DAQ-2024-011081

DAQE-AN101210294-24

{{$d1 }}

Amanda Burton
Hill Air Force Base
75 CEG/CEIE
7290 Weiner Street, Building 383
Hill Air Force Base, UT 84056-5003
[e-mail]

Dear Ms. Burton:

Re: Approval Order: Administrative Amendment to Approval Order to DAQE-AN101210261-18, to
Update Equipment List
Project Number: N101210294

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on July 22,
2024. Hill Air Force Base must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Tad Anderson, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:JB:jg

cc: Davis County Health Department
EPA Region 8

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

September 25, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN101210294-24
Administrative Amendment to Approval Order to
DAQE-AN101210261-18, to Update Equipment List

Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]

Issued to
Hill Air Force Base - Main Base

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 25, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN101210294-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Hill Air Force Base Hill Air Force Base - Main Base

Mailing Address Physical Address
75 CEG/CEIE 7290 Weiner Street, Building 383 75 CEG/CEIE 7290 Weiner Street, Building 383
Hill Air Force Base, UT 84056-5003 Hill Air Force Base, UT 84056-5003

Source Contact UTM Coordinates
Name: Erik Dettenmaier 416,588 m Easting
Phone: [phone],553,000 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 9711 (National Security)

SOURCE INFORMATION
General Description
Hill Air Force Base (Hill AFB) is a major U.S. Air Force base located in northern Utah, just south of the
city of Ogden. Hill AFB is the home of the Air Force Materiel Command's Ogden Air Logistics Complex,
which is the worldwide manager for a wide range of aircraft, engines, missiles, software, avionics, and
accessory components.

NSR Classification
Administrative Amendment

Source Classification
Located in Davis County
Airs Source Size: A

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), PPPPP: National Emission Standards for Hazardous Air Pollutants for
Engine Test Cells/Stands
Title V (Part 70) Major Source
DAQE-AN101210294-24
Page 4

Project Description
Hill AFB is requesting to add a third burnout oven to the Engine Test Stands AO. There is no change in
workload, and the natural gas rolling 12-month is not increasing. The third oven is needed to support the
existing workload when the two current burnout ovens are out of service for maintenance.

On October 31, 2019, Hill AFB submitted a notification of a reduction in air pollutants to the Utah
Division of Air Quality for the replacement of AQUIS ID 38106 rated at 0.75 MMBtu/hr with a smaller
burnout oven. These changes are being incorporated into this permit change.
Process Description
Load Testing of Generators
The load bank is used for testing the completed mobile generator unit after repair/overhaul. The
generators use diesel fuel.

Burn-off ovens
The burn-off ovens are used to burn off coating and debris from the electrical generator components.
Emission factors include combustion products and emissions from material being burned off. The lb/hr
emission factors represent the burn-off cycle. Hill AFB tracks operating hours and then calculates gas
consumption using burner ratings and altitude adjustments.

IC engine/turbine test stands
Test stands will be used to test engines being repaired/overhauled. It is assumed that emissions from JP-8
are 0.053 weight percent (from Defense Logistics Agency, Defense Energy Support Center, Petroleum
Quality Information System Fuel Data [1998-2009]). The initial puff of smoke is the result of residual oil
in the cylinders after repair and is insufficient and unquantifiable.

Basic Expeditionary Air Field and Resources (BEAR) power unit load test system
The additional load testing operation is needed to support the BEAR weapon system diesel-fired support
units. The BEAR engines are reworked and then connected to an existing dyno test stand. After passing
dyno testing, the engine will be reinstalled in the reworked generator, and the power unit will be tested to
ensure it works. After passing this testing, the power unit will be connected to the new load testing system
to ensure the rework unit can meet the load requirements in the field. Multiple load test rates are required
for military specifications.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Ammonia 0 0.03
CO2 Equivalent 0 1160.00
Carbon Monoxide 0 3.40
Nitrogen Oxides -0.16 13.03
Particulate Matter - PM10 0 0.93
Particulate Matter - PM2.5 0 0.93
Sulfur Oxides 0 0.04
Volatile Organic Compounds 0 2.08

DAQE-AN101210294-24
Page 5

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 69
Change (TPY) Total (TPY)
Total HAPs 0 0.03

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 five-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 five 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]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT
II.A.1 Main Base Base Wide II.A.2 Oven-1
Natural gas-fired burnout oven (AQUIS #34356)
Oven type: Two Stage Burner Capacity: 0.5 MMBtu/hr

DAQE-AN101210294-24
Page 6

II.A.3 Oven-2 Natural gas-fired burnout oven (AQUIS #45018) Oven type: Two Stage Burner Capacity: 0.283 MMBtu/hr Controls: Low NOx Technology II.A.4 Oven-3 (NEW) Natural gas-fired burnout oven (AQUIS #45551)
Oven type: Two Stage Burner Capacity: 0.52 MMBtu/hr Controls: Low NOx Technology

II.A.5 Test Stand IC engine/turbine test stands (AQUIS #34360) Power rated: greater than 25 horse power II.A.6 Load Test System (new)
Load testing operations and associated equipment

II.A.7 Generator Generator Load Testing Operations and associated equipment (AQ ID 3617) Generator fuel type: Fuel* *JP-4, JP-5, JP-6, JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director.

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Base Wide Requirements
II.B.1.a The following consumption limit shall not be exceeded: 10.78 MMSCF/yr of natural gas consumed per rolling 12-month period. [R307-401-8]
II.B.1.b The permittee shall not exceed 40,000 gallons of combined fuels consumed (JP-4, JP-5, JP-6, JP-8, JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director) by the IC
engine/turbine test stands, load test system, and generator testing equipment per rolling 12-month
period. The permittee shall not exceed 5,400 gallons of gasoline consumed by the IC engine/turbine test stands per rolling 12-month period. [R307-401-8]

II.B.1.c Visible emissions from natural gas fired equipment shall be no greater than 10% opacity. [R307-401-8]
II.B.1.d Visible emissions from the combustion of JP-4, JP-5, JP-6, JP-8, JP-10, Jet A, or equivalent fuels as determined by the Director in the Test Stand/Load Test System, and diesel-fired engines shall be no greater than 20% opacity, except for a period not exceeding three minutes in any hour for
diesel-fired operation. [R307-305-3]

DAQE-AN101210294-24
Page 7

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN101210261-18 dated December 26, 2018 Is Derived From NOI dated July 22, 2024

DAQE-AN101210294-24
Page 8

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN101210294 August 21, 2024 Amanda Burton
Hill Air Force Base 75 CEG/CEIE 7290 Weiner Street
Building 383 Hill Air Force Base, UT 840565003 [e-mail]
Dear Amanda Burton, Re: Engineer Review: Administrative Amendment to Approval Order to DAQE-AN101210261-18, to Update Equipment List Project Number: N101210294 Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this document to be considered as the application for a Title V administrative amendment, a Title V Responsible Official must sign the next page.
Please contact Tad Anderson at [phone] if you have any questions or concerns about the ER. If you accept the contents of this ER, please email this signed cover letter to Tad Anderson at [e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.
If Hill Air Force Base does not respond to this letter within 10 business days, the project will move forward without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
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
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 1
OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be considered as an application to administratively amend your Title V Permit, the Responsible Official, as
defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL. If you do not want the Engineer Review to be considered as an application to administratively amend your Operating Permit only the approval signature above is required. Failure to have the Responsible Official sign below will not delay the Approval Order, but will require submittal of a separate Operating Permit Application to revise the Title V permit in accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit Application Due Dates clarifies the required due dates for Title V operating permit applications and can be viewed at:
https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality “Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided for this Approval Order are true, accurate and complete and request that this Approval Order be considered as an application to administratively amend the Operating Permit.” Responsible Official _________________________________________________ (Signature & Date) Print Name of Responsible Official _____________________________________

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N101210294 Owner Name Hill Air Force Base
Mailing Address 75 CEG/CEIE 7290 Weiner Street Building 383
Hill Air Force Base, UT, 840565003 Source Name Hill Air Force Base- Main Base
75 CEG/CEIE 7290 Weiner Street Building 383 Hill Air Force Base, UT 84056-5003 UTM Projection 416,588 m Easting, 4,553,000 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 9711 (National Security) Source Contact Erik Dettenmaier
Phone Number [phone] Email [e-mail]
Billing Contact Erik Dettenmaier Phone Number [phone] Email [e-mail]
Project Engineer Tad Anderson, Engineer Phone Number [phone] Email [e-mail] Notice of Intent (NOI) Submitted July 24, 2024 Date of Accepted Application July 31, 2024

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 3
SOURCE DESCRIPTION General Description
Hill Air Force Base (Hill AFB) is a major U.S. Air Force base located in northern Utah, just south of the city of Ogden. Hill AFB is the home of the Air Force Materiel Command's Ogden Air Logistics Complex which is the worldwide manager for a wide range of aircraft, engines,
missiles, software, avionics, and accessories components. NSR Classification: Administrative Amendment Source Classification Located in, Davis County Airs Source Size: A Applicable Federal Standards MACT (Part 63), A: General Provisions
MACT (Part 63), PPPPP: National Emission Standards for Hazardous Air Pollutants for Engine Test Cells/Stands Title V (Part 70) Major Source
Project Proposal Administrative Amendment to Approval Order to DAQE-AN101210261-18, to Update
Equipment List Project Description Project Description Hill AFB is requesting to add a third burnout oven to the Engine Test Stands AO. There is no change in workload and the natural gas rolling 12-month is not increasing. The third oven is
needed to support the existing workload when the two current burnout ovens are out of service for maintenance. On 31 October 2019, Hill AFB submitted a notification of a reduction in air pollutants to the Utah Division of Air Quality for the replacement of AQUIS ID 38106 rated at 0.75 MMBtu/hr with a smaller burnout oven. These changes are being incorporated into this permit change. Process Description
Load Testing of Generators The load bank is used for testing of completed mobile generator unit after repair/overhaul. The generators use diesel fuel.
Burn-off ovens The burn-off ovens are used to burn off coating and debris from the electrical generator components. Emission factors include combustion products and emissions from material being burned off. The lb/hr emission factors represent the burn-off cycle. Hill tracks operating hours and then calculates gas consumption using burner ratings and altitude adjustments.
IC engine/turbine test stands Test stands will be used to test engines being repaired/overhauled. It is assumed that emissions from JP-8 are 0.053 weight percent (from Defense Logistics Agency, Defense Energy Support

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 4
Center, Petroleum Quality Information System Fuel Data [1998-2009]). The initial puff of smoke is the result of residual oil in the cylinders after repair and is insufficient and unquantifiable.
Basic Expeditionary Air Field and Resources (BEAR) power units load test system The additional load testing operation is needed to support the BEAR weapon system diesel-fired support units. The BEAR engines are reworked and then connected to an existing dyno test stand. After passing dyno testing, the engine will be reinstalled in the reworked generator and the power unit will be tested to ensure it works. After passing this testing, the power unit will be connected to the new load testing system to ensure the rework unit can meet the load requirements in the field. Multiple load test rates are required for military specifications. EMISSION IMPACT ANALYSIS This administrative amendment does not involve any new or increasing air pollutants. No modeling is required as per R307-410-4 or R307-410-5 since the emission rate is decreasing. [Last updated July 31, 2024]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 5
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) Ammonia 0 0.03 CO2 Equivalent 0 1160.00
Carbon Monoxide 0 3.40
Nitrogen Oxides -0.16 13.03
Particulate Matter - PM10 0 0.93
Particulate Matter - PM2.5 0 0.93
Sulfur Oxides 0 0.04 Volatile Organic Compounds 0 2.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 69
Change (TPY) Total (TPY)
Total HAPs 0 0.03
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 6
Review of BACT for New/Modified Emission Units 1. BACT review regarding BACT
This permit change does not involve any addition of new increase in emission rates and subject to R307-401-2, Reduction in Air Pollutants. BACT is not required since it does not require a NOI as per R307-401-5. [Last updated July 31, 2024]

SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): 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 five-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 five (5) 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]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 7
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Main Base Base Wide II.A.2 Oven-1 Natural gas fired burnout oven (AQUIS #34356) Oven type: Two Stage Burner Capacity: 0.5 MMBtu/hr
II.A.3 Oven-2
Natural gas fired burnout oven (AQUIS #45018) Oven type: Two Stage Burner Capacity: 0.283 MMBtu/hr Controls: Low NOx Technology II.A.4 NEW Oven-3 (NEW) Natural gas fired burnout oven (AQUIS #45551)
Oven type: Two Stage Burner Capacity: 0.52 MMBtu/hr Controls: Low NOx Technology

II.A.5 Test Stand IC engine/turbine test stands (AQUIS #34360) Power rated: greater than 25 horse power

II.A.6 Load Test System Load testing operations and associated equipment II.A.7 Generator Generator Load Testing Operations and associated equipment (AQ ID 3617)
Generator fuel type: Fuel* *JP-4, JP-5, JP-6, JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director.

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 8
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Base Wide Requirements
II.B.1.a The following consumption limit shall not be exceeded:
10.78 MMSCF/yr of Natural gas consumed per rolling 12-month period. [R307-401-8]

II.B.1.b The permittee shall not exceed 40,000 gallons of combined fuels consumed (JP-4, JP-5, JP-6, JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director) by the IC engine/turbine test stands, load test system and generator testing equipment per rolling 12-month period. The permittee shall not exceed 5,400 gallons of gasoline consumed by the IC engine/turbine test stands per rolling 12-month period. [R307-401-8]
Visible emissions from natural gas fired equipment shall be no greater than 10 percent opacity. [R307-401-8]
II.B.1.d Visible emissions from the combustion of JP-4, JP-5, JP-6, JP-8, JP-10, Jet A, or equivalent fuels as determined by the Director in the Test Stand/Load Test System, and diesel-fired engines shall be no greater than 20 % opacity, except for a period not exceeding three minutes in any hour for diesel-fired operation. [R307-305-3]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Is Derived From NOI dated July 22, 2024
Supersedes DAQE-AN101210261-18 dated December 26, 2018
REVIEWER COMMENTS

1. Comment regarding Emission Estimates: The NOx emissions for the new and updated ovens used AP-42, Table 1.4-1 'Emission Factors for Nitrogen Oxides from Natural Gas Combustion' for small boilers. The uncontrolled emission factor of 100 lb/MMscf was used for Oven 1 (AQ ID 34356). The controlled - low NOx burners emission factor of 50 lb/MMscf was used for Ovens 2 and 3. The 10.78 MMSCF/yr natural gas limit will remain the same. [Last updated July 31, 2024] 2. Comment regarding Emissions Reduction: The NOx PTE emissions for natural gas combustion in the existing burnout ovens are based on burnout ovens without NOx controls or low NOx controls. The 2019 replacement burnout oven and the new requested third burnout oven are equipped with low NOx controls. The NOx PTE emissions
were recalculated with the replaced and new low NOx burners on the burnout ovens which results in a reduction in NOx emissions. [Last updated August 1, 2024]
3. Comment regarding Project Type: This permit change is being conducted as a Reduction of Air Pollutants UAC R307-401-12. NOx
emissions are reducing, and all other emissions are remaining the same in this permit change. The new and updated burnout ovens have been installed with low NOx controls and the natural gas limit remains the same. [Last updated July 31, 2024] 4. Comment regarding Replacement in Kind: On 31 October 2019, Hill AFB submitted a notification to the Utah Division of Air Quality for the replacement of Oven-2 (AQUIS ID 38106) rated at 0.75 MMBtu/hr with a smaller burnout oven. The new oven, AQ ID 45018, is rated at 0.283 MMBtu/hr and has low NOx burners. This equipment change was conducted as a Replacement in Kind Equipment UAC R307-401-11 and is being updated in this administrative Amendment. [Last updated July 31, 2024] 5. Comment regarding Applicable Regulations: Hill AFB is subject to MACT 40 CFR 63, Subpart GG, National Emission Standards for Aerospace Manufacturing and Rework Facilities and UAC R307-355. This operation and equipment are not
subject to 40 CFR 63, Subpart GG. Hill AFB is subject UAC R307-355 "Control of Emissions from Aerospace Manufacture and Rework Facilities". [Last updated July 31, 2024]
6. Comment regarding De-aggregate: Hill AFB is classified as a major source of air pollution and subject to the Operating Permit Program. Hill AFB is a SIP-listed source, a major source for VOC and PM10, and a PSD source for
NOx and CO. Hill AFB has multiple active AOs but only one Title V permit. Hill AFB is a military air force base and governed under the Department of Defense (DOD). It is not required (for military)

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 10
nor needed to combine all the approval orders as the Title V is the combined permit. Hill AFB is classified as if all the permits were combined, and all projects and pollutants are looked as though
they were one permit. For this reason, the source is allowed to de-aggregate. [Last updated July 31, 2024] 7. Comment regarding SIP Listed Source: Hill AFB is a listed major source with conditions in Part H.12.n of the PM2.5 Serious Nonattainment SIP. The PM2.5 Serious Nonattainment SIP has been approved by the Air Quality Board but has not been approved by Region 8 EPA. The PM2.5 Serious Nonattainment SIP conditions have been incorporated into the current appropriate AOs. This process was reviewed in the SIP analysis, but no conditions were assigned to this operation/AO. No additional SIP /permitting action is required for the addition of the new diesel fuel storage tank. [Last updated July 31, 2024]
8. Comment regarding Permit Change: The addition of the equipment (Oven-3) is the only change to the permit. No new conditions were added since the fuel consumption limit is not changing. [Last updated August 1, 2024]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 11
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
DAQE-

RN101210294 August 21, 2024 Amanda Burton
Hill Air Force Base 75 CEG/CEIE 7290 Weiner Street
Building 383 Hill Air Force Base, UT 840565003 [e-mail]
Dear Amanda Burton, Re: Engineer Review: Administrative Amendment to Approval Order to DAQE-AN101210261-18, to Update Equipment List Project Number: N101210294 Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this document to be considered as the application for a Title V administrative amendment, a Title V Responsible Official must sign the next page.
Please contact Tad Anderson at [phone] if you have any questions or concerns about the ER. If you accept the contents of this ER, please email this signed cover letter to Tad Anderson at [e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.
If Hill Air Force Base does not respond to this letter within 10 business days, the project will move forward without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
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
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 1
OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be considered as an application to administratively amend your Title V Permit, the Responsible Official, as
defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL. If you do not want the Engineer Review to be considered as an application to administratively amend your Operating Permit only the approval signature above is required. Failure to have the Responsible Official sign below will not delay the Approval Order, but will require submittal of a separate Operating Permit Application to revise the Title V permit in accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit Application Due Dates clarifies the required due dates for Title V operating permit applications and can be viewed at:
https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality “Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided for this Approval Order are true, accurate and complete and request that this Approval Order be considered as an application to administratively amend the Operating Permit.” Responsible Official _________________________________________________ (Signature & Date) Print Name of Responsible Official _____________________________________

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N101210294 Owner Name Hill Air Force Base
Mailing Address 75 CEG/CEIE 7290 Weiner Street Building 383
Hill Air Force Base, UT, 840565003 Source Name Hill Air Force Base- Main Base
75 CEG/CEIE 7290 Weiner Street Building 383 Hill Air Force Base, UT 84056-5003 UTM Projection 416,588 m Easting, 4,553,000 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 9711 (National Security) Source Contact Erik Dettenmaier
Phone Number [phone] Email [e-mail]
Billing Contact Erik Dettenmaier Phone Number [phone] Email [e-mail]
Project Engineer Tad Anderson, Engineer Phone Number [phone] Email [e-mail] Notice of Intent (NOI) Submitted July 24, 2024 Date of Accepted Application July 31, 2024

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 3
SOURCE DESCRIPTION General Description
Hill Air Force Base (Hill AFB) is a major U.S. Air Force base located in northern Utah, just south of the city of Ogden. Hill AFB is the home of the Air Force Materiel Command's Ogden Air Logistics Complex which is the worldwide manager for a wide range of aircraft, engines,
missiles, software, avionics, and accessories components. NSR Classification: Administrative Amendment Source Classification Located in, Davis County Airs Source Size: A Applicable Federal Standards MACT (Part 63), A: General Provisions
MACT (Part 63), PPPPP: National Emission Standards for Hazardous Air Pollutants for Engine Test Cells/Stands Title V (Part 70) Major Source
Project Proposal Administrative Amendment to Approval Order to DAQE-AN101210261-18, to Update
Equipment List Project Description Project Description Hill AFB is requesting to add a third burnout oven to the Engine Test Stands AO. There is no change in workload and the natural gas rolling 12-month is not increasing. The third oven is
needed to support the existing workload when the two current burnout ovens are out of service for maintenance. On 31 October 2019, Hill AFB submitted a notification of a reduction in air pollutants to the Utah Division of Air Quality for the replacement of AQUIS ID 38106 rated at 0.75 MMBtu/hr with a smaller burnout oven. These changes are being incorporated into this permit change. Process Description
Load Testing of Generators The load bank is used for testing of completed mobile generator unit after repair/overhaul. The generators use diesel fuel.
Burn-off ovens The burn-off ovens are used to burn off coating and debris from the electrical generator components. Emission factors include combustion products and emissions from material being burned off. The lb/hr emission factors represent the burn-off cycle. Hill tracks operating hours and then calculates gas consumption using burner ratings and altitude adjustments.
IC engine/turbine test stands Test stands will be used to test engines being repaired/overhauled. It is assumed that emissions from JP-8 are 0.053 weight percent (from Defense Logistics Agency, Defense Energy Support

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 4
Center, Petroleum Quality Information System Fuel Data [1998-2009]). The initial puff of smoke is the result of residual oil in the cylinders after repair and is insufficient and unquantifiable.
Basic Expeditionary Air Field and Resources (BEAR) power units load test system The additional load testing operation is needed to support the BEAR weapon system diesel-fired support units. The BEAR engines are reworked and then connected to an existing dyno test stand. After passing dyno testing, the engine will be reinstalled in the reworked generator and the power unit will be tested to ensure it works. After passing this testing, the power unit will be connected to the new load testing system to ensure the rework unit can meet the load requirements in the field. Multiple load test rates are required for military specifications. EMISSION IMPACT ANALYSIS This administrative amendment does not involve any new or increasing air pollutants. No modeling is required as per R307-410-4 or R307-410-5 since the emission rate is decreasing. [Last updated July 31, 2024]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 5
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) Ammonia 0 0.03 CO2 Equivalent 0 1160.00
Carbon Monoxide 0 3.40
Nitrogen Oxides -0.16 13.03
Particulate Matter - PM10 0 0.93
Particulate Matter - PM2.5 0 0.93
Sulfur Oxides 0 0.04 Volatile Organic Compounds 0 2.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 69
Change (TPY) Total (TPY)
Total HAPs 0 0.03
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 6
Review of BACT for New/Modified Emission Units 1. BACT review regarding BACT
This permit change does not involve any addition of new increase in emission rates and subject to R307-401-2, Reduction in Air Pollutants. BACT is not required since it does not require a NOI as per R307-401-5. [Last updated July 31, 2024]

SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): 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 five-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 five (5) 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]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 7
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Main Base Base Wide II.A.2 Oven-1 Natural gas fired burnout oven (AQUIS #34356) Oven type: Two Stage Burner Capacity: 0.5 MMBtu/hr
II.A.3 Oven-2
Natural gas fired burnout oven (AQUIS #45018) Oven type: Two Stage Burner Capacity: 0.283 MMBtu/hr Controls: Low NOx Technology II.A.4 NEW Oven-3 (NEW) Natural gas fired burnout oven (AQUIS #45551)
Oven type: Two Stage Burner Capacity: 0.52 MMBtu/hr Controls: Low NOx Technology

II.A.5 Test Stand IC engine/turbine test stands (AQUIS #34360) Power rated: greater than 25 horse power

II.A.6 Load Test System Load testing operations and associated equipment II.A.7 Generator Generator Load Testing Operations and associated equipment (AQ ID 3617)
Generator fuel type: Fuel* *JP-4, JP-5, JP-6, JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director.

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 8
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Base Wide Requirements
II.B.1.a The following consumption limit shall not be exceeded:
10.78 MMSCF/yr of Natural gas consumed per rolling 12-month period. [R307-401-8]

II.B.1.b The permittee shall not exceed 40,000 gallons of combined fuels consumed (JP-4, JP-5, JP-6, JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director) by the IC engine/turbine test stands, load test system and generator testing equipment per rolling 12-month period. The permittee shall not exceed 5,400 gallons of gasoline consumed by the IC engine/turbine test stands per rolling 12-month period. [R307-401-8]
Visible emissions from natural gas fired equipment shall be no greater than 10 percent opacity. [R307-401-8]
II.B.1.d Visible emissions from the combustion of JP-4, JP-5, JP-6, JP-8, JP-10, Jet A, or equivalent fuels as determined by the Director in the Test Stand/Load Test System, and diesel-fired engines shall be no greater than 20 % opacity, except for a period not exceeding three minutes in any hour for diesel-fired operation. [R307-305-3]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Is Derived From NOI dated July 22, 2024
Supersedes DAQE-AN101210261-18 dated December 26, 2018
REVIEWER COMMENTS

1. Comment regarding Emission Estimates: The NOx emissions for the new and updated ovens used AP-42, Table 1.4-1 'Emission Factors for Nitrogen Oxides from Natural Gas Combustion' for small boilers. The uncontrolled emission factor of 100 lb/MMscf was used for Oven 1 (AQ ID 34356). The controlled - low NOx burners emission factor of 50 lb/MMscf was used for Ovens 2 and 3. The 10.78 MMSCF/yr natural gas limit will remain the same. [Last updated July 31, 2024] 2. Comment regarding Emissions Reduction: The NOx PTE emissions for natural gas combustion in the existing burnout ovens are based on burnout ovens without NOx controls or low NOx controls. The 2019 replacement burnout oven and the new requested third burnout oven are equipped with low NOx controls. The NOx PTE emissions
were recalculated with the replaced and new low NOx burners on the burnout ovens which results in a reduction in NOx emissions. [Last updated August 1, 2024]
3. Comment regarding Project Type: This permit change is being conducted as a Reduction of Air Pollutants UAC R307-401-12. NOx
emissions are reducing, and all other emissions are remaining the same in this permit change. The new and updated burnout ovens have been installed with low NOx controls and the natural gas limit remains the same. [Last updated July 31, 2024] 4. Comment regarding Replacement in Kind: On 31 October 2019, Hill AFB submitted a notification to the Utah Division of Air Quality for the replacement of Oven-2 (AQUIS ID 38106) rated at 0.75 MMBtu/hr with a smaller burnout oven. The new oven, AQ ID 45018, is rated at 0.283 MMBtu/hr and has low NOx burners. This equipment change was conducted as a Replacement in Kind Equipment UAC R307-401-11 and is being updated in this administrative Amendment. [Last updated July 31, 2024] 5. Comment regarding Applicable Regulations: Hill AFB is subject to MACT 40 CFR 63, Subpart GG, National Emission Standards for Aerospace Manufacturing and Rework Facilities and UAC R307-355. This operation and equipment are not
subject to 40 CFR 63, Subpart GG. Hill AFB is subject UAC R307-355 "Control of Emissions from Aerospace Manufacture and Rework Facilities". [Last updated July 31, 2024]
6. Comment regarding De-aggregate: Hill AFB is classified as a major source of air pollution and subject to the Operating Permit Program. Hill AFB is a SIP-listed source, a major source for VOC and PM10, and a PSD source for
NOx and CO. Hill AFB has multiple active AOs but only one Title V permit. Hill AFB is a military air force base and governed under the Department of Defense (DOD). It is not required (for military)

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 10
nor needed to combine all the approval orders as the Title V is the combined permit. Hill AFB is classified as if all the permits were combined, and all projects and pollutants are looked as though
they were one permit. For this reason, the source is allowed to de-aggregate. [Last updated July 31, 2024] 7. Comment regarding SIP Listed Source: Hill AFB is a listed major source with conditions in Part H.12.n of the PM2.5 Serious Nonattainment SIP. The PM2.5 Serious Nonattainment SIP has been approved by the Air Quality Board but has not been approved by Region 8 EPA. The PM2.5 Serious Nonattainment SIP conditions have been incorporated into the current appropriate AOs. This process was reviewed in the SIP analysis, but no conditions were assigned to this operation/AO. No additional SIP /permitting action is required for the addition of the new diesel fuel storage tank. [Last updated July 31, 2024]
8. Comment regarding Permit Change: The addition of the equipment (Oven-3) is the only change to the permit. No new conditions were added since the fuel consumption limit is not changing. [Last updated August 1, 2024]

Engineer Review N101210294: Hill Air Force Base- Main Base August 21, 2024 Page 11
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
DEPARTMENT OF THE AIR FORCE
75TH CIVIL ENGINEER GROUP (AFMC)
HILL AIR FORCE BASE UTAH

22 July 2024

Amanda C. Burton
Chief, Environmental Branch
7290 Weiner St., Building 383
Hill Air Force Base, Utah 84056-5003

Director
Utah Division of Air Quality
Attention: NSR
P.O. Box 144820
Salt Lake City, Utah 84114-4820

Dear Director

Hill Air Force Base (AFB) is submitting this request for an administrative amendment to approval
order (AO) DAQE-AN101210261-18 to incorporate a burnout oven replacement submitted in 2019, add a
third bake oven and update the potential to emit (PTE) emissions. A redline of DAQE-AN101210261-18
with the requested changes is included as Attachment 1.

On 31 October 2019, Hill AFB submitted a request to the Utah Division of Air Quality for the
replacement of AQUIS ID 38106 rated at 0.75 MMBtu/hr with a smaller burnout oven. The new oven,
AQ ID 45018, is rated at 0.283 MMBtu/hr and has low NOx burners. The information of Oven-2 in
Section II.A of the permit needs to be updated with the new burnout oven details.

Hill AFB is requesting to add a third burnout oven. There is no change in workload and an
increase in the 12-month rolling total natural gas usage is not being requested. The third oven is needed
to support the existing workload when the two current burnout ovens are out of service for maintenance.
The new burnout oven will have the following specifications:

Manufacturer: Steelman Industries
Model: 555 BA-E
NOx control: low NOx burners
Oven type: 2-stage
Oven rating: 0.52 MMBtu/hr

The oxides of nitrogen (NOx) PTE emissions for natural gas combustion that are in the permit are
based on burnout ovens without NOx controls or low NOx technology. The 2019 replacement burnout
oven and the third burnout oven are equipped with low NOx technology. The NOx PTE emissions were
recalculated to take into account the low NOx burners. The calculations utilize EPA AP-42 emission
factors. Detailed NOx emission calculations for natural gas combustion are provided Attachment 2. PTE
emissions for the AO are provided in the following table.
Pollutant AO PTE Emissions PTE Emissions
Change New AO PTE Emissions
lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr
PM10 0.21 0.93 0 0 0.21 0.93
PM2.5 0.21 0.93 0 0 0.21 0.93

SOX 8.42E-03 0.04 0 0 8.42E-03 0.04
NOX 3.01 13.19 -0.04 -0.16 2.98 13.03
CO 0.78 3.40 0 0 0.78 3.40
VOC 0.47 2.08 0 0 0.47 2.08
HAPs 4.79E-03 0.02 0 0 4.79E-03 0.02
Ammonia 7.85E-03 0.03 0 0 7.85E-03 0.03
Lead 6.15E-07 2.70E-06 0 0 6.15E-07 2.70E-06
Total CO2e 265 1160 0 0 265 1160

The changes proposed in this NOI do not result in a major modification. Therefore, the
requirements of Utah Administrative Code (UAC) R307-403, R307-405, R307-406 and R307-420 do not
apply. Criteria pollutant modeling is not required because there are no emission increases resulting from
this project. Additionally, a HAP screening analysis under R307-410-5(1)(c) was not conducted as there
are no HAP emission increases.

The new burnout oven is not subject to any New Source Performance Standards or National
Emission Standards for Hazardous Air Pollutants. The burnout oven will comply with the 12-month
rolling total limit for natural gas usage in Condition II.B.19.a of the Hill AFB Main Base Title V
Operating Permit (TVOP). Best available control technology (BACT) for the burnout oven has been
determined to be low NOx burners, good combustion practices, operation / maintenance in accordance
with manufacturer’s instructions and the use of pipeline quality natural gas. A BACT determination for
the new burnout oven is included as Attachment 3.

Hill AFB requests an administrative modification to DAQE-AN101210261-18 via R307-401-12
‘Reduction of Air Pollutants’, as the changes proposed in this request result in an emission reduction. If
you have any questions or would like to discuss this issue further, my point of contact is Dr. Erik
Dettenmaier 75 CEG/CEIEA, at [phone] or [e-mail].

Sincerely
7/24/2024
X Amanda C Burton
Signed by: BURTON.AMANDA.CHRISTINE.1270023068 AMANDA C BURTON, NH-III, DAF
Chief, Environmental Branch

3 Attachments:
1. Redline of DAQE-AN101210261-18
2. PTE Emission Calculations
3. BACT Determination

STATE OF UTAH

Department of Environmental Quality
Division of Air Quality

APPROVAL ORDER: Administrative Amendment to
Approval Order DAQE-AN10121024861-178 to
Add Equipment and Update Emissions

Prepared By: Tad Anderson, Engineer
Phone: [phone]
Email: [e-mail]

APPROVAL ORDER NUMBER
DAQE-AN101210261-18TBD
Date: December 26, 2018TBD

Hill Air Force Base
Main Base
Source Contact:
Erik Dettenmaier
Phone: [phone]
Email: [e-mail] Signed by
Bryce C. Bird on December 26, 2018TBD
Bryce C. Bird
Director
Abstract
Hill Air Force Base (Hill AFB) has requested an Administrative Amendment to the Engine Test Stands AO DAQE-AN10121024861-178, to add equipment for a second load testing operation and update emissions to include ammonia and update greenhouse gas emissions third burnout oven, incorporate a burnout oven replacement done in 2019 via UAC R307-401-12 “Reduction of Air Pollutants” and update the emissions for NOX. The additional load testing operation is needed to support the new Basic Expeditionary Air Field and Resources Weapon System diesel-fired support units. The new workload requires load testing systems to ensure the reworked units can meet the specific load military standards. The PTE emissions have been updated to include ammonia emissions and updated greenhouse gas
emissions for natural gas have been updated to incorporate low NOX burners. This permit change is
being conducted as an administrative amendment under UAC R307-401-12, "Reduction of Air
Pollutants". The ammonia emissions are assumed to be in the process but were not accounted for in the
permit until now. Updating the emissions will change the PTE emission as follows (in TPY): -0.34
PM10, -0.34 PM2.5 (a subset of PM10),-0.14 SOX, -0.07 VOC, -10 CO2e and 0.03 ammonia-0.16 NOX. The PTE emissions are as follows (in TPY):0.93 PM10, 0.93 PM2.5 (a subset of PM10), 13.1903 NOX, 3.40 CO, 0.04 SOX, 2.08 VOC, 0.02 combined HAPs, 1160 CO2e and 0.03 ammonia.
This AO is subject to 40 CFR 63 NESHAP Subpart A and PPPPP "NESHAP for Engine Test Cells/ Stands", however, there are no applicable requirements for these processes. The AO is not subject to any other federal standards of 40 CFR 60, 61, or 63. Hill AFB is classified as a major source of air pollution and subject to the Operating Permit Program. Hill AFB is a major source for VOC, HAP, GHG, PM2.5 and PM10, and a PSD source for NOx and CO. The Title V permit will be administratively amended to incorporate the conditions of this AO. Hill AFB is located in Davis County which is a NAA for PM2.5 and ozone, and an attainment area for all other criteria pollutants. Hill AFB is also located in Weber County which is NAA for PM2.5 and ozone and an attainment area for all other criteria pollutants.
This air quality AO authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order. This AO is issued to, and applies to the following:

Name of Permittee:
Hill Air Force Base 75 CEG/CEIE 7290 Weiner Street, Building 383 Hill Air Force Base, UT 84056-5003
Permitted Location: Main Base 75 CEG/CEIE
7290 Weiner Street, Building 383 Hill Air Force Base, UT 84056-5003
UTM coordinates: 416,588 m Easting, 4,553,000 m Northing, UTM Zone 12
UTM Datum: NAD27
SIC code: 9711 (National Security)

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 five (5)-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 five (5) years. [R307-401-8]
DAQE-AN101210TBD261-2418
Page 3

I.5 At all times, including periods of start-up, 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]
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Main Base
Base-wide
II.A.2 Oven-1
Natural gas-fired burnout oven (AQUIS #34356) Oven type: Two (2) Stage Burner Capacity: 0.5 MMBtu/hr
II.A.3 Oven-2
Natural gas-fired burnout oven (AQUIS #3810645018) Oven type: Two (2) Stage Burner Capacity: 0.75283 MMBtu/hr
II.A.4 Oven-3
Natural gas-fired burnout oven (AQUIS #45551) Oven type: Two (2) Stage Burner Capacity: 0.52 MMBtu/hr
II.A.4II.A.5 Test Stand
IC engine/turbine test stands (AQUIS #34360)
Power rated: greater than 25 horse power
II.A.5II.A.6 Load Test System (new)
Load testing operations and associated equipment
II.A.6II.A.7 Generator
Generator Load Testing Operations and associated equipment (AQ ID 3617) Generator fuel type: Fuel* *JP-4, JP-5, JP-6, JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director
II.B Requirements and Limitations
II.B.1 Base-wide Requirements
II.B.1.a The following consumption limit shall not be exceeded:
10.78 MMSCF/yr of Natural gas consumed per rolling 12-month period
[R307-401-8]
DAQE-AN101210TBD261-2418
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II.B.1.b The permittee shall not exceed 40,000 gallons of combined fuels consumed (JP-4, JP-5, JP-6,
JP-8 JP-10, diesel or Jet A fuels or equivalent fuels to be determined by the Director) by the IC
engine/turbine test stands, load test system and generator testing equipment per rolling 12-
month period. The permittee shall not exceed 5,400 gallons of gasoline consumed by the IC
engine/turbine test stands per rolling 12-month period. [R307-401-8]
II.B.1.c Visible emissions from natural gas-fired equipment shall be no greater than 10% opacity. [R307-401-8]
II.B.1.d Visible emissions from the combustion of JP-4, JP-5, JP-6, JP-8, JP-10, Jet A, or equivalent fuels as determined by the Director in the Test Stand/Load Test System, and diesel-fired engines shall be no greater than 20% opacity, except for a period not exceeding three (3) minutes in any hour for diesel-fired operation. [R307-305-3]
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), A: General Provisions
MACT (Part 63), PPPPP: NESHAP for Engine Test Cells/Stands Title V (Part 70) Major Source
PERMIT HISTORY
This AO is based on the following documents:
Is Derived From NOI dated July 2024August 31, 2018
Supersedes AO DAQE-AN10121026148-187 dated December 26, 2018June 7, 2017
ADMINISTRATIVE CODING
The following information is for UDAQ internal classification use only:
Davis County CDS A PSD, Nonattainment or Maintenance Area, Title V (Part 70) Major Source, Major Criteria Source, MACT (Part 63
DAQE-AN101210TBD261-2418
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ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
NOx Emissions from Natural Gas
lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr
NOX.0.12 0.54 0.09 0.38 -0.04 -0.16
Current Natural Gas PTE Emission Calculations for NOx
lb/MMscf MMscf/yr lb/hr ton/yr
NOX.100 10.78 0.12 0.54
Updated Natural Gas PTE Emission Calculations for NOx
lb/MMscf MMscf/yr lb/hr ton/yr
NOX: uncontrolled 100 4.29 0.05 0.21
NOX: controlled - low NOx burners 50 6.49 0.04 0.16
0.09 0.38
1 Emission factors from:
3 lb/hr emissions calculated assuming the ton/yr emissions occur over 8,760 hours in one year.
Total
(0.50 MMBtu/hr) / (1,020 Btu/scf) * (8,760 hrs/yr) = (4.29 MMscf/yr)
(10.78 MMscf/yr) - (4.49 MMscf/yr) = (6.49 MMscf/yr)
The annual fuel usage for controlled low NOx burners was calculated by subtracting the uncontrolled Nox fuel usage from the 12-MRT permit fuel usage.
- AP-42, Table 1.4-1 ‘Emission Factors for Nitrogen Oxides from Natural Gas Combustion’ (effective July 1998) for small boilers. The uncontrolled emission factor of 100
lb/MMscf was used for AQ ID 34356. The controlled - low NOx burners emission factor of 50 lb/MMscf was used for the remaining burnout ovens.
2 The annual fuel usage for uncontrolled NOx equipment (AQ ID 34356) was calculated via: (rating of AQ ID 34356) / (natural gas heating value) * (hours/yr):
Regulated Pollutant
Current AO NOx PTE
Emissions
Updated NOx PTE
Emissions
Natural Gas NOx Emission
Decrease
- AP-42, Table 1.4-1 ‘Emission Factors for Nitrogen Oxides from Natural Gas Combustion’ (effective July 1998) for small boilers.
Regulated Pollutant
Emission
Factor 1
Natural Gas
Fuel
Consumption
Permit Limit
PTE Emissions 2
Regulated Pollutant
Emission
Factor 1
Natural Gas
Fuel Usage 2 PTE Emissions 3
1 Emission factors from:
2 lb/hr emissions calculated assuming the ton/yr emissions occur over 8,760 hours in one year.
Attachment 2: PTE Emission Calculations - Natural Gas NOx Emissions page 1 of 1
Attachment 3: BACT Determination
To evaluate the appropriate best available control technology (BACT) for the proposed
burnout oven, the Environmental Protection Agency (EPA)’s Reasonably Available Control
Technology (RACT)-BACT-Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC)
was reviewed. The RBCL provides listings of emission control determinations made by state
and local air pollution control agencies as well as the regional EPA offices and includes control
technologies and/or work practices that may be suitable for each process type code. In addition
to the RBLC, other sources including control equipment vendors, published literature and
previous Utah Division of Air Quality BACT determinations. The following is a list of control
technologies identified.
1) EPA’s RBLC was reviewed and no process-specific control technologies were
identified for the burnout oven.

2) Good Combustion Practices: Includes official documentation and training in
operating and maintenance procedure, including procedures for startup, shutdown
and malfunction; routine inspection and preventative maintenance procedures;
equipment overhaul and include recordkeeping of operating logs and maintenance
records. Good combustion practices reduce emissions of all criteria pollutants.

3) Utah Administrative Code (UAC) R307-401-4(3)‘General Requirements: Low
Oxides of Nitrogen Burner Technology’: R307-401-4(3)(a) requires installation
of low oxides of nitrogen burners or equivalent oxides of nitrogen controls
whenever fuel combustion burners are replaced (unless, approved by the Director,
when such equipment is not physically practical or cost effective). The burnout
oven is equipped with low oxide of nitrogen burners.

 Based on the review of control technologies considered BACT for boilers, Hill AFB has
determined the following meets BACT requirements for the new burnout oven:
1) Low NOX burner technology
2) Operate and maintain in according to the manufacturer’s instructions
3) Good combustion practices
4) Use of pipeline quality natural gas