DAQ-2024-010423

DAQE-GN126250006-24

{{$d1 }}

Greg Warner
Utah Athletic Foundation
3419 Olympic Parkway
PO Box 980337
Park City, UT 84098
[e-mail]

Dear Mr. Warner:

RE: Revocation of Approval Order (DAQE-707-01) dated August 28, 2001
Project Number: N126250006

The Division of Air Quality (DAQ) initiated a 10-Year Review for Approval Order DAQE-707-01 for the
Utah Athletic Foundation’s Utah Olympic Oval. During this process, information was received from the
Utah Athletic Foundation to update emissions at the facility. This update resulted in a decrease in
emissions, and the source was found to be under the thresholds for a Small Source Exemption. Because of
this, the source requested a Small Source Exemption from the DAQ. Therefore, the DAQ has revoked the
AO referenced above as of the date of this letter.

As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the
invoice.

If you have any questions, please contact Katie Andersen, who can be reached at [phone].

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:KA:jg

cc: EPA Region 8
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}
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

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

August 26, 2024

DAQE-GN126250006-24

{{$d1 }}

Greg Warner
Utah Athletic Foundation
3419 Olympic Parkway
PO Box 980337
Park City, UT 84098
[e-mail]

Dear Mr. Warner :

RE: Revocation of Approval Order (DAQE-707-01) dated August 28, 2001
Project Number: N126250006

The Division of Air Quality (DAQ) initiated a 10-Year Review for Approval Order DAQE-707-01 for the
Utah Athletic Foundation’s Utah Olympic Oval. During this process, information was received from the
Utah Athletic Foundation to update emissions at the facility. This update resulted in a decrease of
emissions, and the source was found to be under the thresholds for a Small Source Exemption. Because of
this, the source requested a Small Source Exemption from the DAQ. Therefore, the DAQ has revoked the
AO referenced above as of the date of this letter.

As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the
invoice.

If you have any questions, please contact Katie Andersen who can be reached at [phone].

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:xx:jg

cc: , EPA Region 8
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
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

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director
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 <[e-mail]>
10-Year Review of DAQE-AN707-01
7 messages
Katie Andersen <[e-mail]>Tue, Jun 11, 2024 at 4:05 PM
To: [e-mail]
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: [phone]
airquality.utah.gov
Greg Warner <[e-mail]>Tue, Jul 2, 2024 at 2:38 PM
To: Katie Andersen <[e-mail]>
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 <[e-mail]>
Sent: Tuesday, June 11, 2024 4:06 PM
To: Greg Warner <[e-mail]>
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: [phone]
airquality.utah.gov

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Katie Andersen <[e-mail]>Tue, Jul 2, 2024 at 3:03 PM
To: Greg Warner <[e-mail]>
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 <[e-mail]>Fri, Aug 2, 2024 at 9:25 AM
To: Greg Warner <[e-mail]>
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 <[e-mail]>Tue, Aug 6, 2024 at 12:12 PM
To: Katie Andersen <[e-mail]>
Hi Katie,

Finaly able to get that Round To It.
[Quoted text hidden]
[Quoted text hidden]
Dominion Fuel Decatherms.xlsx
13K
Katie Andersen <[e-mail]>Tue, Aug 13, 2024 at 3:02 PM
To: Greg Warner <[e-mail]>
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 <[e-mail]>Tue, Aug 13, 2024 at 3:31 PM
To: Katie Andersen <[e-mail]>
Cc: Todd Porter <[e-mail]>
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