DAQ-2025-002013

Small Source Registration

DAQE-EN117060002-25

{{$d1 }}

Mark Hogan
Utah Army National Guard
12953 South Minuteman Drive
G9 – CFMO – ERM
Draper, UT 84020
[e-mail]

Dear Mr. Hogan:

Re: Request for Evaluation of Compliance with Rule R307-401-9, UAC: Small Source Exemption
Project Fee Code: N117060002
On April 1, 2025, the Division of Air Quality (DAQ) received your request for a small source exemption for Utah Army National Guard’s Defense Depot Ogden. The source is located at 968 West 400 North, Building 11C, Bays 1 and 2, in Ogden, Weber County. DAQ has determined the small source exemption applies to the source, as long as the equipment and associated processes operate as specified in the registration request. The equipment and associated processes located at this site include one (1) 463 hp emergency generator engine.

The small source exemption does not exempt a source from complying with other applicable federal,
state, and local regulations and the current Utah Administrative Code. Based on the emissions that you
submitted to DAQ with your registration request, the Utah Army National Guard is not required to obtain
an approval order under R307-401 for the Defense Depot Ogden. If you change your operation such that
there is an increase in emissions, we recommend that you notify us, as an approval order may be required.

As authorized by the Utah Legislature, the fee for issuing this small source exemption is a one-time filing
fee in addition to the actual time spent by the review engineer and all other staff on the project. Payment
should be sent to DAQ upon receipt of the invoice.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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DAQE-EN117060002-25
Page 2
Thank you for registering your source with the DAQ. If you have any additional questions, please contact
Katie Andersen at [phone] or [e-mail].

Sincerely,

Bryce C. Bird
Director
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Alan D. Humpherys, Manager
New Source Review Section

BCB:ADH:KA:jg

{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
Utah Army National Guard
Defense Depot - Ogden
Emergency Generator Emissions Calculations
NOx Emission Factor (lb/HP-hr)3.10E-02 [AP-42, Table 3.3-1, Diesel Fuel]
CO Emission Factor (lb/HP-hr)6.68E-03 [AP-42, Table 3.3-1, Diesel Fuel]
SOx Emission Factor (lb/HP-hr)2.05E-03 [AP-42, Table 3.3-1, Diesel Fuel]
PM10 Emission Factor (lb/HP-hr)2.20E-03 [AP-42, Table 3.3-1, Diesel Fuel]
TOC Emission Factor (lb/HP-hr)2.51E-03 [AP-42, Table 3.3-1, Diesel Fuel]
Source Name
Caterpillar
Engine
Location DDO Bay 1
Rating (kW)345
Rating (HP)463
Fuel Use (gal/hr)26.5
Annual Hours of Operation 30
Fuel Use (gal/yr)795
Tier Level N/A
NOx Emissions (lb/hr)14.35
CO Emissions (lb/hr)3.09
SOx Emissions (lb/hr)0.95
PM10 Emissions (lb/hr)1.02
PM2.5 Emissions (lb/hr)1.02
VOC Emissions (lb/hr)1.16
NOx Emissions (tpy)0.215
CO Emissions (tpy)0.046
SOx Emissions (tpy)0.014
PM10 Emissions (tpy)0.015
PM2.5 Emissions (tpy)0.015
VOC Emissions (tpy)0.017
Notes:
Emissions estimated using factors from AP-42 Table 3.3-1. Fuel Use estimated using data availab
Diesel heat rating 0.1395 MMBtu/gal
Fuel use 3.7 MMBtu/hr
Fuel use 110.9 MMBtu/yr
HAP Emissions
Pollutant

(lb/MMbtu)

(lb/hr)

(lb/year)
Acenaphthene 1.42E-06 5.25E-06 1.57E-04
Acenaphthylene 5.06E-06 1.87E-05 5.61E-04
Acetaldehyde 7.67E-04 2.84E-03 8.51E-02
Acrolein 9.25E-05 3.42E-04 1.03E-02
Anthracene 1.87E-06 6.91E-06 2.07E-04
Benz[a]anthracene 1.68E-06 6.21E-06 1.86E-04
Benzene 9.33E-04 3.45E-03 1.03E-01
Benzo[b]fluoranthene 9.91E-08 3.66E-07 1.10E-05
Benzo[k]fluoranthene 1.55E-07 5.73E-07 1.72E-05
Benzo(g,h,l)perylene 4.89E-07 1.81E-06 5.42E-05
Benzo[a]pyrene 1.88E-07 6.95E-07 2.08E-05
1,3-Butadiene 3.91E-05 1.45E-04 4.34E-03
Dibenz[a,h]anthracene 5.83E-07 2.16E-06 6.47E-05
Fluoranthene 7.61E-06 2.81E-05 8.44E-04
Fluorene 2.92E-05 1.08E-04 3.24E-03
Formaldehyde 1.18E-03 4.36E-03 1.31E-01
Indeno[1,2,3-c,d]pyrene 3.75E-07 1.39E-06 4.16E-05
Naphthalene 8.48E-05 3.13E-04 9.40E-03
Phenanthrene 2.94E-05 1.09E-04 3.26E-03
Pyrene 4.78E-06 1.77E-05 5.30E-04
Toluene 4.09E-04 1.51E-03 4.54E-02
Xylenes - Mixed isomer 2.85E-04 1.05E-03 3.16E-02
Total 1.43E-02 4.30E-01
Notes:
(1) HAP emission factors taken from AP-42 Section 3.3, Tables 3.3-2
(2) HAP emission factors taken from Air Emissions Guide for Air Force Stationary Sources. Table
CO2 73.25 kg/MMBtu 40 CFR 98.33 Tab
CH4 3.00E-03 kg/MMBtu 40 CFR 98.33 Ta
N2O 6.00E-04 kg/MMBtu 40 CFR 98.33 Tab
CO2 Emissions (tpy)

(tpy)

(tpy)

(tpy)
4.48E-03 3.67E-04 7.33E-05 3.55E-02
Notes:
(1) CO2 emission factors and calculations from 40 CFR 98.33
0.43
3-7 HAP Emission Factors for Stationary Compression Ignition ICOM Engines
Katie Andersen <[e-mail]>
Small Source Exemption for Emergency Generator
12 messages
Katie Andersen <[e-mail]>Tue, Feb 11, 2025 at 1:40 PM
To: "[e-mail]" <[e-mail]>
Hi Joel,
Thank you for your time today talking on the phone regarding the air quality permit for the emergency generator at
building 11C.
I spoke with Alan Humphreys, and he has not received information regarding a Small Source Exemption Application for
the site.
If you could follow up with your rep to see if an application was submitted, that would be great. If an application has not
been submitted, you can do so here. I'd be more than happy to assist with calculations if needed.
Please let me know if you have any questions or concerns.
Cheers,
Katie Andersen
--

Katie Andersen
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Hogan, Mark A NFG NG UTARNG (USA) <[e-mail]>Tue, Feb 11, 2025 at 4:45 PM
To: "[e-mail]" <[e-mail]>, Alan Humpherys <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Hello Katie and Alan,

I’m Mark Hogan, the Air Quality Manager for the Utah Army National Guard (UTARNG). Last I
corresponded with Alan about this was that I was going to check what other sources of air pollutants we
(UTARNG) have at the Depot. For some background, we call that area Defense Depot-Ogden, or DDO.
We’re a tenant there and we’ve had a lease to rent one Bay for a long time.

The emergency generator is for some classrooms, our Joint Language Training Center (JLTC), and there is
no boiler. However, there are 3 separate, residential-style heating systems and I think those are not subject
4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…1/7
to NSR rules. The soldiers there do not perform maintenance activities that would add VOCs to the
equation, like degreasing, painting/coating, or gun-cleaning. Since confirming the limits of our emissions
there (limited to one Em. Generator), I’ve been following the breadcrumbs of contacts to the owner of the
DDO, the US Army Reserves (USAR).

At first, I wanted to go ahead and register a SSE for UTARNG’s JLTC, but we’re just the tenant there. We
are in the throes of figuring out what’s best for the generators and other emission sources at DDO: one SSE
or more than one. That is the latest on that generator.

Please feel free to come to me with any air quality questions or concerns you may have related to
UTARNG. You can email either one of my addresses (state address is copied as FYI) and my office number
is [phone].

Warm regards,
Mark H

--

Mark Hogan
Air Quality/ECP Manager
Utah Army National Guard
Environmental Resources Management
Cell: [phone]
State Email: [e-mail]
Federal Email: [e-mail]

From: Yoder, Joel T SFC USARMY NG UTARNG (USA) <[e-mail]>
Sent: Tuesday, February 11, 2025 3:36 PM
To: Hogan, Mark A NFG NG UTARNG (USA) <[e-mail]>; Crookston, T David MIL USARMY NG
UTARNG (USA) <[e-mail]>; [e-mail]
Subject: FW: Small Source Exempon for Emergency Generator

This is the email I got as well… the number she called from was 385-515-1748.

v/r,
Joel

4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…2/7
You don't often get email from [e-mail]. Learn why this is important
Joel Yoder, SFC
IC Det 142 NCOIC
UTNG CD-JLTC IT NCO
801-476-3861 (Office)
208-860-8478 (Cell)

From: Kae Andersen <[e-mail]>
Sent: Tuesday, February 11, 2025 1:41 PM
To: Yoder, Joel T SFC USARMY NG UTARNG (USA) <[e-mail]>
Subject: Small Source Exempon for Emergency Generator

Hi Joel,

Thank you for your time today talking on the phone regarding the air quality permit for the emergency generator at
building 11C.

I spoke with Alan Humphreys, and he has not received information regarding a Small Source Exemption Application for
the site.

If you could follow up with your rep to see if an application was submitted, that would be great. If an application has not
been submitted, you can do so here. I'd be more than happy to assist with calculations if needed.

Please let me know if you have any questions or concerns.

Cheers,
Katie Andersen
--
4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…3/7

[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Feb 12, 2025 at 2:07 PM
To: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Mark,
Thank you for reaching out with this. Just to help clarify, what are the other emission sources at the DDO?
Though you are a tenant at the location, you are the operator of the emission sources. For compliance inspections and
such, you would be the responsible party to ensure that the emission sources were operated properly. For this reason, I
would recommend applying for the SSE.
Please let me know your thoughts and if you have any concerns or questions. If you'd like, I'd be more than happy to
discuss this over the phone.
Cheers,
Katie Andersen
[Quoted text hidden]
--

[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Mar 4, 2025 at 9:59 AM
To: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Hi Mark,
I haven't heard back from you regarding my last email. I'm hoping it didn't slip through the cracks.
Please let me know your thoughts about the Small Source Exemption.
Cheers,
Katie Andersen
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Mar 4, 2025 at 10:29 AM
To: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Mark,
4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…4/7
Here are the links to revoke the current AO and apply for a Small Source Exemption.
[Quoted text hidden]
Hogan, Mark A NFG NG UTARNG (USA) <[e-mail]>Tue, Mar 4, 2025 at 10:37 AM
To: Katie Andersen <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Thank you, Katie! If I have any issues or questions, I’ll reach out to you.

-Mark H
[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Mar 17, 2025 at 4:05 PM
To: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Hi Mark,
I don't think the DAQ has received a revocation application or a Small Source Exemption application from you yet. I just
wanted to follow up with that to see if you have an estimated timeline on submitting those applications.
Please let me know if you have any questions.
Cheers,
Katie
[Quoted text hidden]
Hogan, Mark A NFG NG UTARNG (USA) <[e-mail]>Wed, Mar 19, 2025 at 2:50 PM
To: Katie Andersen <[e-mail]>
Cc: Mark Hogan <[e-mail]>
4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…5/7
Good afternoon Katie!

Apologies for the delay. I’m getting input from my consultant on the emissions spreadsheet since we could
use my refined version for other sources.

By the way, the emergency generator itself is in Bay 1 of Bldg 11, but our classroom spaces are in Bay 2.
We have access to Bay 1 (of course to access the generator), but we don’t rent/occupy that space.
Therefore, we’re going to set the street address’ 2nd line to be: Building 11C Bays 1-2.

This should be done any day now. Thank you for your patience!

Warm regards,
Mark H
[phone]
[Quoted text hidden]
Hogan, Mark A NFG NG UTARNG (USA) <[e-mail]>Tue, Apr 1, 2025 at 4:09 PM
To: Katie Andersen <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Hello again Katie,

I finally submitted the request to revoke the old AO (DAQE-845-97) and the registration/application for a
new Small Source Exemption.

I first tried to do the SSE registration on my federal laptop, which has connectivity/security issues with some
Utah.gov websites. I can’t tell if it went through. The second attempt was made on my state laptop, which
appeared to be successful.

If the first attempt went through, then it has the wrong fax number. My apologies! I looked at the Approval
Order for our Headquarters in Draper and accidentally put in the fax number for UDAQ (801-536-4099) –
the correct fax number for us is 801-523-4449 and the second attempt has the correct fax number.

Please let me know if there are any issues that I can help with. It looks like someone like yourself will have
to do a review of the permitting changes.

Best regards,
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Apr 2, 2025 at 8:04 AM
4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…6/7
To: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Hello Mark,
We received the applications and I've been assigned to process the revocation and the Small Source Exemption. I'll be
reviewing the applications today and let you know if I have any questions.
Cheers,
Katie Andersen
[Quoted text hidden]
Katie Andersen <[e-mail]>Fri, Apr 4, 2025 at 10:44 AM
To: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Cc: Mark Hogan <[e-mail]>
Hello Mark,
Would you mind confirming what the mailing address should be for both the Small Source Exemption letter and the permit
revocation? There were some slight differences between the two addresses provided in the applications and I'd like to
make sure we have the right address.
Cheers,
Katie Andersen
[Quoted text hidden]
Mark Hogan <[e-mail]>Fri, Apr 4, 2025 at 11:42 AM
To: Katie Andersen <[e-mail]>
Cc: "Hogan, Mark A NFG NG UTARNG (USA)" <[e-mail]>
Good morning Katie!
Thanks for asking. Letters and such should definitely go to our HQ in Draper: 12953 Minuteman Dr, Draper, UT 84020
If we can customize the first and second lines, then the first should be the regular "Utah Army National Guard" and the
second line should help the letter get routed to our office with "G9 - CFMO - ERM". We share the same name as the
consultant, Environmental Resources Management, haha!
In case I didn't put it in an earlier email, my office line is [phone]. [phone] is our catch-all phone number to
get in touch with someone else at ERM in case I'm not available and/or as the permanent ERM Office number for
permitting documents.
Cheers and have a great weekend!
-Mark H
[Quoted text hidden]
4/4/25, 12:22 PM State of Utah Mail - Small Source Exemption for Emergency Generator
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-4927887696433986469&simpl=msg-a:r-82731503485123…7/7
Response Summary:
To be eligible businesses shall not do any of the follow:

1) Emit more than 5 tons per year of each of the following pollutants: Sulfur Dioxide (SO2), Carbon Monoxide (CO),
Nitrogen Oxides (NOx), Particulate Matter (PM10), Ozone (O3), or Volatile Organic Compounds (VOCs).
2) Emit more than 500 lbs/yr of any single Hazardous Air Pollutant (HAP), and emit more than 2000 lbs/yr of any
combination of HAPs
3) Emit more than 500 lbs/yr of any combination of air contaminants not listed in 1 or 2

A copy of this registration notice and worksheets are required on site to verify permit exemption status.

Please be aware a the Small Source Exemption ONLY exempts the site from the air permitting requirements of R307-
401-5 thru R307-401-8 of the Utah Administrative Code, all other air quality regulations still apply.

Q4.
Please fill out the following contact information:
Site Contact Site Owner
Name Joel Yoder
Defense Depot Ogden
- Utah Army National
Guard
UTARNG - G9 Environmental
Resources Management
Mailing Address 968 West 400 North 968 West 400 North 12953 Minuteman Drive
Mailing Address 2 Building 11C Bay 2 Building 11C Bay 1 G9 - CFMO - ERM
City Ogden Ogden Draper
State UT UT UT
Zip Code 84404 84404 84020
Phone [phone]-4386
Fax N/A N/A 801-523-4449
Email [e-mail] N/A [e-mail]

Q5. County the Site is located in:
Weber County

Q6. Briefly describe the process including the end products, raw materials, and process equipment used.
One (1) emergency generator (Magna One, 300 KW) powered by a diesel-fueled engine (Caterpillar, 463 HP) is
located in Bay 1 and connected to classrooms in Bay 2.

Q7. List emission units
One (1) emergency generator engine

Q8. List any pollution control equipment
None

Q9. Please include Annual Emission Rates calculation spreadsheet.
[Click here]

Q11. Contact Information: (person filling out form - signature will be required)
Name Mark Hogan
Title Environmental Scientist - Air Quality Manager
Phone [phone]
Date 4/1/2025

Q10. By signing below, I hereby certify that the information and data submitted in this notice fully describes
this site and ONLY this site. The information provide is true, accurate, and complete to the best of my
knowledge. I understand that I am responsible for determining whether the site remain eligible for this
exemption before making operational or process changes in the future, and agree to notify the Division of
Air Quality when this site is not longer eligible for this exemption. (Signature of Owner/Manager)
[Click here]

Embedded Data:
N/A