23, 2024 10:48 AM
To: Shepardson, Ken <[e-mail]>
Cc: Fetzer, Jon <[e-mail]>; Slaughter, Shiloh <[e-mail]>;
2/27/24, 2:41 PM State of Utah Mail - RE: 12090 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1791074293423498056&simpl=msg-f:17910742934234980…4/5
[e-mail]
Subject: Re: RE: 12090 Follow up to air quality inspection

This message is from an EXTERNAL email address - Please only click links and attachments if you're sure they
are safe.
[Quoted text hidden]
Daniel Riddle <[e-mail]>Fri, Feb 23, 2024 at 10:56 AM
To: "Shepardson, Ken" <[e-mail]>
Cc: "Fetzer, Jon" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
Thank you, you too!
[Quoted text hidden]
Fetzer, Jon <[e-mail]>Fri, Feb 23, 2024 at 10:56 AM
To: "Shepardson, Ken" <[e-mail]>, Daniel Riddle <[e-mail]>
Cc: "Slaughter, Shiloh" <[e-mail]>, "[e-mail]" <[e-mail]>
Daniel,
I have a call with one of you Air Quality engineers on Monday as well. Just wanted to give you the heads up. Thank you
Get Outlook for iOS
From: Shepardson, Ken <[e-mail]>
Sent: Friday, February 23, 2024 10:55:38 AM
To: Daniel Riddle <[e-mail]>
Cc: Fetzer, Jon <[e-mail]>; Slaughter, Shiloh <[e-mail]>;
[e-mail] <[e-mail]>
Subject: RE: RE: 12090 Follow up to air quality inspecon

[Quoted text hidden]
Daniel Riddle <[e-mail]>Tue, Feb 27, 2024 at 8:40 AM
To: "Fetzer, Jon" <[e-mail]>
Cc: "Shepardson, Ken" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
Jon - some further clarification on your boilers. After discussing with my manager, your new boilers do not require a new
permit since they are still <5 MMBTu/hr. According to the notes I took at the time of inspection, the 2 boilers in the east
building are both rated at 2 MMBtu/hr and the 2 in the west building are both rated at 1.6 MMBtu/hr. I won't be issuing
any compliance action at this time - engineering will probably give you a similar response if you let them know about the
ratings.
Best,
Daniel
[Quoted text hidden]
Fetzer, Jon <[e-mail]>Tue, Feb 27, 2024 at 8:45 AM
To: Daniel Riddle <[e-mail]>
Cc: "Shepardson, Ken" <[e-mail]>, "Slaughter, Shiloh" <[e-mail]>,
"[e-mail]" <[e-mail]>
2/27/24, 2:41 PM State of Utah Mail - RE: 12090 Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1791074293423498056&simpl=msg-f:17910742934234980…5/5
Sounds good, thank you. I have a call with them tomorrow afternoon.

Thanks!

Jon Fetzer
Facilities Manager- C&W at CAMBIA HEALTH SOLUTIONS
Direct: [phone]
[e-mail]
[e-mail]
[Quoted text hidden]