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Home My WebLink AboutDAQ-2024-010422 Small Source Registration DAQE-EN126250005-24 {{$d1 }} Greg Warner Utah Athletic Foundation 3419 Olympic Parkway PO Box 980337 Park City, UT 84098 GWarner@uolf.org Dear Mr. Warner: Re: Request for Evaluation of Compliance with Rule R307-401-9, UAC: Small Source Exemption Project Fee Code: N126250005 On August 13, 2024, the Division of Air Quality (DAQ) received your request for a small source exemption for the Utah Olympic Oval. The source is located at 5662 S. 4800 W. Kearns, Salt Lake County. DAQ has determined the small source exemption applies to the source based on DAQ emission estimates and source verified process operations. The equipment on site consists of three (3) 2 MMBtu/hr boilers, four (4) 2.5 MMBtu/hr boilers, one (1) 750 kW emergency generator, and various ice sheet maintenance vehicles. The boilers are exempted equipment under R307-401-10. 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 calculated by the DAQ, the Utah Athletic Foundation is not required to obtain an approval order under R307-401 for the Utah Olympic Oval. 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director 2 $ 2 0 1 Û Ü Û Ù Û Ý DAQE-EN126250005-24 Page 2 Thank you for registering your source with the DAQ. If you have any additional questions, please contact Katie Andersen at (385) 515-1748 or kandersen@utah.gov. Sincerely, Bryce C. Bird Director {{$s }} 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}} Year Fuel Usage 2022 31347 decatherms 2023 28598 decatherms NOx Emission Factor 100 lb/10^6 scf AP-42 Table 1.4-1, Uncontrolled CO Emission Factor 84 lb/10^6 scf AP-42 Table 1.4-1, Uncontrolled CO2 Emission Factor 120,000 lb/10^6 scf AP-42 Table 1.4-2 Lead Emission Factor 0.0005 lb/10^6 scf AP-42 Table 1.4-2 N2O Emission Factor 0.64 lb/10^6 scf AP-42 Table 1.4-2, Controlled low nox burner PM Total Emission Factor 7.6 lb/10^6 scf AP-42 Table 1.4-2 SO2 Emission Factor 0.6 lb/10^6 scf AP-42 Table 1.4-2 VOC Emission Factor 5.5 lb/10^6 scf AP-42 Table 1.4-2 1 decatherm=1,026 scf 2022 32162022 scf/yr NOx Emissions 1.61 ton/yr CO Emissions 1.35 ton/yr CO2 Emissions 1929.72 ton/yr Lead Emissions 0.00 ton/yr N2O 0.01 ton/yr PM Total 0.12 ton/yr SO2 0.01 ton/yr VOC 0.09 ton/yr 2023 29341548 scf/yr NOx Emissions 1.47 ton/yr CO Emissions 1.23 ton/yr CO2 Emissions 1760.49 ton/yr Lead Emissions 0.00 ton/yr N2O 0.01 ton/yr PM Total 0.11 ton/yr SO2 0.01 ton/yr VOC 0.08 ton/yr Average 30751785 scf/yr NOx Emissions 1.54 tpy CO Emissions 1.29 tpy CO2 Emissions 1845.11 tpy Lead Emissions 0.00 tpy N2O 0.01 tpy PM Total 0.12 tpy SO2 0.01 tpy VOC 0.08 tpy Emissions Including Engine NOx Emissions 2.75 tpy CO Emissions 1.57 tpy CO2 Emissions 1903.11 tpy Lead Emissions 0.00 tpy N2O 0.01 tpy PM Total 0.16 tpy SO2 0.01 tpy VOC 0.11 tpy Equipment Details Rating 1,005 hp = (750 Operationa 100 hours/year Sulfur Con 15 ppm or 0.0 Criteria Po tandards (n Factor (lbon Rate (lb Total (tonsReference NOX 0.024 24.12 1.21 CO 5.50E-03 5.53 0.28 PM10 7.00E-04 0.7 0.04 PM2.5 7.00E-04 0.7 0.04 VOC 6.42E-04 0.64 0.03 SO2 1.21E-05 0.01 0 42 Table 3.4-1 HAP 0.01 0 See Below Green Ho Warming Pn Factor (lbon Rate (lb Total (tonsReference CO2 (mas 1 1.16 1,166 58 Methane ( 25 6.35E-05 0 0 CO2e 58 Diesel-Fired Engines s should equal 100 hours o -42 Table 3 e 3.3-1 & Ta Boilers at 2.5 MMBtu/hour and 8760 hours/yr Pollutant tpy NOX 1.07 CO 0.90 PM10 0.08 PM2.5 0.08 SO2 0.01 VOC 0.06 Lead 0.00 HAP 0.02 Emergency Engine Pollutant tpy NOX 0.52 CO 0.11 PM10 0.04 PM2.5 0.04 NOX VOC 0.04 CO SO2 0.00 PM10 HAP 0.00 PM2.5 SO2 Total Combined VOC pollutant tpy Lead NOX 4.81 HAP CO 3.72 CO2 (mass bas PM10 0.36 Methane (mass PM2.5 0.36 N2O (mass bas VOC 0.07 CO2e SO2 0.24 HAP 0.00 7 boilers 2 are a different size - plus a summer boiler 3 2-Mmbtu two for domestic, one for back up one is on 24/7, only used 8 hours a day, 6 days 4 2.5 MMBtu for heating the building typically, at least one is running. Other 3 are on Generator - 750 kW 5 roof top heaters that are used in the winter - Totals tpy 0.489411765 1.073529412 0.705882353 2.268823529 0.411105882 0.901764706 0.592941176 1.905811765 0.037195294 0.081588235 0.053647059 0.172430588 0.037195294 0.081588235 0.053647059 0.172430588 0.002936471 0.006441176 0.004235294 0.013612941 0.026917647 0.059044118 0.038823529 0.124785294 2.44706E-06 5.36765E-06 3.52941E-06 1.13441E-05 0.009242337 0.020273154 0.013330293 0.042845784 587.2941176 1288.235294 847.0588235 2722.588235 0.011256471 0.024691176 0.016235294 0.052182941 0.010767059 0.023617647 0.015529412 0.049914118 590.7841129 1295.890632 852.0924706 2738.767216 Assume only one online 1-2.5 MMBtu running 24/7 running 24/7 in 4 winter 8760 2496 Month 2022 DTH 2023 DTH 2024 DTH January 4388 4122 3838 February 3971 3767 3500 March 3636 3512 3265 April 1546 1341 1430 May 1679 1213 1253 June 742 737 757 July 847 1232 1817 August 1669 1543 September 1827 1894 October 2683 2639 November 3971 2974 December 4388 3624 31347 28598 15860 Katie Andersen <kandersen@utah.gov> 10-Year Review of DAQE-AN707-01 7 messages Katie Andersen <kandersen@utah.gov>Tue, Jun 11, 2024 at 4:05 PM To: gwarner@uolf.org Hi Greg, We spoke on the phone a few weeks ago about the air quality permit for the Utah Olympic Oval. I believe we set a date for a follow-up call, but I must have forgotten to put it in my calendar. Apologies for not calling! Like I mentioned over the phone, the Utah Division of Air Quality (DAQ) likes to update Approval Orders when they become older than 10 years. This is so the permits match the language and formatting of current DAQ standards. Another reason to update the permits is to ensure that the source is still operating as outlined in the permit. The Utah Olympic Oval Approval Order is up for a 10-Year Review. Our Compliance team noted in 2018 that four 2.5 MMBtu boilers replaced the boilers mentioned in Equipment Item 7.A and 7.B. When we spoke over the phone a few weeks back, you mentioned that there are actually 7 boilers on site. Would you please send me the manufacturer data/specifications and any information about the boilers? I will be running some emission calculations with the data you provide me. I appreciate your cooperation. Cheers, Katie Andersen -- Katie Andersen Engineering Technician I | Minor NSR Section M: (385) 515-1748 airquality.utah.gov Greg Warner <GWarner@uolf.org>Tue, Jul 2, 2024 at 2:38 PM To: Katie Andersen <kandersen@utah.gov> Hi Katie, Here is the remaining information you requested. 8/14/24, 11:03 AM State of Utah Mail - 10-Year Review of DAQE-AN707-01 https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1160306123350355958&simpl=msg-a:r-40926434459124…1/5 Generator 250kW 2ea. 250k BTU roof mount heating units. 3ea. 36K BTU roof mount heating units. Hope this helps, Greg From: Kae Andersen <kandersen@utah.gov> Sent: Tuesday, June 11, 2024 4:06 PM To: Greg Warner <GWarner@uolf.org> Subject: 10-Year Review of DAQE-AN707-01 Hi Greg, We spoke on the phone a few weeks ago about the air quality permit for the Utah Olympic Oval. I believe we set a date for a follow-up call, but I must have forgotten to put it in my calendar. Apologies for not calling! Like I mentioned over the phone, the Utah Division of Air Quality (DAQ) likes to update Approval Orders when they become older than 10 years. This is so the permits match the language and formatting of current DAQ standards. Another reason to update the permits is to ensure that the source is still operating as outlined in the permit. The Utah Olympic Oval Approval Order is up for a 10-Year Review. Our Compliance team noted in 2018 that four 2.5 MMBtu boilers replaced the boilers mentioned in Equipment Item 7.A and 7.B. When we spoke over the phone a few weeks back, you mentioned that there are actually 7 boilers on site. Would you please send me the manufacturer data/specifications and any information about the boilers? I will be running some emission calculations with the data you provide me. I appreciate your cooperation. Cheers, Katie Andersen -- 8/14/24, 11:03 AM State of Utah Mail - 10-Year Review of DAQE-AN707-01 https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1160306123350355958&simpl=msg-a:r-40926434459124…2/5 Katie Andersen Engineering Technician I | Minor NSR Section M: (385) 515-1748 airquality.utah.gov Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here. Katie Andersen <kandersen@utah.gov>Tue, Jul 2, 2024 at 3:03 PM To: Greg Warner <GWarner@uolf.org> Thank you Greg! I have used the numbers provided to get a quick estimate on the emissions from the Olympic Oval. It may be possible that the Olympic Oval qualifies for a Small Source Exemption. Small Source Exemptions are for sources that emit less than 5 tons per year of any criteria pollutant, 500 pounds per year of a hazardous air pollutant, or 500 pounds per year of any other air contaminant. With a Small Source Exemption, sources are not required to pay annual NSR fees, undergo inspections, nor notify the DAQ when they make modifications (unless those modifications would exceed the emission thresholds). Will you send me your record of natural gas consumption for the last 2 years? I will be able to verify if the Olympic Oval qualifies for a Small Source Exemption with the natural gas consumption record. If you would rather keep your Approval Order or if the Olympic Oval will be undergoing any modifications that would increase the air emissions, then I will move forward with updating it to match the language, format, and layout to current DAQ standards. Cheers, Katie Andersen [Quoted text hidden] 8/14/24, 11:03 AM State of Utah Mail - 10-Year Review of DAQE-AN707-01 https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1160306123350355958&simpl=msg-a:r-40926434459124…3/5 -- [Quoted text hidden] Katie Andersen <kandersen@utah.gov>Fri, Aug 2, 2024 at 9:25 AM To: Greg Warner <GWarner@uolf.org> Hi Greg, We spoke on the phone about two weeks ago, so I just wanted to follow up since I haven't heard from you. Can you send me the natural gas consumption records for the last 2 years? I'd like to see if you could qualify for a Small Source Exemption. If you'd rather not worry about it and keep your Approval Order in place, I can continue with updating the AO. I just want to let you know about options you may have. Let me know what you would like to do. Cheers, Katie Andersen [Quoted text hidden] Greg Warner <GWarner@uolf.org>Tue, Aug 6, 2024 at 12:12 PM To: Katie Andersen <kandersen@utah.gov> Hi Katie, Finaly able to get that Round To It. [Quoted text hidden] [Quoted text hidden] Dominion Fuel Decatherms.xlsx 13K Katie Andersen <kandersen@utah.gov>Tue, Aug 13, 2024 at 3:02 PM To: Greg Warner <GWarner@uolf.org> Greg, Thank you for sending that information. I was able to estimate your emissions and found that the Olympic Oval qualifies for a Small Source Exemption. Small Source Exemptions are for sources that emit less than 5 tons per year of any criteria pollutant, 500 pounds per year of a hazardous air pollutant, or 500 pounds per year of any other air contaminant. With a Small Source Exemption, sources are not required to pay annual NSR fees, undergo inspections, nor notify the DAQ when they make modifications (unless those modifications would exceed the emission thresholds). Would you like me to process a Small Source Exemption for the Olympic Oval? If not, I will update and issue an Approval Order for the Olympic Oval. 8/14/24, 11:03 AM State of Utah Mail - 10-Year Review of DAQE-AN707-01 https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1160306123350355958&simpl=msg-a:r-40926434459124…4/5 Cheers, Katie Andersen [Quoted text hidden] -- [Quoted text hidden] Greg Warner <GWarner@uolf.org>Tue, Aug 13, 2024 at 3:31 PM To: Katie Andersen <kandersen@utah.gov> Cc: Todd Porter <TPorter@uolf.org> Katie, I think it would be a good idea to get the exemption. Thanks for all the help, [Quoted text hidden] [Quoted text hidden] 8/14/24, 11:03 AM State of Utah Mail - 10-Year Review of DAQE-AN707-01 https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r1160306123350355958&simpl=msg-a:r-40926434459124…5/5