DAQ-2024-008203

DAQE-AN101210291-24

{{$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: Modification to Approval Order to DAQE-AN101210266-19, to Add Two (2)
Emergency Generator Engines
Project Number: N101210291

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
26, 2023. 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. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TA: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

May 28, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN101210291-24
Modification to Approval Order to DAQE-AN101210266-19 to
Add Two (2) Emergency Generator Engines

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

May 28, 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 .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN101210291-24
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 416588 m Easting
Phone: [phone] 4553000 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
Minor Modification at Major Source

Source Classification
Located in
Davis County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source
DAQE-AN101210291-24
Page 4

Project Description
Hill AFB has requested a modification to AO DAQE-AN101210266-19 to add two (2) large emergency
generator engines and update PTE emissions. The PTE emissions for the four (4) existing permitted large
emergency generator engines have been updated, and the emissions impacted by the update are SOx
(+0.00028 TPY), NOx (+0.000004), CO (+0.0000009), VOC (-0.0083), GHG (-0.0009), and the total
HAPs combined (-0.00477 TPY). All other emissions from the existing four (4) large emergency
generators remain the same. No new requirements were added to the AO for the addition of the two (2)
new emergency generator engines.

Process Description
Hill AFB permits large (greater than 2000 Kw) emergency generator engines in a separate approval order.
All generators below 2000 Kw are permitted under the emergency generator permit. All Hill AFB
operations have combined requirements in the Title V permit. The emissions associated with all
operations have been combined for classification purposes.

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 0.01 0.04
CO2 Equivalent 373 1127.00
Carbon Monoxide 1.67 2.74
Nitrogen Oxides 3.00 8.09
Particulate Matter - PM10 0.1 0.18
Particulate Matter - PM2.5 0.1 0.18
Sulfur Oxides 0.004 0.01
Volatile Organic Compounds 0.09 0.26

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -7.1 7.42
Change (TPY) Total (TPY)
Total HAPs -0.003 0.0037

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]

DAQE-AN101210291-24
Page 5

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Permitted Source
Source-wide

II.A.2 Four (4) Diesel-fired Emergency Generators
Capacity: 2,250 kW (each)
Site-specific capacity: 2,210 kW (each)
AQUIS IDs: 44689, 44690, 44691, 44692

II.A.3 One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,500 kW
Site-specific capacity: 2,301 kW
AQUIS IDs: 45491

II.A.4 One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,000 kW
Site-specific capacity: 1,670 kW
AQUIS IDs: 45495

DAQE-AN101210291-24
Page 6

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a Visible emissions from the six (6) diesel-fired emergency generators shall be no greater than 20
percent opacity, except for a period not exceeding three (3) minutes in any hour. The permittee
shall apply one (1) of the following monitoring techniques to each affected emission unit when in
operation.

A. Monthly visual opacity survey conducted by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If any visible
emissions other than condensed water vapor are observed from an emission
point, an opacity determination of that emission point shall be performed in
accordance with 40 CFR 60, Method 9 within 24 hours of the initial visual
opacity survey or upon start-up if the unit must be shut down for maintenance. If
the unit must be permanently removed from service, no follow-up opacity
determination is required.

B. Quarterly photogrametric opacity observations conducted by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If
an opacity of 15 percent or more is detected by the photogrametric analysis, an
opacity determination of that emission point shall be performed in accordance
with 40 CFR 60, Appendix A, Method 9 within 24 hours of the initial
photogrametric opacity observation or upon startup if the unit must be shut down
for maintenance. If the unit must be permanently removed from service, no
follow-up opacity determination is required.

C. An annual opacity determination performed in accordance with 40 CFR 60,
Appendix A, Method 9.

The monitoring option selected can vary from unit to unit. For example, if
quarterly photogrametric opacity observations are being conducted for a given
unit and the permittee cannot conduct a photogrametric opacity observation in a
quarter that unit operated, an opacity determination conducted in accordance
with the procedures of 40 CFR 60, Appendix A, Method 9 will satisfy the
monitoring requirements of this condition.

[R307-201-3, R307-305, R307-401-8]

II.B.1.a.1 The permittee shall maintain a monthly log of visual opacity surveys, quarterly photogrametric
observations, and/or annual opacity determinations, which include the following information for
each affected emission unit: the date and time of each visual opacity survey, photogrametric
opacity observation, annual opacity determination, the specific monitoring technique used (visual
opacity survey, 40 CFR 60 Appendix A Method 9, or photogrametric observation), and the
result of the opacity monitoring. The records required by this provision and all data required by
40 CFR 60, Appendix A, Method 9 shall be maintained. [R307-401-8]

II.B.1.b The six (6) diesel-fired emergency generator engines shall meet the applicable requirements in
40 CFR 60, Subparts A and IIII, and 40 CFR 63, Subparts A and ZZZZ.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2 Sulfur Fuel Content Requirement
II.B.2.a The permittee shall purchase diesel fuel with a sulfur content no greater than 15 ppm (0.0015
percent) by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

DAQE-AN101210291-24
Page 7

II.B.2.a.1 For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the sulfur content for
Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain documentation
demonstrating compliance with the condition.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN101210266-19 dated May 8, 2019
Is Derived From NOI dated October 26, 2023
Incorporates Additional Information dated November 6, 2023

DAQE-AN101210291-24
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-MN101210291-24

M E M O R A N D U M

To: Site: 10121 – Hill Air Force Base, Main Base

Through: Jon L. Black, Major New Source Review Section Manager, DAQ

From: Tad Anderson, Engineer, Major New Source Review Section, DAQ

Date: May , 2027

Subject: Response to Comments on Intent to Approve DAQE-IN101210291-24

An ITA for Hill Air Force Base (HAFB), Main Base, was proposed with a public comment period from
April 10, 2024, through May 10, 2024. On April 24, 2024, HAFB submitted comments on the proposed
AO [DAQE-IN101210291-24].

The following is the comment that was received from HAFB and DAQ’s response to the comment: A
copy of written the comment documentation is attached to this memorandum as Attachment A.

Comments and Responses

COMMENT #1:

“Hill AFB is submitting this public comment to modify the capacities listed in II.A.3 and II.A.4 of the
equipment list in DAQE-IN101210291-24.

Current ITA Equipment List Correct Equipment List
II.A.3 One (1) Diesel-fired Emergency Generator
(NEW)
Capacity: 2,500 kW
Site-specific capacity: 2,202 kW
AQUIS ID: 45491
One (1) Diesel-fired Emergency Generator
(NEW)
Capacity: 2,500 kW
Site-specific capacity: 2,301 kW
AQUIS ID: 45491
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

JB
DAQE-MN101210291-24
Page 2
II.A.4 One (1) Diesel-fired Emergency Generator
(NEW)
Capacity: 2,181 kW
Site-specific capacity: 2,142 kW
AQUIS ID: 45495
One (1) Diesel-fired Emergency Generator
(NEW)
Capacity: 2,000 kW
Site-specific capacity: 1,670 kW
AQUIS ID: 45495

The above requested changes will result in the following emission reductions:

Pollutant Change in PTE Emissions
lb/hr ton /yr
PM10 -0.01 -6.62E-04
PM2.5 -0.01 -6.62E-04
SOx -5.04E-04 -2.52E-05
NOx -0.41 -0.02
CO -0.23 -0.01
VOC -0.01 -5.72E-04
Lead 0 0
Total HAP -1.68E-04 -8.39E-06
CO2e 0 0
NH3 0 0
“

DAQ Response

UDAQ has reviewed the information submitted during the public comment period and determined that the
updated equipment capacity and emissions do not trigger any additional permit review. The equipment
updates and emissions reduction require the existing engineering review and Intent to Approve (ITA) to
be updated and regenerated. There were no official comments submitted during the public comment
period. Since the additional information submitted by HAFB during the public comment period is a
reduction in emissions, no additional public comment period is needed.

DAQE-MN101210291-24
Page 3
ATTACHMENT A

Comment Letter

DAQE-IN101210291A-24

May 20, 2024

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

Dear Ms. Burton:

Re: Intent to Approve: Modification to Approval Order to DAQE-AN101210266-19, to Add Two (2)
Emergency Generator Engines
Project Number: N101210291

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Tad Anderson, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Tad Anderson, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:TA: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

* ) ' & — 4 A B v A ? A C @ C w @ @ ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN101210291-24
Modification to Approval Order to DAQE -AN101210266-19, to Add
Two (2) Emergency Generator Engines

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

Issued to
Hill Air Force Base - Main Base

Issued On
May 20, 2024

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}

* ) ' & — 4 A B v A ? A C @ C w @ @ ˜

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
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN101210291A-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, Bldg. 383
75 CEG/CEIE
7290 Weiner Street, Bldg. 383
Hill Air Force Base, UT 84056-5003 Hill Air Force Base, UT 84056-5003

Source Contact UTM Coordinates
Name: Erik Dettenmaier 416588 m Easting
Phone: [phone] 4553000 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
Minor Modification at Major Source

Source Classification
Located in
Davis County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source
DAQE-IN101210291A-24
Page 4

Project Description
Hill AFB has requested a modification to AO DAQE-AN101210266-19 to add two (2) large emergency
generator engines and update PTE emissions. The PTE emissions for the four (4) existing permitted large
emergency generator engines have been updated, and the emissions impacted by the update are SOx
(+0.00028 TPY), NOx (+0.000004), CO (+0.0000009), VOC (-0.0083), GHG (-0.0009), and the total
HAPs combined (-0.00477 TPY). All other emissions for the existing four (4) large emergency
generators remain the same. No new requirements were added to the AO for the addition of the two (2)
new emergency generator engines.

Process Description
Hill AFB permits large (greater than 2000 Kw) emergency generator engines in a separate approval order.
All generators below 2000 Kw are permitted in the emergency generator permit. All Hill AFB operations
have combined requirements in the Title V permit. The emissions associated with all operations have
been combined for classification purposes.

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 0.01 0.04
CO2 Equivalent 373 1127.00
Carbon Monoxide 1.67 2.74
Nitrogen Oxides 3.00 8.09
Particulate Matter - PM10 0.1 0.18
Particulate Matter - PM2.5 0.1 0.18
Sulfur Oxides 0.004 0.01
Volatile Organic Compounds -0.09 0.26

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -7.1 7.42
Change (TPY) Total (TPY)
Total HAPs -0.003 0.0037

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Ogden Standard Examiner on April 10, 2024. During the public
comment period the proposal and the evaluation of its impact on air quality will be available for the
DAQE-IN101210291A-24
Page 5

public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

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.

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN101210291A-24
Page 6

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.

II.A THE APPROVED EQUIPMENT

II.A.1 Permitted Source
Source-wide

II.A.2 Four (4) Diesel-fired Emergency Generators
Capacity: 2,250 kW (each)
Site-specific capacity: 2,210 kW (each)
AQUIS IDs: 44689, 44690, 44691, 44692

II.A.3 One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,500 kW
Site-specific capacity: 2,301 kW
AQUIS IDs: 45491

II.A.4 One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,000 kW
Site-specific capacity: 1,670 kW
AQUIS IDs: 45495

DAQE-IN101210291A-24
Page 7

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.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a Visible emissions from the six (6) diesel-fired emergency generators shall be no greater than 20
percent opacity, except for a period not exceeding three (3) minutes in any hour. The permittee
shall apply one (1) of the following monitoring techniques to each affected emission unit when in
operation.

A. Monthly visual opacity survey conducted by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If any visible
emissions other than condensed water vapor are observed from an emission
point, an opacity determination of that emission point shall be performed in
accordance with 40 CFR 60, Method 9, within 24 hours of the initial visual
opacity survey or upon start-up if the unit must be shut down for maintenance.
If the unit must be permanently removed from service, no follow-up opacity
determination is required.

B. Quarterly photogrametric opacity observations conducted by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If
an opacity of 15 percent or more is detected by the photogrametric analysis, an
opacity determination of that emission point shall be performed in accordance
with 40 CFR 60, Appendix A, Method 9 within 24 hours of the initial
photogrametric opacity observation or upon startup if the unit must be shut down
for maintenance. If the unit must be permanently removed from service, no
follow-up opacity determination is required.

C. An annual opacity determination performed in accordance with 40 CFR 60,
Appendix A, Method 9.

The monitoring option selected can vary from unit to unit. For example, if
quarterly photogrametric opacity observations are being conducted for a given
unit and the permittee cannot conduct a photogrametric opacity observation the
quarter that unit operated, an opacity determination conducted in accordance
with the procedures of 40 CFR 60, Appendix A, Method 9 will satisfy the
monitoring requirements of this condition.

[R307-201-3, R307-305, R307-401-8]

II.B.1.a.1 The permittee shall maintain a monthly log of visual opacity surveys, quarterly photogrametric
observations, and/or annual opacity determinations, which include the following information for
each affected emission unit: the date and time of each visual opacity survey, photogrametric
opacity observation, annual opacity determination, the specific monitoring technique used (visual
opacity survey, 40 CFR 60 Appendix A Method 9, or photogrametric observation), and the
result of the opacity monitoring. The records required by this provision and all data required by
40 CFR 60, Appendix A, Method 9 shall be maintained. [R307-401-8]

II.B.1.b The six (6) diesel-fired emergency generator engines shall meet the applicable requirements in
40 CFR 60, Subparts A and IIII, and 40 CFR 63, Subparts A and ZZZZ.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

DAQE-IN101210291A-24
Page 8

II.B.2 Sulfur Fuel Content Requirement
II.B.2.a The permittee shall purchase diesel fuel with a sulfur content no greater than 15 ppm (0.0015
percent) by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2.a.1 For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the sulfur content for
Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain documentation
demonstrating compliance with the condition.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN101210266-19 dated May 8, 2019
Is Derived From NOI dated October 26, 2023
Incorporates Additional Information dated November 6, 2023

DAQE-IN101210291A-24
Page 9

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-IN101210291-24

April 8, 2024

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: Intent to Approve: Modification to Approval Order to DAQE-AN101210266-19, to Add Two (2)
Emergency Generator Engines
Project Number: N101210291

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Tad Anderson, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Tad Anderson, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:TA:jg

cc: Davis County Health Department
DJ Law, 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

* ) ' & — + - G v A ? A C ? G w D E ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN101210291-24
Modification to Approval Order to DAQE -AN101210266-19, to Add
Two (2) Emergency Generator Engines

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

Issued to
Hill Air Force Base - Main Base

Issued On
April 8, 2024

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}

* ) ' & — + - G v A ? A C ? G w D E ˜

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
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN101210291-24
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 416588 m Easting
Phone: [phone] 4553000 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
Minor Modification at Major Source

Source Classification
Located in
Davis County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source
DAQE-IN101210291-24
Page 4

Project Description
Hill AFB has requested a modification to AO DAQE-AN101210266-19 to add two (2) large emergency
generator engines and update PTE emissions. The PTE emissions for the four (4) existing permitted large
emergency generator engines have been updated, and the emissions impacted by the update are SOx
(+0.00028 TPY), NOx (+0.000004), CO (+0.0000009), VOC (-0.0083), GHG (-0.0009), and the total
HAPs combined (-0.00477 TPY). All other emissions from the existing four (4) large emergency
generators remain the same. No new requirements were added to the AO for the addition of the two (2)
new emergency generator engines.

Process Description
Hill AFB permits large (greater than 2000 Kw) emergency generator engines in a separate approval order.
All generators below 2000 Kw are permitted under the emergency generator permit. All Hill AFB
operations have combined requirements in the Title V permit. The emissions associated with all
operations have been combined for classification purposes.

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 0.01 0.04
CO2 Equivalent 373 1127.00
Carbon Monoxide 1.67 2.74
Nitrogen Oxides 3.00 8.09
Particulate Matter - PM10 0.1 0.18
Particulate Matter - PM2.5 0.1 0.18
Sulfur Oxides 0.004 0.01
Volatile Organic Compounds 0.09 0.26

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -7.1 7.42
Change (TPY) Total (TPY)
Total HAPs -0.003 0.0037

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Ogden Standard Examiner on April 10, 2024. During the public
comment period the proposal and the evaluation of its impact on air quality will be available for the
public to review and provide comment. If anyone so requests a public hearing within 15 days of
DAQE-IN101210291-24
Page 5

publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

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.

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN101210291-24
Page 6

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.

II.A THE APPROVED EQUIPMENT

II.A.1 Permitted Source
Source-wide

II.A.2 Four (4) Diesel-fired Emergency Generators
Capacity: 2,250 kW (each)
Site-specific capacity: 2,210 kW (each)
AQUIS IDs: 44689, 44690, 44691, 44692

II.A.3 One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,500 kW
Site-specific capacity: 2,202 kW
AQUIS IDs: 45491

II.A.4 One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,181 kW
Site-specific capacity: 2,142 kW
AQUIS IDs: 45495

DAQE-IN101210291-24
Page 7

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.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a Visible emissions from the six (6) diesel-fired emergency generators shall be no greater than 20
percent opacity, except for a period not exceeding three (3) minutes in any hour. The permittee
shall apply one (1) of the following monitoring techniques to each affected emission unit when in
operation.

A. Monthly visual opacity survey conducted by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If any visible
emissions other than condensed water vapor are observed from an emission
point, an opacity determination of that emission point shall be performed in
accordance with 40 CFR 60, Method 9 within 24 hours of the initial visual
opacity survey or upon start-up if the unit must be shut down for maintenance.
If the unit must be permanently removed from service, no follow-up opacity
determination is required.

B. Quarterly photogrametric opacity observations conducted by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If
an opacity of 15 percent or more is detected by the photogrametric analysis, an
opacity determination of that emission point shall be performed in accordance
with 40 CFR 60, Appendix A, Method 9 within 24 hours of the initial
photogrametric opacity observation or upon startup if the unit must be shut down
for maintenance. If the unit must be permanently removed from service, no
follow-up opacity determination is required.

C. An annual opacity determination performed in accordance with 40 CFR 60,
Appendix A, Method 9.

The monitoring option selected can vary from unit to unit. For example, if
quarterly photogrametric opacity observations are being conducted for a given
unit and the permittee cannot conduct a photogrametric opacity observation in a
quarter that unit operated, an opacity determination conducted in accordance
with the procedures of 40 CFR 60, Appendix A, Method 9 will satisfy the
monitoring requirements of this condition.

[R307-201-3, R307-305, R307-401-8]

II.B.1.a.1 The permittee shall maintain a monthly log of visual opacity surveys, quarterly photogrametric
observations, and/or annual opacity determinations, which include the following information for
each affected emission unit: the date and time of each visual opacity survey, photogrametric
opacity observation, annual opacity determination, the specific monitoring technique used (visual
opacity survey, 40 CFR 60 Appendix A Method 9, or photogrametric observation), and the result
of the opacity monitoring. The records required by this provision and all data required by 40
CFR 60, Appendix A, Method 9 shall be maintained. [R307-401-8]

II.B.1.b The six (6) diesel-fired emergency generator engines shall meet the applicable requirements in
40 CFR 60, Subparts A and IIII, and 40 CFR 63, Subparts A and ZZZZ.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

DAQE-IN101210291-24
Page 8

II.B.2 Sulfur Fuel Content Requirement
II.B.2.a The permittee shall purchase diesel fuel with a sulfur content no greater than 15 ppm (0.0015
percent) by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2.a.1 For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the sulfur content for
Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain documentation
demonstrating compliance with the condition.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN101210266-19 dated May 8, 2019
Is Derived From NOI dated October 26, 2023
Incorporates Additional Information dated November 6, 2023

DAQE-IN101210291-24
Page 9

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-NN101210291-24

April 8, 2024

Ogden Standard Examiner
Legal Advertising Dept.
Standard Way
P.O. Box 12790332
Ogden, UT 84412

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard
Examiner (Account Number: 100331) on April 10, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council
cc: Davis County

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

DAQE-NN101210291-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Hill Air Force Base
Location: Hill Air Force Base - Main Base – 75 CEG/CEIE, 7290 Weiner Street, Building
383, Hill Air Force Base, UT
Project 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 has requested a modification to
Approval Order DAQE-AN101210266-19, to add two (2) large emergency
generator engines.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before May 10, 2024 will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: April 10, 2024

{{#s=Sig_es_:signer1:signature}}

4/11/24, 11:22 AM utahlegals.com/(S(mwuuvwhoafczu2kxq5ozyevq))/DetailsPrint.aspx?SID=mwuuvwhoafczu2kxq5ozyevq&ID=182361
https://www.utahlegals.com/(S(mwuuvwhoafczu2kxq5ozyevq))/DetailsPrint.aspx?SID=mwuuvwhoafczu2kxq5ozyevq&ID=182361 1/1
Standard Examiner
Publication Name:
Standard Examiner
Publication URL:
www.standard.net
Publication City and State:
Ogden, UT
Publication County:
Weber
Notice Popular Keyword Category:
Notice Keywords:
hill
Notice Authentication Number:
202404111222128778253
1761527914
Notice URL:
Back
Notice Publish Date:
Wednesday, April 10, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Hill Air Force Base Location: Hill Air Force Base - Main Base - 75 CEG/CEIE, 7290
Weiner Street, Building 383, Hill Air Force Base, UT Project 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 has requested a modification to Approval Order DAQE-AN101210266-19, to add two
(2) large emergency generator engines. The completed engineering evaluation and air quality impact analysis showed the proposed project
meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order
pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are
available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written
comments received by the Division at this same address on or before May 10, 2024 will be considered in making the final decision on the
approval/disapproval of the proposed project. Email comments will also be accepted at [e-mail]. If anyone so requests to the
Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-
1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was
raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully
consider the substance and significance of the issue. Date of Notice: April 10, 2024 Legal Notice 12735 Published in the Standard Examiner
on April 10, 2024
Back
DAQE-

RN101210291
April 2, 2024

Amanda Burton
Hill Air Force Base
75 CEG/CEIE
7290 Weiner Street
Bldg 383
Hill Air Force Base, UT 840565003
[e-mail]

Dear Amanda Burton,

Re: Engineer Review:
Modification to Approval Order to DAQE-AN101210266-19, to Add Two Emergency Generator
Engines
Project Number: N101210291

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 Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the DAQ
will consider any comments received and will issue the Approval Order.

If you do 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 N101210291: Hill Air Force Base- Main Base
April 2, 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 N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 2

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N101210291
Owner Name Hill Air Force Base
Mailing Address 75 CEG/CEIE
7290 Weiner Street
Bldg 383
Hill Air Force Base, UT, 840565003

Source Name Hill Air Force Base- Main Base
Source Location 75 CEG/CEIE
7290 Weiner Street
Hill Air Force Base, UT 84056-5003

UTM Projection 416588 m Easting, 4553000 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 October 26, 2023
Date of Accepted Application January 23, 2024

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 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:
Minor Modification at Major Source

Source Classification
Located in, Davis County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source

Project Proposal
Modification to Approval Order to DAQE-AN101210266-19, to Add Two Emergency Generator
Engines

Project Description
Project Description
Hill AFB has requested a modification to AO DAQE-AN101210266-19, to add two large
emergency generator engines and updated PTE emissions. The PTE emissions for the four
existing permitted large emergency generator engines have been updated and the emissions
impacted by the update are the SOx (+0.00028 TPY), NOx (+0.000004), CO (+0.0000009), VOC
(-0.0083), GHG (-0.0009) and the total HAPs combined (-0.00477 TPY). All other emissions for
the existing 4 large emergency generators remain the same. No new requirements were added to
the AO for the addition of the two new emergency generators engines.

Process Description
Hill Air Force Base (Hill AFB) permits large (greater than 2000 Kw) emergency generator
engines in a separate approval order. All generators below 2000 Kw are permitted in the
emergency generator permit. All Hill AFB operations have combined requirements in the Title V
permit. The emissions associated with all operations have been combined for classification
purposes.

EMISSION IMPACT ANALYSIS
This permit change does not trigger Impact Analysis in UAC R307-410-4 or R307-410-5. The emissions
increase for the addition of the two large emergency compressor engines is as follows; +0.1 TPY of PM10/2.5,
+3.0 TPY of NOx, +1.67 TPY of CO, +0.00367 TPY of SOx, +0.08 TPY of VOC, 373 TPY of CO2e, and
+0.00122 TPY of combined HAPs. NO2 modeling was conducted and documented in DAQE-MN101210291-

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 4
24, with the results being below the 1 hours NO2 standard. [Last updated April 1, 2024]

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 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 0.01 0.04
CO2 Equivalent 373 1127.00
Carbon Monoxide 1.67 2.74
Nitrogen Oxides 3.00 8.09
Particulate Matter - PM10 0.1 0.18
Particulate Matter - PM2.5 0.1 0.18
Sulfur Oxides 0.004 0.01
Volatile Organic Compounds 0.09 0.26

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -7.1 7.42
Change (TPY) Total (TPY)
Total HAPs -0.003 0.0037

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 6
Review of BACT for New/Modified Emission Units

1. BACT review regarding Emergency Generator Engines
BACT was conducted for emergency generator engine larger (rating of 1,750 to 2,500 kW)by
reviewing the RBLC. The following technologies were specified in the analysis: good combustion
practices, maintenance and operating practices, use of low-sulfur diesel fuel, compliance with
applicable NSPS IIII requirements, compliance with applicable NESHAP ZZZZ requirements and
the use of SCR. All of the listed control technologies are technically feasible, except for SCR. For
SCR systems to function effectively, exhaust temperatures must be 200°C to 500°C to
enable catalyst activation. SCR control efficiencies are low during the first 20 to 30 minutes after
engine start up during maintenance and testing. There are also complications controlling the
excess ammonia during the engine startup during maintenance and testing. from SCR use. SCR is
not considered technically feasible for emergency units.

BACT for diesel-fired emergency engines, is the following:

Good combustion, maintenance, and operating practices
Use of low-sulfur diesel fuel
Compliance with applicable NSPS IIII requirements
Use of a tier certified engine
Limit on hours of operation for maintenance and testing operations
Compliance with applicable NESHAP ZZZZ requirements

[Last updated January 25, 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]

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 7
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]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

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 Permitted Source
Source-wide

II.A.2 Four (4) Diesel-fired Emergency Generators
Capacity: 2,250 kW (each)
Site-specific capacity: 2,210 kW (each)
AQUIS IDs: 44689, 44690, 44691, 44692

II.A.3
NEW
One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,500 kW
Site-specific capacity: 2,202 kW
AQUIS IDs: 45491

II.A.4
NEW
One (1) Diesel-fired Emergency Generator (NEW)
Capacity: 2,181 kW
Site-specific capacity: 2,142 kW
AQUIS IDs: 45495

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 8
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):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a
NEW
Visible emissions from the six (6) diesel-fired emergency generators shall be no greater than
20 percent opacity except for a period not exceeding 3 minutes in any hour. The permittee
shall apply one of the following monitoring techniques to each affected emission unit when in
operation.

A. Monthly visual opacity survey conducted by an individual trained on the observation
procedures of 40 CFR 60, Appendix A, Method 9. If any visible emissions other than
condensed water vapor are observed from an emission point, an opacity determination of that
emission point shall be performed in accordance with 40 CFR 60, Method 9 within 24 hours
of the initial visual opacity survey or upon start-up if the unit must be shut down for
maintenance. If the unit must be permanently removed from service, no follow-up opacity
determination is required.

B. Quarterly photogrametric opacity observations conducted by an individual trained on
the observation procedures of 40 CFR 60, Appendix A, Method 9. If an opacity of 15 percent
or more is detected by the photogrametric analysis, an opacity determination of that emission
point shall be performed in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial photogrametric opacity observation or upon startup if the unit must be
shutdown for maintenance. If the unit must be permanently removed from service, no follow-
up opacity determination is required.

C. An annual opacity determination performed in accordance with 40 CFR 60, Appendix
A, Method 9.

The monitoring option selected can vary from unit to unit. For example, if quarterly
photogrametric opacity observations are being conducted for a given unit and the permittee
cannot conduct a photogrametric opacity observation in a quarter that unit operated, an opacity
determination conducted in accordance with the procedures of 40 CFR 60, Appendix A,
Method 9 will satisfy the monitoring requirements of this condition. [R307-201-3, R307-305,
R307-401-8]

II.B.1.a.1 The permittee shall maintain a monthly log of visual opacity surveys, quarterly
photogrametric observations, and/or annual opacity determinations which include the
following information for each affected emission unit: the date and time of each visual opacity
survey, photogrametric opacity observation, annual opacity determination, the specific
monitoring technique used (visual opacity survey, 40 CFR 60 Appendix A Method 9,or
photogrametric observation), and the result of the opacity monitoring. The records required by
this provision and all data required by 40 CFR 60, Appendix A, Method 9 shall be maintained.
[R307-401-8]

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 9
II.B.1.b The six diesel-fired emergency generator engines shall meet the applicable requirements in 40
CFR 60, Subparts A and IIII, and 40 CFR 63, Subparts A and ZZZZ. [40 CFR 60 Subpart IIII,
40 CFR 63 Subpart ZZZZ]

II.B.2 Sulfur Fuel Content Requirement
II.B.2.a The permittee shall purchase diesel fuel with a sulfur content no greater than 15 ppm (0.0015
percent) by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2.a.1 For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the sulfur content for
Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain documentation
demonstrating compliance with the condition. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart
ZZZZ]

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 2024
Page 10
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 October 26, 2023
Supersedes DAQE-AN101210266-19 dated September 4, 2019
Incorporates Additional Information dated November 6, 2023

REVIEWER COMMENTS

1. 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)
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 January
23, 2024]

2. Comment regarding Emissions Estimates:
The PTE emissions estimates were generated using the manufactures emissions factors for PM10/2.5,
NOx, CO and VOC emissions. The SOx emissions were generated using Air Force guidance (Air
Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC],
August 2018, Section 3). The CO2e calculated used table A-1 "Global Warming Potentials" from 40
Code of Federal Regulations (CFR) Part 98. [Last updated January 25, 2024]

3. Comment regarding SIP Listed Source:
The PTE emissions estimates were generated using the manufactures emissions factors for PM10/2.5,
NOx, CO and VOC emissions. The SOx emissions were generated using Air Force guidance (Air
Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC],
August 2018, Section 3). The CO2e calculated used table A-1 "Global Warming Potentials" from 40
Code of Federal Regulations (CFR) Part 98. [Last updated January 23, 2024]

4. 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" but is subject to 40 CFR 60 Subpart IIII and 40 CFR
63 Subpart ZZZZ. [Last updated January 23, 2024]

Engineer Review N101210291: Hill Air Force Base- Main Base
April 2, 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-MN101210291-24

M E M O R A N D U M

TO: Tad Anderson, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler

DATE: March 28, 2024

SUBJECT: Modeling Analysis Review for the Notice of Intent for Hill Air Force Base – Main Base,
Davis County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Hill Air Force Base (Applicant) is seeking an approval order for the Main Base located in Davis
County, Utah. Hill AFB has requested a modification to AO DAQE-AN101210266-19, to add two
large emergency generator engines and updated PTE emissions.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

III. MODELING METHODOLOGY

A. Applicability

Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a
modified approval order. The emission rates for NOx triggered the requirement to model under
R307-410. Modeling was performed by the UDAQ.

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

JK
DAQE- MN101210291-24
Page 2
B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4780 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12

b. Approximate Location:

UTM (NAD83): 416588 meters East
4553000 meters North

2. Urban or Rural Area Designation

After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is
“rural” for air modeling purposes.

3. Ambient Air

It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash

The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Syracuse, UT NWS: 2005 - 2009
Upper Air – Salt Lake Airport, UT NWS: 2005 - 2009

6. Background

The background concentrations were based on concentrations measured in Harrisville,
Utah.

7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.

DAQE- MN101210291-24
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Hill Air Force Base – Main Base
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
MIF1 414907 4553862 30.42 1.52 100
SSC1 415022 4554037 29.58 1.48 100
EGEN1 414848 4552574 25.43 1.27 100
EGEN2 414842 4552571 25.43 1.27 100
EGEN3 414853 4552578 25.43 1.27 100
EGEN4 414837 4552567 25.43 1.27 100
SHREDR 415247 4555100 3.09 13.53 8760

Total 164.81 21.62
Holcim – Devil’s Slide
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
KILN_NAQ 455467 4545816 541.10 2370.00 8760
KILN_PSD 455467 4545816 0.00 0.00 8760

Total 541.10 2370.00
Wasatch Integrated Waste Management District -Davis Landfill
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
TEHOGEN 421544 4552075 2.46 10.77 8760
GENSET 422049 4551561 2.31 0.12 100
FLARE 421538 4552017 0.98 4.29 8760

Total 5.75 15.18

DAQE- MN101210291-24
Page 4

10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (ft)
MIF1 POINT 4674.2 5.1 16.8 764 45.59 0.51
SSC1 POINT 4693.7 5.6 18.3 799 91.23 1.17
EGEN1 POINT 4615.0 5.1 16.8 753 89.42 0.41
EGEN2 POINT 4615.0 5.1 16.8 753 89.42 0.41
EGEN3 POINT 4615.0 5.1 16.8 753 89.42 0.41
EGEN4 POINT 4615.0 5.1 16.8 753 89.42 0.41
SHREDR POINT 4743.0 3.6 11.7 735 68.15 0.15
KILN_NAQ POINT 5262.5 88.4 289.9 400 17.53 3.48
KILN_PSD POINT 5262.5 88.4 289.9 400 17.53 3.48
TEHOGEN POINT 4933.1 7.0 23.0 754 35.86 0.46
GENSET POINT 4911.0 2.4 7.7 922 50.07 0.09
FLARE POINT 4921.5 12.2 40.0 1144 0.12 2.44

IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the
NAAQS. The predicted total concentrations are less than the NAAQS.

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2
1-
Hour 63.2 7.5 37.3 4.3 104.8 188 55.7%

JK:jg

DEPARTMENT OF THE AIR FORCE
75TH CIVIL ENGINEER GROUP (AFMC)
HILL AIR FORCE BASE UTAH

6 November 2023

Amanda Burton
Chief, Environmental Branch
75 CEG/CEIE
7290 Weiner Road
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 addendum to the notice of intent (NOI) submitted on 26 Oct
23 to modify approval order (AO) DAQE-AN101210266-19. This addendum is for the addition of a second
emergency generator. A redline of DAQE-AN101210266-19 with the requested changes in the original NOI
(addition of one emergency generator and updates to the potential to emit [PTE] emissions for the four generators in
the AO) and this addendum is included as Attachment 1. The two new generators will have the following
specifications:

Equipment type: compression ignition internal combustion engine
Power type: emergency
Manufacturer: Caterpillar
Model: 3516C
Fuel: diesel
Engine rating: 2,500 kW
Engine site-specific rating: 2,202 kW
Manufacturer year: 2021
Tier rating: 2
Quantity: 1
AQUIS ID: 45491

Equipment type: compression ignition internal combustion engine
Power type: emergency
Manufacturer: Mitsubishi
Model: S16R-Y2PTAW2-1
Fuel: diesel
Engine rating: 2,181 kW
Engine site-specific rating: 2,142 kW
Manufacturer year: 2023
Tier rating: 2
Quantity: 1
AQUIS ID: 45495

The PTE emissions were calculated using manufacturer data; Air Force guidance documents; 40 Code of
Federal Regulations (CFR) Part 98, Mandatory Greenhouse Gas Reporting, Subpart C; Environmental Protection
Agency (EPA) guidance documents; and EPA AP-42. Detailed emission calculations for the two new generators
and the recalculated PTE emissions for the four generators in the AO are provided in Attachment 2. PTE emissions
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 1.75 0.09 1.93 0.10 3.68 0.18
PM2.5 1.75 0.09 1.93 0.10 3.68 0.18
SOX 0.14 7.19E-03 0.08 3.95E-03 0.22 0.01
NOX 102 5.09 60.0 3.00 162 8.09
CO 21.4 1.07 33.4 1.67 54.8 2.74
VOC 3.51 0.18 1.67 0.09 5.17 0.26
HAPs 0.13 7.26E-03 -0.06 -3.55E-03 0.07 3.71E-03
Ammonia 0.53 0.03 0.26 0.01 0.80 0.04
Lead 0 0 0 0 0 0
Total CO2e 15,092 755 7,458 373 22,549 1,127
1 Speciated HAP emissions are included in the attached emission calculations.

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 emission increases are below the applicable thresholds provided in UAC R307-
410-4. Pursuant to R307-410-5(1)(c), a screening analysis was conducted for HAP emissions. From the analysis, it
was determined the proposed HAP emission increases from the two new emergency generators were below the
respective emission threshold values based upon the applicable threshold limit value – time weighted average.

The engines are subject to New Source Performance Standards Subpart IIII, ‘Standards of Performance for
Stationary Compression Ignition Internal Combustion Engines’ and are also affected sources under National
Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart ZZZZ, ‘Stationary Reciprocating Internal
Combustion Engines’, but there are no applicable emission limits under the NESHAP. The units will comply with
all applicable requirements of the Hill AFB Main Base Title V Operating Permit (TVOP) Conditions II.B.43, II.B.44
and II.B.48. Best available control technology (BACT) for internal combustion engines is provided in TVOP
Conditions II.B.43, II.B.44 and II.B.48 and a BACT determination is included as Attachment 3.

Hill AFB requests the enhanced new source review process for this AO so the Main Base Title V Operating
Permit can be modified administratively. 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
11/6/2023
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-AN101210266-19
2. PTE Emission Calculations
3. BACT Determination
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

APPROVAL ORDER: Administrative
AmendmentModification to Large Emergency Generators
Approval Order,
DAQE-AN1012102566-198, to Update
Opacity Monitoring LanguageAdd Two
Emergency Generators and Update PTE
Emissions for the Emergency Generators
Already Listed in the Permit

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

APPROVAL ORDER NUMBER
DAQE-AN101210266TBD-2319
Date: May 8, 2019TBD

Hill Air Force Base
Main Base
Source Contact:
Erik Dettenmaier
Phone: [phone]
Email: [e-mail]
Signed by Bryce C. Bird on TBDMay 8,
2019 Bryce C. BirdBD
Director
Abstract
Hill Air Force Base (Hill AFB) has requested an administrative amendment modification to the Large
Emergency Generator AO DAQE-AN10121026656-198, to add two emergency generators and update emission
calculations for the four emergency generators already listed in the permit due to a change in emission
calculation methodology.update opacity monitoring language with the language for limited use power supply
units in the Title V Operating Permit. Hill AFB is also requesting removal of the 30,000 gallon diesel tank
from this permit. The tank has been incorporated into the fuel tanks permit DAQE-AN101210260-19. This
permit action is an administrative correction and is not adding equipment or increasing emissions. The
following are the PTE emission changes (in TPY) resulting from the changes requested in this permit
modification: 0.10 of PM10, 0.10 of PM2.5 (Subset of PM10), 3.00 of NOX, 1.67 of CO, 0.004 of SOX, 0.09 of
VOC, 373 of CO2e, and -0.004 of combined HAPs The following are the estimated PTE emissions (in TPY) for
the processes in this AO: 0.18 of PM10, 0.18 of PM2.5 (Subset of PM10), 8.09 of NOX, 2.74 of CO, 0.01 of SOX,
0.26 of VOC, 1,127 of CO2e, and 0.004 of combined HAPs

Hill AFB is subject to 40 CFR 63 Subpart GG, NESHAP for Aerospace Manufacturing and Rework
Facilities, but the generators in this AO are not subject to this regulation. The engines are subject to
NSPS 40 CFR 60 Subpart A and IIII (Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines) and are also subject to NESHAP 40 CFR 63 Subpart A and ZZZZ
(National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines). Hill AFB is classified as a major source of air pollution and is subject to the
Operating Permit Program. Hill AFB is a PM2.5 SIP-listed source, a major source for VOCs, GHGs,
PM10, PM2.5, HAPs and CO2e. Hill AFB is a PSD source for NOX and CO. Hill AFB is located in Davis
and Weber Counties, which are nonattainment for PM2.5 and ozone and attainment area for all other
criteria pollutants. The Title V permit will be administratively amended to incorporate the conditions of
this AO.
The following are the estimated PTE emissions (in TPY): 0.09 of PM10, 0.09 of PM2.5 (Subset of PM10),
5.09 of NOX, 1.07 of CO, 0.007 of SOX, 0.18 of VOC, 755 of CO2e, and 0.006 of combined HAPs.

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/CEIEA
7290 Weiner Street, Bldg. 383
Hill Air Force Base, UT 84056-
5236003
Permitted Location:
Main Base
75 CEG/CEIEA
7290 Weiner Street
Hill Air Force Base, UT 84056-5136003

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-AN1012102TBD66-TBD19
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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from AO DAQE-AN101210256TBD-TBD18 dated
TBDSeptember 4, 2018. This AO may become invalid if construction is not commenced
within 18 months from the AO dated TBDSeptember 4, 2018, or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Permitted Source
Source-wide
II.A.2 Four (4) Diesel-fired Emergency Generators
Capacity: 2,250 kW (each)
Site-specific capacity: 2,210 kW (each)
AQUIS IDs: 44689, 44690, 44691, 44692

II.A.3 One (1) Diesel-fired Emergency Generator
Capacity: 2,500 kW
Site-specific capacity: 2,202 kW
AQUIS IDs: 45491

II.A.4 One (1) Diesel-fired Emergency Generator
Capacity: 2,181 kW
Site-specific capacity: 2,142 kW
AQUIS IDs: 45495

II.B Requirements and Limitations
II.B.1 Site-wide Requirements

II.B.1.a Visible emissions from the sixfour (64) diesel-fired emergency generators shall be no greater
than 20% opacity except for a period not exceeding three (3) minutes in any hour. The
permittee shall apply one (1) of the following monitoring techniques to each affected emission
unit when in operation.

A. Monthly visual opacity survey conducted by an individual trained on the observation
procedures of 40 CFR 60, Appendix A, Method 9. If any visible emissions other than
condensed water vapor are observed from an emission point, an opacity determination
of that emission point shall be performed in accordance with 40 CFR 60, Method 9
within 24 hours of the initial visual opacity survey or upon start-up if the unit must be
DAQE-AN1012102TBD66-TBD19
Page 4

shut down for maintenance. If the unit must be permanently removed from service, no
follow-up opacity determination is required.

B. Quarterly photogrametric opacity observations conducted by an individual trained on
the observation procedures of 40 CFR 60, Appendix A, Method 9. If an opacity of
15% or more is detected by the photogrametric analysis, an opacity determination of
that emission point shall be performed in accordance with 40 CFR 60, Appendix A,
DAQE-AN1012102TBD66-TBD19
Page 5

Method 9 within 24 hours of the initial photogrametric opacity observation or upon
start-up if the unit must be shut down for maintenance. If the unit must be
permanently removed from service, no follow-up opacity determination is required.

C. An annual opacity determination performed in accordance with 40 CFR 60, Appendix
A, Method 9.

The monitoring option selected can vary from unit to unit. For example, if quarterly
photogrametric opacity observations are being conducted for a given unit and the permittee
cannot conduct a photogrametric opacity observation in a quarter that unit operated, an opacity
determination conducted in accordance with the procedures of 40 CFR 60, Appendix A,
Method 9 will satisfy the monitoring requirements of this condition.
[R307-201-3, R307-305, R307-401-8]

II.B.1.a.1 The permittee shall maintain a monthly log of visual opacity surveys, quarterly photogrametric
observations, and/or annual opacity determinations which include the following information
for each affected emission unit: the date and time of each visual opacity survey,
photogrametric opacity observation, annual opacity determination, the specific monitoring
technique used (visual opacity survey, 40 CFR 60 Appendix A Method 9, or photogrametric
observation), and the result of the opacity monitoring. The records required by this provision
and all data required by 40 CFR 60, Appendix A, Method 9 shall be maintained.
[R307-401-8]

II.B.1.b The sixfour (64) diesel-fired emergency generator engines shall meet the applicable
requirements in 40 CFR 60, Subparts A and IIII, and 40 CFR 63, Subparts A and ZZZZ.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]
II.B.2 Sulfur Fuel Content Requirement

II.B.2.a The permittee shall purchase diesel fuel with a sulfur content no greater than 15 ppm
(0.0015%) by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2.a.1 For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the sulfur content for
Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain documentation
demonstrating compliance with the condition. [40 CFR 60 Subpart IIII,
40 CFR 63 Subpart ZZZZ]
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.
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source
DAQE-AN1012102TBD66-TBD19
Page 6

PERMIT HISTORY

This AO is based on the following documents:
Is Derived From NOI dated October 26, 2023December 20, 2018
NOI addendum dated November 2023
Supersedes AO DAQE-AN10121026656-198 dated September 4, 201918
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, PM2.5 Serious Area SIP,
Major Criteria Source, NSPS (Part 60), MACT (Part 63)
DAQE-AN1012102TBD66-TBD19
Page 7

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
lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr
PM10 1.75 0.09 1.75 0.09 1.93 0.10 1.93 0.10 3.68 0.18
PM2.5 1.75 0.09 1.75 0.09 1.93 0.10 1.93 0.10 3.68 0.18
SOX 0.14 7.19E-03 0.15 7.47E-03 0.07 3.67E-03 0.08 3.95E-03 0.22 0.01
NOX 102 5.09 102 5.09 60.0 3.00 60.0 3.00 162 8.09
CO 21.4 1.07 21.4 1.07 33.4 1.67 33.4 1.67 54.8 2.74
VOC 3.51 0.18 3.51 0.18 1.67 0.08 1.67 0.09 5.17 0.26
Lead 0 0 0 0 0 0 0 0 0 0
Total HAP 0.13 7.26E-03 0.05 2.49E-03 0.02 1.22E-03 -0.06 -3.55E-03 0.07 3.71E-03
GHG (CO2e) 4 15,092 755 15,092 755 7,458 373 7,458 373 22,549 1,127
NH3 0.53 0.03 0.53 0.03 0.26 0.01 0.26 0.01 0.80 0.04
Change in PTE Emissions 2 AO Recalculated
PTE Emissions 1
New Generators
PTE Emissions
New AO
PTE Emissions 3Pollutant
AO Current PTE
Emissions
1 The PTE emissions for the four emergency generators listed in approval order DAQE-AN101210266-19 were recalculated due to a change in Hill AFB generator PTE
emission calculation methodology which occurred after the issuance of DAQE-AN101210266-19. Per Air Force Guidance, emission factors from the Air Emissions Guide for
Air Force Stationary Sources are used to calculate emissions for emergency generators. The change in calculation methodology only impacts the SOX and HAP emissions for
the four generators.
2 The change in PTE emissions is the difference between the PTE emissions listed in AQE-AN101210266-19 and the AO Recalculated PTE emissions and the addition of the
PTE emissions from the new emergency generators.
[(AO current PTE emissions) - (AO recalculated PTE emissions) + (new emergency generators PTE emissions)]
3 The new AO PTE emissions is the sum of the AO Recalculated PTE emissions and the PTE emissions from the new emergency generators.
[(AO recalculated PTE emissions) + (new emergency generators PTE emissions)]
4 CO2e calculated using Table A-1 'Global Warming Potentials' from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas pollutant (CO2,
CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Attachment 2: PTE  Emission Calculations page 1 of 11
Criteria Pollutant and Greenhouse Gas Emission Recalculations - Four Emergency Generators
The generators are EPA Tier 2 compliant, consistent with NSPS Subpart IIII requirements
Number of units 4
Fuel consumption rate 167 gal/hr - per manufacturer technical data sheets
668 gal/hr - four generators
Engine rating 2,250 kW
2,210 kW (derated for altitude)
8,840 kW - four generators (derated for altitude)
Maximum horsepower rating: 2,964 hp - per generator (derated for altitude)
11,855 hp - four generators (derated for altitude)
Hours of
Operation
g/kW-hr lb/hp-hr kg/MMBtu lb/1,000 gal hr/yr/engine lb/hr ton/yr
NOX 5.22 100 102 5.09
VOC 0.18 100 3.51 0.18
CO 1.10 100 21.4 1.07
SOX 1.26E-05 100 0.15 7.47E-03
PM10 0.09 100 1.75 0.09
PM2.5 0.09 100 1.75 0.09
CO2 73.96 100 15,040 752
CH4 3.00E-03 100 0.61 0.03
N2O 6.00E-04 100 0.12 6.10E-03
NH3 0.80 100 0.53 0.03
CO2e 15,092 755
Notes:
Pollutant Emission Factors PTE Emissions
- SOX emission factor calculated per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC],
August 2018, Section 3), using the following equation. Emission factor calculated in units of lb/MMBtu and converted to lb/hp-hr using an average Brake-
Specific Fuel Consumption (BSFC) of 8089 Btu/hp-hr.
- Emission factors for PM10, PM2.5, NOX, CO and VOC and are from manufacturer. Engine is certified NSPS Subpart IIII Tier 2 compliant. The NSPS
incorporates EPA Tier 2 requirements of 40 CFR 89.112, Table 1. The particulate emission factor is for total PM. PM 10 and PM2.5 are subsets of total PM.
Assumed all PM is PM10 and all PM10 is PM2.5.
- Annual hours of operation based on 100 hours for non-emergency use per generator.
Attachment 2: PTE  Emission Calculations page 2 of 11
HAP Emission Calculations
lb/MMBtu lb/hp-hr lb/hr ton/yr
Acenaphthene 83-32-9
4.68E-06 1.25E-08 1.48E-04 7.41E-06
Acenaphthylene 208-96-8 9.23E-06 2.46E-08 2.92E-04 1.46E-05
Acetaldehyde 75-07-0
2.52E-05 6.72E-08 7.97E-04 3.98E-05
Acrolein 107-02-8 7.88E-06 2.10E-08 2.49E-04 1.24E-05
Anthracene 120-12-7 1.23E-06 3.28E-09 3.89E-05 1.94E-06
Benzo(a)anthracene 56-55-3
6.22E-07 1.66E-09 1.97E-05 9.84E-07
Benzene 71-43-2 7.76E-04 2.07E-06 0.02 1.23E-03
Benzo(a)pyrene 50-32-8
2.57E-07 6.85E-10 8.12E-06 4.06E-07
Benzo(b)fluoranthene 205-99-2 1.11E-06 2.96E-09 3.51E-05 1.75E-06
Benzo(g,h,l)perylene 191-24-2
5.56E-07 1.48E-09 1.75E-05 8.77E-07
Benzo(k)fluoranthene 207-08-9 2.18E-07 5.81E-10 6.89E-06 3.44E-07
Chrysene 218-01-9
1.53E-06 4.08E-09 4.84E-05 2.42E-06
Dibenz(a,h)anthracene 53-70-3 3.46E-07 9.22E-10 1.09E-05 5.46E-07
Fluoranthene 206-44-0
4.03E-06 1.07E-08 1.27E-04 6.34E-06
Fluorene 7782-41-4 1.28E-05 3.41E-08 4.04E-04 2.02E-05
Formaldehyde 50-00-0
7.89E-05 2.10E-07 2.49E-03 1.24E-04
Indeno(1,2,3-cd)pyrene 193-39-5 4.14E-07 1.10E-09 1.30E-05 6.52E-07
Naphthalene 91-20-3
1.30E-04 3.47E-07 4.11E-03 2.06E-04
Phenanthrene 85-01-8 4.08E-05 1.09E-07 1.29E-03 6.46E-05
Pyrene 129-00-0
3.71E-06 9.89E-09 1.17E-04 5.86E-06
S x 0.02 x D x (1/HV)
where,
- S = weight percent sulfur content of the fuel (0.0015%).
- 0.02 = conversion factor converting the weight percent to a weight fraction multiplied by the ratio of the molecular weight of SO 2 to the molecular weight
of sulfur.
- D = the density of the fuel (7.14 lb/gal).
- HV = the heating value of the fuel (0.137 MMBtu/gal).
- CO2, CH4, and N2O emission factors from Tables C-1 and C-2 of 40 CFR 98, Subpart C. Emissions calculated using the high heat value of 0.138 MMBtu/gal
from Table C-1 of 40 CFR 98, Subpart C and a fuel consumption at 100% load (from manufacturer spec sheet).
- NH3 emission factor from "Development and Selection of Ammonia Emission Factors," developed under EPA contract by Battye, Battye, Overcash and Fudge,
1994. Emissions calculated using a fuel consumption at 100% load (from manufacturer spec sheet).
- CO2e calculated using table A-1 "Global Warming Potentials" from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas
pollutant (CO2, CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Pollutant CAS #
Emission Factor PTE Emissions
Attachment 2: PTE  Emission Calculations page 3 of 11
lb/MMBtu lb/hp-hr lb/hr ton/yr
Toluene 108-88-3
2.81E-04 7.49E-07 8.88E-03 4.44E-04
Xylenes 1330-20-7 1.93E-04 5.15E-07 6.11E-03 3.05E-04
Total HAPs 0.05 2.49E-03
Notes:
- Emission factors in units of lb/MMBtu obtained from AP-42, Fifth Edition, Section 3.4, Tables 3.4-3 and 3.4-4 (dated 10/96).
- Emission factors in units of lb/hp-hr values from AFCEC. Values calculated using the ratio of the HAP to total VOC from AP-42. The ratio was then multiplied
by the most conservative AFCEC VOC value for emergency engines (0.0292 lb/MMBtu). [(AP-42 HAP emission factor / NMHC AP42) x 0.0292 = AFCEC HAP
emission factor]
Pollutant CAS #
Emission Factor PTE Emissions
Attachment 2: PTE  Emission Calculations page 4 of 11
Criteria Pollutant and Greenhouse Gas Emission Calculations - New Emergency Generator
The generator is EPA Tier 2 compliant, consistent with NSPS Subpart IIII requirements
Fuel consumption rate 175 gal/hr - per manufacturer technical data sheets
Engine rating 2,500 kW
2,202 kW (derated for altitude)
Maximum horsepower rating: 2,953 hp (derated for altitude)
Hours of
Operation
g//kW-hr lb/hp-hr kg/MMBtu lb/1,000 gal hr/yr lb/hr ton/yr
NOX + NMHC 6.4
NOX 1.03E-02 100 30.4 1.52
VOC 2.86E-04 100 0.84 0.04
CO 3.5 5.73E-03 100 16.9 0.85
SOX 1.26E-05 100 0.04 1.86E-03
PM10 0.20 3.31E-04 100 0.98 0.05
PM2.5 0.20 3.31E-04 100 0.98 0.05
CO2 73.96 100 3,944 197
CH4 3.00E-03 100 0.16 8.00E-03
N2O 6.00E-04 100 0.03 1.60E-03
NH3 0.80 100 0.14 7.01E-03
CO2e 3,958 198
Notes:
Pollutant Emission Factors PTE Emissions
- Engine is certified NSPS Subpart IIII Tier 2 compliant. The NSPS incorporates EPA Tier 2 requirements in 40 CFR Part 1039, Appendix I, Table 2 as
the applicable standards for this engine.
- Annual hours of operation based on 100 hours for non-emergency use.
- The EPA Tier 2 emission factor for NOX includes both NMHC and NOX. Per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force
Civil Engineer Center [AFCEC], July 2023, Section 3) a NO X emission factor is calculated using emission factors from AP-42, NSPS emission limits and the
following equation:
- Emission factors in g/kW-hr for NOX + NMHC, CO and PM10/PM2.5 are from NSPS Subpart IIII requirements. It is assumed that all PM is PM10 and all PM10 is
PM2.5. PM10 and PM2.5 are subsets of total PM.
Attachment 2: PTE  Emission Calculations page 5 of 11
HAP Emission Calculations
lb/MMBtu lb/hp-hr lb/hr ton/yr
Acenaphthene 83-32-9 4.68E-06 1.25E-08 3.69E-05 1.85E-06
Acenaphthylene 208-96-8 9.23E-06 2.46E-08 7.26E-05 3.63E-06
Acetaldehyde 75-07-0
2.52E-05 6.72E-08 1.98E-04 9.92E-06
Acrolein 107-02-8
7.88E-06 2.10E-08 6.20E-05 3.10E-06
- SOX emission factor calculated per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC], August
2018, Section 3), using the following equation. Emission factor calculated in units of lb/MMBtu and converted to lb/hp-hr using an average Brake-Specific Fuel
Consumption (BSFC) of 8089 Btu/hp-hr.
S x 0.02 x D x (1/HV)
where,
- S = weight percent sulfur content of the fuel (0.0015%).
- 0.02 = conversion factor converting the weight percent to a weight fraction multiplied by the ratio of the molecular weight of SO 2 to the molecular weight of
sulfur.
- D = the density of the fuel (7.14 lb/gal).
- HV = the heating value of the fuel (0.137 MMBtu/gal).
NOX NSPS = [(NOX + NMHC) NSPS / NOX AP42 + NMHC AP42)] x NOX AP42
where,
- NOX NSPS = NOX emission factor using NSPS emission limits and NOX / NMHC ratio.
- (NOX + NMHC) NSPS = Maximum allowable combined NOX and NMHC emissions from NSPS IIII requirements.
- NOX AP42 = NOX emission factor from AP-42.
- NMHC AP42 = NMHC emission factor calculated using the VOC emission factor data from AP-42.
- NMHC AP42 emission factor calculated using the AP-42 emission factor for TOC and multiplying by hydrocarbon conversion factors (VOC/THC = 1.053,
NMHC/THC = 0.984, TOC/THC = 1.070) from Conversion Factors for Hydrocarbon Emission Components, EPA, Office of Transportation and Air Quality, July
2010. [(AP-42 TOC emission factor) x (0.984 NMHC/THC) / (1.070 TOC/THC) = NMHC emission factor]
- VOC emission factor calculated using (NOX + NMHC) NSPS, NOX NSPS and hydrocarbon conversion factors. [((NO X + NMHC) NSPS - NOX NSPS) x (1.053 VOC/THC)
/ (0.984 NMHC/THC) = VOC emission factor]
- CO2, CH4, and N2O emission factors from Tables C-1 and C-2 of 40 CFR 98, Subpart C. Emissions calculated using the high heat value of 0.138 MMBtu/gal from
Table C-1 of 40 CFR 98, Subpart C and a fuel consumption at 100% load (from manufacturer spec sheet).
- NH3 emission factor from "Development and Selection of Ammonia Emission Factors," developed under EPA contract by Battye, Battye, Overcash and Fudge,
1994. Emissions calculated using a fuel consumption at 100% load (from manufacturer spec sheet).
- CO2e calculated using table A-1 "Global Warming Potentials" from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas
pollutant (CO2, CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Pollutant CAS #
Emission Factor PTE Emissions
Attachment 2: PTE  Emission Calculations page 6 of 11
lb/MMBtu lb/hp-hr lb/hr ton/yr
Anthracene 120-12-7 1.23E-06 3.28E-09 9.69E-06 4.84E-07
Benzo(a)anthracene 56-55-3 6.22E-07 1.66E-09 4.90E-06 2.45E-07
Benzene 71-43-2
7.76E-04 2.07E-06 6.11E-03 3.06E-04
Benzo(a)pyrene 50-32-8 2.57E-07 6.85E-10 2.02E-06 1.01E-07
Benzo(b)fluoranthene 205-99-2
1.11E-06 2.96E-09 8.74E-06 4.37E-07
Benzo(g,h,l)perylene 191-24-2 5.56E-07 1.48E-09 4.37E-06 2.19E-07
Benzo(k)fluoranthene 207-08-9
2.18E-07 5.81E-10 1.72E-06 8.58E-08
Chrysene 218-01-9 1.53E-06 4.08E-09 1.20E-05 6.02E-07
Dibenz(a,h)anthracene 53-70-3
3.46E-07 9.22E-10 2.72E-06 1.36E-07
Fluoranthene 206-44-0 4.03E-06 1.07E-08 3.16E-05 1.58E-06
Fluorene 7782-41-4
1.28E-05 3.41E-08 1.01E-04 5.03E-06
Formaldehyde 50-00-0 7.89E-05 2.10E-07 6.20E-04 3.10E-05
Indeno(1,2,3-cd)pyrene 193-39-5
4.14E-07 1.10E-09 3.25E-06 1.62E-07
Naphthalene 91-20-3 1.30E-04 3.47E-07 1.02E-03 5.12E-05
Phenanthrene 85-01-8
4.08E-05 1.09E-07 3.22E-04 1.61E-05
Pyrene 129-00-0 3.71E-06 9.89E-09 2.92E-05 1.46E-06
Toluene 108-88-3
2.81E-04 7.49E-07 2.21E-03 1.11E-04
Xylenes 1330-20-7 1.93E-04 5.15E-07 1.52E-03 7.60E-05
Total HAPs 0.01 6.20E-04
Notes:
- Emission factors in units of lb/MMBtu obtained from AP-42, Fifth Edition, Section 3.4, Tables 3.4-3 and 3.4-4 (dated 10/96).
Pollutant CAS #
Emission Factor PTE Emissions
- Emission factors in units of lb/hp-hr values from AFCEC. Values calculated using the ratio of the HAP to total VOC from AP-42. The ratio was then multiplied by
the most conservative AFCEC VOC value for emergency engines (0.0292 lb/MMBtu). [(AP-42 HAP emission factor / NMHC AP42) x 0.0292 = AFCEC HAP
emission factor]
Attachment 2: PTE  Emission Calculations page 7 of 11
Criteria Pollutant and Greenhouse Gas Emission Calculations - New Emergency Generator
The generator is EPA Tier 2 compliant, consistent with NSPS Subpart IIII requirements
Fuel consumption rate 155 gal/hr - per manufacturer technical data sheets
Engine rating 2,181 kW
2,142 kW (derated for altitude)
Maximum horsepower rating: 2,872 hp (derated for altitude)
Hours of
Operation
g//kW-hr lb/hp-hr kg/MMBtu lb/1,000 gal hr/yr lb/hr ton/yr
NOX + NMHC 6.4
NOX 1.03E-02 100 29.6 1.48
VOC 2.86E-04 100 0.82 0.04
CO 3.5 5.73E-03 100 16.5 0.82
SOX 1.26E-05 100 0.04 1.81E-03
PM10 0.20 3.31E-04 100 0.95 0.05
PM2.5 0.20 3.31E-04 100 0.95 0.05
CO2 73.96 100 3,488 174
CH4 3.00E-03 100 0.14 7.07E-03
N2O 6.00E-04 100 0.03 1.41E-03
NH3 0.80 100 0.12 6.20E-03
CO2e 3,500 175
Notes:
Pollutant Emission Factors PTE Emissions
- Annual hours of operation based on 100 hours for non-emergency use.
- Engine is certified NSPS Subpart IIII Tier 2 compliant. The NSPS incorporates EPA Tier 2 requirements in 40 CFR Part 1039, Appendix I, Table 2 as
the applicable standards for this engine.
- Emission factors in g/kW-hr for NOX + NMHC, CO and PM10/PM2.5 are from NSPS Subpart IIII requirements. It is assumed that all PM is PM10 and all PM10 is
PM2.5. PM10 and PM2.5 are subsets of total PM.
- The EPA Tier 2 emission factor for NOX includes both NMHC and NOX. Per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force
Civil Engineer Center [AFCEC], July 2023, Section 3) a NO X emission factor is calculated using emission factors from AP-42, NSPS emission limits and the
following equation:
Attachment 2: PTE  Emission Calculations page 8 of 11
HAP Emission Calculations
lb/MMBtu lb/hp-hr lb/hr ton/yr
Acenaphthene 83-32-9 4.68E-06 1.25E-08 3.59E-05 1.80E-06
Acenaphthylene 208-96-8 9.23E-06 2.46E-08 7.07E-05 3.53E-06
Acetaldehyde 75-07-0
2.52E-05 6.72E-08 1.93E-04 9.65E-06
Acrolein 107-02-8
7.88E-06 2.10E-08 6.03E-05 3.02E-06
S x 0.02 x D x (1/HV)
where,
- S = weight percent sulfur content of the fuel (0.0015%).
- 0.02 = conversion factor converting the weight percent to a weight fraction multiplied by the ratio of the molecular weight of SO 2 to the molecular weight of
sulfur.
- D = the density of the fuel (7.14 lb/gal).
- HV = the heating value of the fuel (0.137 MMBtu/gal).
NOX NSPS = [(NOX + NMHC) NSPS / NOX AP42 + NMHC AP42)] x NOX AP42
where,
- NOX NSPS = NOX emission factor using NSPS emission limits and NOX / NMHC ratio.
- (NOX + NMHC) NSPS = Maximum allowable combined NOX and NMHC emissions from NSPS IIII requirements.
- NOX AP42 = NOX emission factor from AP-42.
- NMHC AP42 = NMHC emission factor calculated using the VOC emission factor data from AP-42.
- NMHC AP42 emission factor calculated using the AP-42 emission factor for TOC and multiplying by hydrocarbon conversion factors (VOC/THC = 1.053,
NMHC/THC = 0.984, TOC/THC = 1.070) from Conversion Factors for Hydrocarbon Emission Components, EPA, Office of Transportation and Air Quality, July
2010. [(AP-42 TOC emission factor) x (0.984 NMHC/THC) / (1.070 TOC/THC) = NMHC emission factor]
- VOC emission factor calculated using (NOX + NMHC) NSPS, NOX NSPS and hydrocarbon conversion factors. [((NO X + NMHC) NSPS - NOX NSPS) x (1.053 VOC/THC)
/ (0.984 NMHC/THC) = VOC emission factor]
- SOX emission factor calculated per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC], August
2018, Section 3), using the following equation. Emission factor calculated in units of lb/MMBtu and converted to lb/hp-hr using an average Brake-Specific Fuel
Consumption (BSFC) of 8089 Btu/hp-hr.
- CO2, CH4, and N2O emission factors from Tables C-1 and C-2 of 40 CFR 98, Subpart C. Emissions calculated using the high heat value of 0.138 MMBtu/gal from
Table C-1 of 40 CFR 98, Subpart C and a fuel consumption at 100% load (from manufacturer spec sheet).
- NH3 emission factor from "Development and Selection of Ammonia Emission Factors," developed under EPA contract by Battye, Battye, Overcash and Fudge,
1994. Emissions calculated using a fuel consumption at 100% load (from manufacturer spec sheet).
- CO2e calculated using table A-1 "Global Warming Potentials" from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas
pollutant (CO2, CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Pollutant CAS #
Emission Factor PTE Emissions
Attachment 2: PTE  Emission Calculations page 9 of 11
lb/MMBtu lb/hp-hr lb/hr ton/yr
Anthracene 120-12-7 1.23E-06 3.28E-09 9.42E-06 4.71E-07
Benzo(a)anthracene 56-55-3 6.22E-07 1.66E-09 4.77E-06 2.38E-07
Benzene 71-43-2
7.76E-04 2.07E-06 5.95E-03 2.97E-04
Benzo(a)pyrene 50-32-8 2.57E-07 6.85E-10 1.97E-06 9.84E-08
Benzo(b)fluoranthene 205-99-2
1.11E-06 2.96E-09 8.50E-06 4.25E-07
Benzo(g,h,l)perylene 191-24-2 5.56E-07 1.48E-09 4.25E-06 2.13E-07
Benzo(k)fluoranthene 207-08-9
2.18E-07 5.81E-10 1.67E-06 8.34E-08
Chrysene 218-01-9 1.53E-06 4.08E-09 1.17E-05 5.86E-07
Dibenz(a,h)anthracene 53-70-3
3.46E-07 9.22E-10 2.65E-06 1.32E-07
Fluoranthene 206-44-0 4.03E-06 1.07E-08 3.07E-05 1.54E-06
Fluorene 7782-41-4
1.28E-05 3.41E-08 9.79E-05 4.90E-06
Formaldehyde 50-00-0 7.89E-05 2.10E-07 6.03E-04 3.02E-05
Indeno(1,2,3-cd)pyrene 193-39-5
4.14E-07 1.10E-09 3.16E-06 1.58E-07
Naphthalene 91-20-3 1.30E-04 3.47E-07 9.97E-04 4.98E-05
Phenanthrene 85-01-8
4.08E-05 1.09E-07 3.13E-04 1.57E-05
Pyrene 129-00-0 3.71E-06 9.89E-09 2.84E-05 1.42E-06
Toluene 108-88-3
2.81E-04 7.49E-07 2.15E-03 1.08E-04
Xylenes 1330-20-7 1.93E-04 5.15E-07 1.48E-03 7.40E-05
Total HAPs 0.01 6.03E-04
Notes:
- Emission factors in units of lb/MMBtu obtained from AP-42, Fifth Edition, Section 3.4, Tables 3.4-3 and 3.4-4 (dated 10/96).
Pollutant CAS #
Emission Factor PTE Emissions
- Emission factors in units of lb/hp-hr values from AFCEC. Values calculated using the ratio of the HAP to total VOC from AP-42. The ratio was then multiplied by
the most conservative AFCEC VOC value for emergency engines (0.0292 lb/MMBtu). [(AP-42 HAP emission factor / NMHC AP42) x 0.0292 = AFCEC HAP
emission factor]
Attachment 2: PTE  Emission Calculations page 10 of 11
HAP Modeling Threshold Evaluation for the Two New Emergency Generators
Hourly
Emissions
lb/hr
Benzene 71-43-2 Chronic 0.123 1.60 0.20 0.01 No
Toluene 108-88-3 Chronic 0.123 75.36 9.27 4.36E-03 No
Xylenes 1330-20-7 Chronic 0.123 434 53.41 3.00E-03 No
Formaldehyde 50-00-0 Acute 0.092 0.37 0.03 1.22E-03 No
Acetaldehyde 75-07-0 Acute 0.092 45.04 4.14 3.91E-04 No
Acrolein 107-02-8 Acute 0.092 0.23 0.02 1.22E-04 No
Naphthalene 91-20-3 Chronic 0.123 52.43 6.45 2.02E-03 No
Acenaphthylene 208-96-8 Not Listed - - - 1.43E-04 -
Acenaphthene 83-32-9 Not Listed - - - 7.28E-05 -
Fluorene 7782-41-4 Chronic 0.123 1.55 0.19 1.99E-04 No
Phenanthrene 85-01-8 Not Listed - - - 6.35E-04 -
Anthracene 120-12-7 Not Listed - - - 1.91E-05 -
Fluoranthene 206-44-0 Not Listed - - - 6.23E-05 -
Pyrene 129-00-0 Not Listed - - - 5.76E-05 -
Benzo(a)anthracene 56-55-3 Carcinogenic 0.041 No TLV - 9.67E-06 -
Chrysene 218-01-9 Carcinogenic 0.041 No TLV - 2.38E-05 -
Benzo(b)fluoranthene 205-99-2 Carcinogenic 0.041 No TLV - 1.72E-05 -
Benzo(k)fluoranthene 207-08-9 Not Listed - - - 3.38E-06 -
Benzo(a)pyrene 50-32-8 Carcinogenic 0.041 No TLV - 3.99E-06 -
Indeno(1,2,3-cd)pyrene 193-39-5 Not Listed - - - 6.41E-06 -
Dibenz(a,h)anthracene 53-70-3 Not Listed - - - 5.37E-06 -
Benzo(g,h,i)perylene 191-24-2 Not Listed - - - 8.62E-06 -
4 Emission threshold value (ETV) calculated by multiplying the ETF by the TLV for each pollutant.
1 For benzene and formaldehyde, value from R307-410-5. For all other pollutants, value from American Conference of Government Industrial Hygienists (ACGIH)
Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices (2016).
2 Emission threshold factor (ETF) values from Table 2 of R307-410-5. The distance from the location of the generators to the property boundary conservatively
assumed to be between 51 - 100 meters. It is assumed the release point is vertically restricted (release of an air contaminant through a stack or opening whose flow is
directed in a downward or horizontal direction due to the alignment of the opening or a physical obstruction placed beyond the opening, or at a height which is less
than 1.3 times the height of an adjacent building or structure, as measured from ground level).
3 Threshold limit value (TLV) from ACGIH Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices (2016). TLV
calculated by multiplying the time-weighted average, short-term exposure limit, or ceiling value by the gram molecular weight of the pollutant and dividing by 24.45.
Pollutant CAS #
Acute /
Chronic /
Carcinogenic 1
ETF 2
(lb-m3 /
mg-hr)
TLV 3
(mg/m3)
ETV 4
(lb/hr)
ETV
Exceedance
?
Attachment 2: PTE  Emission Calculations page 11 of 11
Attachment 3: BACT Determination
To evaluate the appropriate best available control technology (BACT) for the proposed
diesel-fired emergency engines, 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 for diesel-
fired emergency generators were reviewed. The following is a list of control technologies
identified.
1) EPA’s RBLC was reviewed to determine EPA BACT decisions for diesel-fired internal
combustion compression ignition engines with size ratings near the new engine ratings of
2,202 kW and 1,964 kW (process type code 17.110). These BACT determinations are
summarized in the following table.
RBCL
ID
Unit Size
(kW) NOX Control Determination
LA-0317 1,750 Comply with 40 CFR 60 Subpart IIII and 40 CFR 63 Subpart ZZZZ
LA-0308 2,000 Good combustion and maintenance practices and compliance with
NSPS 40 CFR 60 Subpart IIII
MI-0423 2,179 Good combustion practices and meeting NSPS IIII requirements
MD-0042 2,250 Limit on operating hours, use of ultra-low sulfur fuel and good
combustion practices
OH-0352 2,250 Purchase engine certified to the standards in NSPS Subpart IIII
LA-0313 1,923
Compliance with 40 CFR 63 Subpart ZZZZ and NSPS 40 CFR 60
Subpart IIII, good combustion practices. use of ultra-low sulfur diesel
fuel
LA-0288 2,000
Comply with 40 CFR 60 Subpart IIII; operate the engine in
accordance with the engine manufacturer’s instructions and/or written
procedures designed to maximize combustion efficiency and minimize
fuel usage
LA-0296 2,000
Compliance with 40 CFR 60 Subpart IIII; operating the engine in
accordance with the engine manufacturer’s instructions and/or written
procedures (consistent with safe operation) designed to maximize
combustion efficiency and minimize fuel usage
LA-0309 2,179 Comply with 40 CFR 60 Subpart IIII
LA-0316 2,500 Comply with 40 CFR 60 Subpart IIII

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.
Attachment 3: BACT Determination

3) Use of Low-Sulfur Fuel (0.05%): Use of low-sulfur diesel fuel reduces SOX emissions
and is considered BACT for diesel-fired emergency engines.

4) 40 CFR Part 60 Subpart IIII 'Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines' requires owners and operators of non-emergency
and emergency affected engines to comply with emission standards (Tier standards)
based on engine model year, maximum engine power, engine displacement and use
(emergency, non-emergency). The Tier standards are emission limits for PM, CO and
NMHC + NOx or NOx and NMHC. The subpart requires proper operation and
maintenance, in accordance with the manufacturer, to ensure affected emission units
achieve the applicable Tier standards over the entire life of the engine. The subpart
requires affected emission units with a displacement of less than 30 liters per cylinder to
comply with fuel sulfur limitations: (1) fuel sulfur content no greater than 15 ppm
(0.0015 percent) by weight and (2) a minimum cetane index of 40 or a maximum
aromatic content of 35 volume percent.

5) Limited Hours of Operation: 40 CFR Part 60 Subpart IIII 'Standards of Performance for
Stationary Compression Ignition Internal Combustion Engines' limits the operation for
readiness (maintenance and testing) to 100 hours annually for emergency generators.
Limiting the hours of operation for the equipment limits emissions of all pollutants
released from the emergency generator.

6) 40 CFR Part 63 Subpart ZZZZ 'National Emission Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines' requires owners
and operators of non-emergency and emergency affected engines to at all times operate
and maintain any affected source in a manner consistent with safety and good air
pollution control practices for minimizing emissions.

7) Selective Catalyst Reduction (SCR): Is a combination of engineered components
designed to reduce the amount of NOx in a turbine or engine exhaust stream. A form of
ammonia is injected in front of a catalyst to reduce the NOx. Nitrogen oxides are formed
when the oxygen and nitrogen in the air react with each other during combustion. High
temperatures and excess oxygen (more than is needed to burn the fuel) favor the
formation of nitrogen oxides. SCR systems are installed to reduce NOx levels in the
exhaust gas stream from the engine. SCR systems have the capability of reducing both
NO and NO2 in the gas stream by injecting an ammonia reagent ahead of the catalyst. In
addition to NOx control, SCR systems with an oxidation catalyst can also reduce CO
emissions.
For SCR systems to function effectively, exhaust temperatures must be high enough
(200°C to 500°C) to enable catalyst activation. SCR control efficiencies are relatively
low during the first 20 to 30 minutes after engine start up, especially during maintenance
and testing. There are also complications controlling the excess ammonia (ammonia slip)
Attachment 3: BACT Determination
from SCR use. SCR is anticipated to have relatively low combustion efficiency during
maintenance and testing, SCR is not considered technically feasible for emergency units.

All of the technologies listed above for control of emissions from diesel-fired emergency
generators are technically feasible. Based on the review of control technologies considered
BACT for diesel-fired emergency engines, Hill AFB has determined the following meets BACT
requirements:
 Good combustion, maintenance and operating practices
 Use of low-sulfur diesel fuel
 Compliance with applicable NSPS IIII requirements
o Use of a tier certified engine
o Limit on hours of operation for maintenance and testing operations
 Compliance with applicable NESHAP ZZZZ requirements
SCR has not been determined to be BACT for the new diesel-fired engine as the engines are
for emergency use. In addition to the above BACT, the unit will be equipped with a
turbocharger and charge air cooler which help control air pollutant emissions.
DEPARTMENT OF THE AIR FORCE
75TH CIVIL ENGINEER GROUP (AFMC)
HILL AIR FORCE BASE UTAH

26 October 2023

Amanda Burton
Chief, Environmental Branch
75 CEG/CEIE
7290 Weiner Road
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 notice of intent to modify approval order (AO)
DAQE-AN101210266-19 for the addition of one emergency generator and to update the potential to
emit (PTE) emissions for the four generators in the AO due to a change in emission calculation
methodology. A redline of DAQE-AN101210266-19 with the requested changes is included as
Attachment 1. The generator will have the following specifications:

Equipment type: compression ignition internal combustion engine
Power type: emergency
Manufacturer: Caterpillar
Model: 3516C
Fuel: diesel
Engine rating: 2,500 kW
Engine site-specific rating: 2,202 kW
Manufacturer year: 2021
Tier rating: 2
Quantity: 1
AQUIS ID: 45491

The PTE emissions were calculated using manufacturer data; Air Force guidance documents;
40 Code of Federal Regulations (CFR) Part 98, Mandatory Greenhouse Gas Reporting, Subpart C;
EPA guidance documents; and EPA AP-42. Detailed emission calculations for the new generator
and the recalculated PTE emissions for the four generators in the AO are provided in Attachment 2.
PTE emissions 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 1.75 0.09 0.98 0.05 2.73 0.14
PM2.5 1.75 0.09 0.98 0.05 2.73 0.14
SOX 0.14 7.19E-03 0.04 2.14E-03 0.19 9.33E-03
NOX 102 5.09 30.4 1.52 132 6.61
CO 21.4 1.07 16.9 0.85 38.4 1.92
VOC 3.51 0.18 0.85 0.05 4.35 0.22
HAPs 0.13 7.26E-03 -0.07 -4.15E-03 0.06 3.11E-03
Ammonia 0.53 0.03 0.14 7.01E-03 0.67 0.03
Lead 0 0 0 0 0 0
Total CO2e 15,092 755 3,958 198 19,050 952
1 Speciated HAP emissions are included in the attached emission calculations.

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 emission increases are below the
applicable thresholds provided in UAC R307-410-4. Pursuant to R307-410-5(1)(c), a screening
analysis was conducted for HAP emissions. From the analysis, it was determined the proposed HAP
emission increases from the new emergency generator were below the respective emission threshold
values based upon the applicable threshold limit value – time weighted average.

The engines are subject to New Source Performance Standards Subpart IIII, ‘Standards of
Performance for Stationary Compression Ignition Internal Combustion Engines’ and are also affected
sources under National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart ZZZZ,
‘Stationary Reciprocating Internal Combustion Engines’, but there are no applicable emission limits
under the NESHAP. The units will comply with all applicable requirements of the Hill AFB Main
Base Title V Operating Permit (TVOP) Conditions II.B.43, II.B.44 and II.B.48. Best available
control technology (BACT) for internal combustion engines is provided in TVOP Conditions II.B.43,
II.B.44 and II.B.48 and a BACT determination is included as Attachment 3.

Hill AFB requests the enhanced new source review process for this AO so the Main Base
Title V Operating Permit can be modified administratively. 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 (801)
777-0888 or [e-mail].

Sincerely
10/26/2023
X Amanda Burton
Signed by: BURTON.AMANDA.CHRISTINE.1270023068 AMANDA BURTON, NH-III, DAF
Chief, Environmental Branch

3 Attachments:
1. Redline of DAQE-AN101210266-19
2. PTE Emission Calculations
3. BACT Determination
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

APPROVAL ORDER: Administrative
AmendmentModification to Large Emergency Generators
Approval Order,
DAQE-AN1012102566-198, to Update
Opacity Monitoring LanguageAdd one
Emergency Generator and Update PTE
Emissions for the Emergency Generators
Already Listed in the Permit

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

APPROVAL ORDER NUMBER
DAQE-AN101210266TBD-2319
Date: May 8, 2019TBD

Hill Air Force Base
Main Base
Source Contact:
Erik Dettenmaier
Phone: [phone]
Email: [e-mail]
Signed by Bryce C. Bird on TBDMay 8,
2019 Bryce C. BirdBD
Director
Abstract
Hill Air Force Base (Hill AFB) has requested an administrative amendment modification to the Large
Emergency Generator AO DAQE-AN10121026656-198, to add one emergency generator and update emission
calculations for the four emergency generators already listed in the permit due to a change in emission
calculation methodology.update opacity monitoring language with the language for limited use power supply
units in the Title V Operating Permit. Hill AFB is also requesting removal of the 30,000 gallon diesel tank
from this permit. The tank has been incorporated into the fuel tanks permit DAQE-AN101210260-19. This
permit action is an administrative correction and is not adding equipment or increasing emissions. The
following are the PTE emission changes (in TPY) resulting from the changes requested in this permit
modification: 0.05 of PM10, 0.05 of PM2.5 (Subset of PM10), 1.52 of NOX, 0.85 of CO, 0.002 of SOX, 0.05 of
VOC, 198 of CO2e, and -0.004 of combined HAPs The following are the estimated PTE emissions (in TPY) for
the processes in this AO: 0.14 of PM10, 0.14 of PM2.5 (Subset of PM10), 6.61 of NOX, 1.92 of CO, 0.009 of
SOX, 0.22 of VOC, 952 of CO2e, and 0.003 of combined HAPs

Hill AFB is subject to 40 CFR 63 Subpart GG, NESHAP for Aerospace Manufacturing and Rework
Facilities, but the generators in this AO are not subject to this regulation. The engines are subject to
NSPS 40 CFR 60 Subpart A and IIII (Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines) and are also subject to NESHAP 40 CFR 63 Subpart A and ZZZZ
(National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines). Hill AFB is classified as a major source of air pollution and is subject to the
Operating Permit Program. Hill AFB is a PM2.5 SIP-listed source, a major source for VOCs, GHGs,
PM10, PM2.5, HAPs and CO2e. Hill AFB is a PSD source for NOX and CO. Hill AFB is located in Davis
and Weber Counties, which are nonattainment for PM2.5 and ozone and attainment area for all other
criteria pollutants. The Title V permit will be administratively amended to incorporate the conditions of
this AO.
The following are the estimated PTE emissions (in TPY): 0.09 of PM10, 0.09 of PM2.5 (Subset of PM10),
5.09 of NOX, 1.07 of CO, 0.007 of SOX, 0.18 of VOC, 755 of CO2e, and 0.006 of combined HAPs.

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/CEIEA
7290 Weiner Street, Bldg. 383
Hill Air Force Base, UT 84056-
5236003
Permitted Location:
Main Base
75 CEG/CEIEA
7290 Weiner Street
Hill Air Force Base, UT 84056-5136003

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-AN1012102TBD66-TBD19
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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from AO DAQE-AN101210256TBD-TBD18 dated
TBDSeptember 4, 2018. This AO may become invalid if construction is not commenced
within 18 months from the AO dated TBDSeptember 4, 2018, or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Permitted Source
Source-wide
II.A.2 Four (4) Diesel-fired Emergency Generators
Capacity: 2,250 kW (each)
Site-specific capacity: 2,210 kW (each)
AQUIS IDs: 44689, 44690, 44691, 44692

II.A.3 One (1) Diesel-fired Emergency Generators
Capacity: 2,500 kW
Site-specific capacity: 2,202 kW
AQUIS IDs: 45491

II.B Requirements and Limitations
II.B.1 Site-wide Requirements

II.B.1.a Visible emissions from the fiveour (54) diesel-fired emergency generators shall be no greater
than 20% opacity except for a period not exceeding three (3) minutes in any hour. The
permittee shall apply one (1) of the following monitoring techniques to each affected emission
unit when in operation.

A. Monthly visual opacity survey conducted by an individual trained on the observation
procedures of 40 CFR 60, Appendix A, Method 9. If any visible emissions other than
condensed water vapor are observed from an emission point, an opacity determination
of that emission point shall be performed in accordance with 40 CFR 60, Method 9
within 24 hours of the initial visual opacity survey or upon start-up if the unit must be
shut down for maintenance. If the unit must be permanently removed from service, no
follow-up opacity determination is required.

B. Quarterly photogrametric opacity observations conducted by an individual trained on
the observation procedures of 40 CFR 60, Appendix A, Method 9. If an opacity of
15% or more is detected by the photogrametric analysis, an opacity determination of
that emission point shall be performed in accordance with 40 CFR 60, Appendix A,
DAQE-AN1012102TBD66-TBD19
Page 4

Method 9 within 24 hours of the initial photogrametric opacity observation or upon
start-up if the unit must be shut down for maintenance. If the unit must be
permanently removed from service, no follow-up opacity determination is required.

C. An annual opacity determination performed in accordance with 40 CFR 60, Appendix
A, Method 9.

The monitoring option selected can vary from unit to unit. For example, if quarterly
photogrametric opacity observations are being conducted for a given unit and the permittee
cannot conduct a photogrametric opacity observation in a quarter that unit operated, an opacity
determination conducted in accordance with the procedures of 40 CFR 60, Appendix A,
Method 9 will satisfy the monitoring requirements of this condition.
[R307-201-3, R307-305, R307-401-8]

II.B.1.a.1 The permittee shall maintain a monthly log of visual opacity surveys, quarterly photogrametric
observations, and/or annual opacity determinations which include the following information
for each affected emission unit: the date and time of each visual opacity survey,
photogrametric opacity observation, annual opacity determination, the specific monitoring
technique used (visual opacity survey, 40 CFR 60 Appendix A Method 9, or photogrametric
observation), and the result of the opacity monitoring. The records required by this provision
and all data required by 40 CFR 60, Appendix A, Method 9 shall be maintained.
[R307-401-8]

II.B.1.b The fiveour (54) diesel-fired emergency generator engines shall meet the applicable
requirements in 40 CFR 60, Subparts A and IIII, and 40 CFR 63, Subparts A and ZZZZ.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]
II.B.2 Sulfur Fuel Content Requirement

II.B.2.a The permittee shall purchase diesel fuel with a sulfur content no greater than 15 ppm
(0.0015%) by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2.a.1 For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the sulfur content for
Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain documentation
demonstrating compliance with the condition. [40 CFR 60 Subpart IIII,
40 CFR 63 Subpart ZZZZ]
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.
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source
DAQE-AN1012102TBD66-TBD19
Page 5

PERMIT HISTORY

This AO is based on the following documents:
Is Derived From NOI dated October 2023December 20, 2018
Supersedes AO DAQE-AN10121026656-198 dated September 4, 201918
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, PM2.5 Serious Area SIP,
Major Criteria Source, NSPS (Part 60), MACT (Part 63)
DAQE-AN1012102TBD66-TBD19
Page 6

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
lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr
PM10 1.75 0.09 1.75 0.09 0.98 0.05 0.98 0.05 2.73 0.14
PM2.5 1.75 0.09 1.75 0.09 0.98 0.05 0.98 0.05 2.73 0.14
SOX 0.14 7.19E-03 0.15 7.47E-03 0.04 1.86E-03 0.04 2.14E-03 0.19 9.33E-03
NOX 102 5.09 102 5.09 30.4 1.52 30.4 1.52 132 6.61
CO 21.4 1.07 21.4 1.07 16.9 0.85 16.9 0.85 38.4 1.92
VOC 3.51 0.18 3.51 0.18 0.84 0.04 0.85 0.05 4.35 0.22
Lead 0 0 0 0 0 0 0 0 0 0
Total HAP 0.13 7.26E-03 0.05 2.49E-03 0.01 6.20E-04 -0.07 -4.15E-03 0.06 3.11E-03
GHG (CO2e) 4 15,092 755 15,092 755 3,958 198 3,958 198 19,050 952
NH3 0.53 0.03 0.53 0.03 0.14 7.01E-03 0.14 7.01E-03 0.67 0.03
Pollutant
AO Current PTE
Emissions
1 The PTE emissions for the four emergency generators listed in approval order DAQE-AN101210266-19 were recalculated due to a change in Hill AFB generator PTE
emission calculation methodology which occurred after the issuance of DAQE-AN101210266-19. Per Air Force Guidance, emission factors from the Air Emissions Guide for
Air Force Stationary Sources are used to calculate emissions for emergency generators. The change in calculation methodology only impacts the SOX and HAP emissions for
the four generators.
2 The change in PTE emissions is the difference between the PTE emissions listed in AQE-AN101210266-19 and the AO Recalculated PTE emissions and the addition of the
PTE emissions from the new emergency generator.
[(AO current PTE emissions) - (AO recalculated PTE emissions) + (new emergency generator PTE emissions)]
3 The new AO PTE emissions is the sum of the AO Recalculated PTE emissions and the PTE emissions from the new emergency generator.
[(AO recalculated PTE emissions) + (new emergency generator PTE emissions)]
4 CO2e calculated using Table A-1 'Global Warming Potentials' from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas pollutant (CO2,
CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Change in PTE Emissions 2 AO Recalculated
PTE Emissions 1
New Generator
PTE Emissions
New AO
PTE Emissions 3
Attachment 2: PTE  Emission Calculations page 1 of 8
Criteria Pollutant and Greenhouse Gas Emission Recalculations - Four Emergency Generators
The generators are EPA Tier 2 compliant, consistent with NSPS Subpart IIII requirements
Number of units 4
Fuel consumption rate 167 gal/hr - per manufacturer technical data sheets
668 gal/hr - four generators
Engine rating 2,250 kW
2,210 kW (derated for altitude)
8,840 kW - four generators (derated for altitude)
Maximum horsepower rating: 2,964 hp - per generator (derated for altitude)
11,855 hp - four generators (derated for altitude)
Hours of
Operation
g/kW-hr lb/hp-hr kg/MMBtu lb/1,000 gal hr/yr/engine lb/hr ton/yr
NOX 5.22 100 102 5.09
VOC 0.18 100 3.51 0.18
CO 1.10 100 21.4 1.07
SOX 1.26E-05 100 0.15 7.47E-03
PM10 0.09 100 1.75 0.09
PM2.5 0.09 100 1.75 0.09
CO2 73.96 100 15,040 752
CH4 3.00E-03 100 0.61 0.03
N2O 6.00E-04 100 0.12 6.10E-03
NH3 0.80 100 0.53 0.03
CO2e 15,092 755
Notes:
Pollutant Emission Factors PTE Emissions
- SOX emission factor calculated per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC],
August 2018, Section 3), using the following equation. Emission factor calculated in units of lb/MMBtu and converted to lb/hp-hr using an average Brake-
Specific Fuel Consumption (BSFC) of 8089 Btu/hp-hr.
- Emission factors for PM10, PM2.5, NOX, CO and VOC and are from manufacturer. Engine is certified NSPS Subpart IIII Tier 2 compliant. The NSPS
incorporates EPA Tier 2 requirements of 40 CFR 89.112, Table 1. The particulate emission factor is for total PM. PM 10 and PM2.5 are subsets of total PM.
Assumed all PM is PM10 and all PM10 is PM2.5.
- Annual hours of operation based on 100 hours for non-emergency use per generator.
Attachment 2: PTE  Emission Calculations page 2 of 8
HAP Emission Calculations
lb/MMBtu lb/hp-hr lb/hr ton/yr
Acenaphthene 83-32-9
4.68E-06 1.25E-08 1.48E-04 7.41E-06
Acenaphthylene 208-96-8 9.23E-06 2.46E-08 2.92E-04 1.46E-05
Acetaldehyde 75-07-0
2.52E-05 6.72E-08 7.97E-04 3.98E-05
Acrolein 107-02-8 7.88E-06 2.10E-08 2.49E-04 1.24E-05
Anthracene 120-12-7 1.23E-06 3.28E-09 3.89E-05 1.94E-06
Benzo(a)anthracene 56-55-3
6.22E-07 1.66E-09 1.97E-05 9.84E-07
Benzene 71-43-2 7.76E-04 2.07E-06 0.02 1.23E-03
Benzo(a)pyrene 50-32-8
2.57E-07 6.85E-10 8.12E-06 4.06E-07
Benzo(b)fluoranthene 205-99-2 1.11E-06 2.96E-09 3.51E-05 1.75E-06
Benzo(g,h,l)perylene 191-24-2
5.56E-07 1.48E-09 1.75E-05 8.77E-07
Benzo(k)fluoranthene 207-08-9 2.18E-07 5.81E-10 6.89E-06 3.44E-07
Chrysene 218-01-9
1.53E-06 4.08E-09 4.84E-05 2.42E-06
Dibenz(a,h)anthracene 53-70-3 3.46E-07 9.22E-10 1.09E-05 5.46E-07
Fluoranthene 206-44-0
4.03E-06 1.07E-08 1.27E-04 6.34E-06
Fluorene 7782-41-4 1.28E-05 3.41E-08 4.04E-04 2.02E-05
Formaldehyde 50-00-0
7.89E-05 2.10E-07 2.49E-03 1.24E-04
Indeno(1,2,3-cd)pyrene 193-39-5 4.14E-07 1.10E-09 1.30E-05 6.52E-07
Naphthalene 91-20-3
1.30E-04 3.47E-07 4.11E-03 2.06E-04
Phenanthrene 85-01-8 4.08E-05 1.09E-07 1.29E-03 6.46E-05
Pyrene 129-00-0
3.71E-06 9.89E-09 1.17E-04 5.86E-06
- CO2, CH4, and N2O emission factors from Tables C-1 and C-2 of 40 CFR 98, Subpart C. Emissions calculated using the high heat value of 0.138 MMBtu/gal
from Table C-1 of 40 CFR 98, Subpart C and a fuel consumption at 100% load (from manufacturer spec sheet).
- NH3 emission factor from "Development and Selection of Ammonia Emission Factors," developed under EPA contract by Battye, Battye, Overcash and Fudge,
1994. Emissions calculated using a fuel consumption at 100% load (from manufacturer spec sheet).
- CO2e calculated using table A-1 "Global Warming Potentials" from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas
pollutant (CO2, CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Pollutant CAS #
Emission Factor PTE Emissions
S x 0.02 x D x (1/HV)
where,
- S = weight percent sulfur content of the fuel (0.0015%).
- 0.02 = conversion factor converting the weight percent to a weight fraction multiplied by the ratio of the molecular weight of SO 2 to the molecular weight
of sulfur.
- D = the density of the fuel (7.14 lb/gal).
- HV = the heating value of the fuel (0.137 MMBtu/gal).
Attachment 2: PTE  Emission Calculations page 3 of 8
lb/MMBtu lb/hp-hr lb/hr ton/yr
Toluene 108-88-3
2.81E-04 7.49E-07 8.88E-03 4.44E-04
Xylenes 1330-20-7 1.93E-04 5.15E-07 6.11E-03 3.05E-04
Total HAPs 0.05 2.49E-03
Notes:
- Emission factors in units of lb/MMBtu obtained from AP-42, Fifth Edition, Section 3.4, Tables 3.4-3 and 3.4-4 (dated 10/96).
- Emission factors in units of lb/hp-hr values from AFCEC. Values calculated using the ratio of the HAP to total VOC from AP-42. The ratio was then multiplied
by the most conservative AFCEC VOC value for emergency engines (0.0292 lb/MMBtu). [(AP-42 HAP emission factor / NMHC AP42) x 0.0292 = AFCEC HAP
emission factor]
Pollutant CAS #
Emission Factor PTE Emissions
Attachment 2: PTE  Emission Calculations page 4 of 8
Criteria Pollutant and Greenhouse Gas Emission Calculations - New Emergency Generator
The generator is EPA Tier 2 compliant, consistent with NSPS Subpart IIII requirements
Fuel consumption rate 175 gal/hr - per manufacturer technical data sheets
Engine rating 2,500 kW
2,202 kW (derated for altitude)
Maximum horsepower rating: 2,953 hp (derated for altitude)
Hours of
Operation
g//kW-hr lb/hp-hr kg/MMBtu lb/1,000 gal hr/yr lb/hr ton/yr
NOX + NMHC 6.4
NOX 1.03E-02 100 30.4 1.52
VOC 2.86E-04 100 0.84 0.04
CO 3.5 5.73E-03 100 16.9 0.85
SOX 1.26E-05 100 0.04 1.86E-03
PM10 0.20 3.31E-04 100 0.98 0.05
PM2.5 0.20 3.31E-04 100 0.98 0.05
CO2 73.96 100 3,944 197
CH4 3.00E-03 100 0.16 8.00E-03
N2O 6.00E-04 100 0.03 1.60E-03
NH3 0.80 100 0.14 7.01E-03
CO2e 3,958 198
Notes:
Pollutant Emission Factors PTE Emissions
- Engine is certified NSPS Subpart IIII Tier 2 compliant. The NSPS incorporates EPA Tier 2 requirements in 40 CFR Part 1039, Appendix I, Table 2 as
the applicable standards for this engine.
- Annual hours of operation based on 100 hours for non-emergency use.
- The EPA Tier 2 emission factor for NOX includes both NMHC and NOX. Per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force
Civil Engineer Center [AFCEC], July 2023, Section 3) a NO X emission factor is calculated using emission factors from AP-42, NSPS emission limits and the
following equation:
- Emission factors in g/kW-hr for NOX + NMHC, CO and PM10/PM2.5 are from NSPS Subpart IIII requirements. It is assumed that all PM is PM10 and all PM10 is
PM2.5. PM10 and PM2.5 are subsets of total PM.
Attachment 2: PTE  Emission Calculations page 5 of 8
HAP Emission Calculations
lb/MMBtu lb/hp-hr lb/hr ton/yr
Acenaphthene 83-32-9 4.68E-06 1.25E-08 3.69E-05 1.85E-06
Acenaphthylene 208-96-8 9.23E-06 2.46E-08 7.26E-05 3.63E-06
Acetaldehyde 75-07-0
2.52E-05 6.72E-08 1.98E-04 9.92E-06
Acrolein 107-02-8
7.88E-06 2.10E-08 6.20E-05 3.10E-06
- CO2, CH4, and N2O emission factors from Tables C-1 and C-2 of 40 CFR 98, Subpart C. Emissions calculated using the high heat value of 0.138 MMBtu/gal from
Table C-1 of 40 CFR 98, Subpart C and a fuel consumption at 100% load (from manufacturer spec sheet).
- NH3 emission factor from "Development and Selection of Ammonia Emission Factors," developed under EPA contract by Battye, Battye, Overcash and Fudge,
1994. Emissions calculated using a fuel consumption at 100% load (from manufacturer spec sheet).
- CO2e calculated using table A-1 "Global Warming Potentials" from 40 Code of Federal Regulations (CFR) Part 98. CO 2e is the sum of each greenhouse gas
pollutant (CO2, CH4 and N2O) multiplied by the global warming potential for each pollutant (CO2 = 1, CH4 = 25, N2O = 298).
Pollutant CAS #
Emission Factor PTE Emissions
- SOX emission factor calculated per Air Force guidance (Air Emissions Guide for Air Force Stationary Sources, Air Force Civil Engineer Center [AFCEC], August
2018, Section 3), using the following equation. Emission factor calculated in units of lb/MMBtu and converted to lb/hp-hr using an average Brake-Specific Fuel
Consumption (BSFC) of 8089 Btu/hp-hr.
S x 0.02 x D x (1/HV)
where,
- S = weight percent sulfur content of the fuel (0.0015%).
- 0.02 = conversion factor converting the weight percent to a weight fraction multiplied by the ratio of the molecular weight of SO 2 to the molecular weight of
sulfur.
- D = the density of the fuel (7.14 lb/gal).
- HV = the heating value of the fuel (0.137 MMBtu/gal).
NOX NSPS = [(NOX + NMHC) NSPS / NOX AP42 + NMHC AP42)] x NOX AP42
where,
- NOX NSPS = NOX emission factor using NSPS emission limits and NOX / NMHC ratio.
- (NOX + NMHC) NSPS = Maximum allowable combined NOX and NMHC emissions from NSPS IIII requirements.
- NOX AP42 = NOX emission factor from AP-42.
- NMHC AP42 = NMHC emission factor calculated using the VOC emission factor data from AP-42.
- NMHC AP42 emission factor calculated using the AP-42 emission factor for TOC and multiplying by hydrocarbon conversion factors (VOC/THC = 1.053,
NMHC/THC = 0.984, TOC/THC = 1.070) from Conversion Factors for Hydrocarbon Emission Components, EPA, Office of Transportation and Air Quality, July
2010. [(AP-42 TOC emission factor) x (0.984 NMHC/THC) / (1.070 TOC/THC) = NMHC emission factor]
- VOC emission factor calculated using (NOX + NMHC) NSPS, NOX NSPS and hydrocarbon conversion factors. [((NO X + NMHC) NSPS - NOX NSPS) x (1.053 VOC/THC)
/ (0.984 NMHC/THC) = VOC emission factor]
Attachment 2: PTE  Emission Calculations page 6 of 8
lb/MMBtu lb/hp-hr lb/hr ton/yr
Anthracene 120-12-7 1.23E-06 3.28E-09 9.69E-06 4.84E-07
Benzo(a)anthracene 56-55-3 6.22E-07 1.66E-09 4.90E-06 2.45E-07
Benzene 71-43-2
7.76E-04 2.07E-06 6.11E-03 3.06E-04
Benzo(a)pyrene 50-32-8 2.57E-07 6.85E-10 2.02E-06 1.01E-07
Benzo(b)fluoranthene 205-99-2
1.11E-06 2.96E-09 8.74E-06 4.37E-07
Benzo(g,h,l)perylene 191-24-2 5.56E-07 1.48E-09 4.37E-06 2.19E-07
Benzo(k)fluoranthene 207-08-9
2.18E-07 5.81E-10 1.72E-06 8.58E-08
Chrysene 218-01-9 1.53E-06 4.08E-09 1.20E-05 6.02E-07
Dibenz(a,h)anthracene 53-70-3
3.46E-07 9.22E-10 2.72E-06 1.36E-07
Fluoranthene 206-44-0 4.03E-06 1.07E-08 3.16E-05 1.58E-06
Fluorene 7782-41-4
1.28E-05 3.41E-08 1.01E-04 5.03E-06
Formaldehyde 50-00-0 7.89E-05 2.10E-07 6.20E-04 3.10E-05
Indeno(1,2,3-cd)pyrene 193-39-5
4.14E-07 1.10E-09 3.25E-06 1.62E-07
Naphthalene 91-20-3 1.30E-04 3.47E-07 1.02E-03 5.12E-05
Phenanthrene 85-01-8
4.08E-05 1.09E-07 3.22E-04 1.61E-05
Pyrene 129-00-0 3.71E-06 9.89E-09 2.92E-05 1.46E-06
Toluene 108-88-3
2.81E-04 7.49E-07 2.21E-03 1.11E-04
Xylenes 1330-20-7 1.93E-04 5.15E-07 1.52E-03 7.60E-05
Total HAPs 0.01 6.20E-04
Notes:
- Emission factors in units of lb/MMBtu obtained from AP-42, Fifth Edition, Section 3.4, Tables 3.4-3 and 3.4-4 (dated 10/96).
- Emission factors in units of lb/hp-hr values from AFCEC. Values calculated using the ratio of the HAP to total VOC from AP-42. The ratio was then multiplied by
the most conservative AFCEC VOC value for emergency engines (0.0292 lb/MMBtu). [(AP-42 HAP emission factor / NMHC AP42) x 0.0292 = AFCEC HAP
emission factor]
Pollutant CAS #
Emission Factor PTE Emissions
Attachment 2: PTE  Emission Calculations page 7 of 8
HAP Modeling Threshold Evaluation
Hourly
Emissions
lb/hr
Benzene 71-43-2 Chronic 0.123 1.60 0.20 6.11E-03 No
Toluene 108-88-3 Chronic 0.123 75.36 9.27 2.21E-03 No
Xylenes 1330-20-7 Chronic 0.123 434 53.41 1.52E-03 No
Formaldehyde 50-00-0 Acute 0.092 0.37 0.03 6.20E-04 No
Acetaldehyde 75-07-0 Acute 0.092 45.04 4.14 1.98E-04 No
Acrolein 107-02-8 Acute 0.092 0.23 0.02 6.20E-05 No
Naphthalene 91-20-3 Chronic 0.123 52.43 6.45 1.02E-03 No
Acenaphthylene 208-96-8 Not Listed - - - 7.26E-05 -
Acenaphthene 83-32-9 Not Listed - - - 3.69E-05 -
Fluorene 7782-41-4 Chronic 0.123 1.55 0.19 1.01E-04 No
Phenanthrene 85-01-8 Not Listed - - - 3.22E-04 -
Anthracene 120-12-7 Not Listed - - - 9.69E-06 -
Fluoranthene 206-44-0 Not Listed - - - 3.16E-05 -
Pyrene 129-00-0 Not Listed - - - 2.92E-05 -
Benzo(a)anthracene 56-55-3 Carcinogenic 0.041 No TLV - 4.90E-06 -
Chrysene 218-01-9 Carcinogenic 0.041 No TLV - 1.20E-05 -
Benzo(b)fluoranthene 205-99-2 Carcinogenic 0.041 No TLV - 8.74E-06 -
Benzo(k)fluoranthene 207-08-9 Not Listed - - - 1.72E-06 -
Benzo(a)pyrene 50-32-8 Carcinogenic 0.041 No TLV - 2.02E-06 -
Indeno(1,2,3-cd)pyrene 193-39-5 Not Listed - - - 3.25E-06 -
Dibenz(a,h)anthracene 53-70-3 Not Listed - - - 2.72E-06 -
Benzo(g,h,i)perylene 191-24-2 Not Listed - - - 4.37E-06 -
4 Emission threshold value (ETV) calculated by multiplying the ETF by the TLV for each pollutant.
ETV 4
(lb/hr)
ETV
Exceedance
?
2 Emission threshold factor (ETF) values from Table 2 of R307-410-5. The distance from the location of the generators to the property boundary conservatively
assumed to be between 51 - 100 meters. It is assumed the release point is vertically restricted (release of an air contaminant through a stack or opening whose flow is
directed in a downward or horizontal direction due to the alignment of the opening or a physical obstruction placed beyond the opening, or at a height which is less
than 1.3 times the height of an adjacent building or structure, as measured from ground level).
1 For benzene and formaldehyde, value from R307-410-5. For all other pollutants, value from American Conference of Government Industrial Hygienists (ACGIH)
Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices (2016).
3 Threshold limit value (TLV) from ACGIH Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices (2016). TLV
calculated by multiplying the time-weighted average, short-term exposure limit, or ceiling value by the gram molecular weight of the pollutant and dividing by 24.45.
Pollutant CAS #
Acute /
Chronic /
Carcinogenic 1
ETF 2
(lb-m3 /
mg-hr)
TLV 3
(mg/m3)
Attachment 2: PTE  Emission Calculations page 8 of 8
Attachment 3: BACT Determination
To evaluate the appropriate best available control technology (BACT) for the proposed
diesel-fired emergency engine, 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 for diesel-
fired emergency generators were reviewed. The following is a list of control technologies
identified.
1) EPA’s RBLC was reviewed to determine EPA BACT decisions for diesel-fired internal
combustion compression ignition engine with size ratings near the new engine rating of
2,202 kW (process type code 17.110). These BACT determinations are summarized in
the following table.
RBCL
ID
Unit Size
(kW) NOX Control Determination
LA-0317 1,750 Comply with 40 CFR 60 Subpart IIII and 40 CFR 63 Subpart ZZZZ
LA-0308 2,000 Good combustion and maintenance practices and compliance with
NSPS 40 CFR 60 Subpart IIII
MI-0423 2,179 Good combustion practices and meeting NSPS IIII requirements
MD-0042 2,250 Limit on operating hours, use of ultra-low sulfur fuel and good
combustion practices
OH-0352 2,250 Purchase engine certified to the standards in NSPS Subpart IIII
LA-0313 1,923
Compliance with 40 CFR 63 Subpart ZZZZ and NSPS 40 CFR 60
Subpart IIII, good combustion practices. use of ultra-low sulfur diesel
fuel
LA-0288 2,000
Comply with 40 CFR 60 Subpart IIII; operate the engine in
accordance with the engine manufacturer’s instructions and/or written
procedures designed to maximize combustion efficiency and minimize
fuel usage
LA-0296 2,000
Compliance with 40 CFR 60 Subpart IIII; operating the engine in
accordance with the engine manufacturer’s instructions and/or written
procedures (consistent with safe operation) designed to maximize
combustion efficiency and minimize fuel usage
LA-0309 2,179 Comply with 40 CFR 60 Subpart IIII
LA-0316 2,500 Comply with 40 CFR 60 Subpart IIII

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.
Attachment 3: BACT Determination

3) Use of Low-Sulfur Fuel (0.05%): Use of low-sulfur diesel fuel reduces SOX emissions
and is considered BACT for diesel-fired emergency engines.

4) 40 CFR Part 60 Subpart IIII 'Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines' requires owners and operators of non-emergency
and emergency affected engines to comply with emission standards (Tier standards)
based on engine model year, maximum engine power, engine displacement and use
(emergency, non-emergency). The Tier standards are emission limits for PM, CO and
NMHC + NOx or NOx and NMHC. The subpart requires proper operation and
maintenance, in accordance with the manufacturer, to ensure affected emission units
achieve the applicable Tier standards over the entire life of the engine. The subpart
requires affected emission units with a displacement of less than 30 liters per cylinder to
comply with fuel sulfur limitations: (1) fuel sulfur content no greater than 15 ppm
(0.0015 percent) by weight and (2) a minimum cetane index of 40 or a maximum
aromatic content of 35 volume percent.

5) Limited Hours of Operation: 40 CFR Part 60 Subpart IIII 'Standards of Performance for
Stationary Compression Ignition Internal Combustion Engines' limits the operation for
readiness (maintenance and testing) to 100 hours annually for emergency generators.
Limiting the hours of operation for the equipment limits emissions of all pollutants
released from the emergency generator.

6) 40 CFR Part 63 Subpart ZZZZ 'National Emission Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines' requires owners
and operators of non-emergency and emergency affected engines to at all times operate
and maintain any affected source in a manner consistent with safety and good air
pollution control practices for minimizing emissions.

7) Selective Catalyst Reduction (SCR): Is a combination of engineered components
designed to reduce the amount of NOx in a turbine or engine exhaust stream. A form of
ammonia is injected in front of a catalyst to reduce the NOx. Nitrogen oxides are formed
when the oxygen and nitrogen in the air react with each other during combustion. High
temperatures and excess oxygen (more than is needed to burn the fuel) favor the
formation of nitrogen oxides. SCR systems are installed to reduce NOx levels in the
exhaust gas stream from the engine. SCR systems have the capability of reducing both
NO and NO2 in the gas stream by injecting an ammonia reagent ahead of the catalyst. In
addition to NOx control, SCR systems with an oxidation catalyst can also reduce CO
emissions.
For SCR systems to function effectively, exhaust temperatures must be high enough
(200°C to 500°C) to enable catalyst activation. SCR control efficiencies are relatively
low during the first 20 to 30 minutes after engine start up, especially during maintenance
and testing. There are also complications controlling the excess ammonia (ammonia slip)
Attachment 3: BACT Determination
from SCR use. SCR is anticipated to have relatively low combustion efficiency during
maintenance and testing, SCR is not considered technically feasible for emergency units.

All of the technologies listed above for control of emissions from diesel-fired emergency
generators are technically feasible. Based on the review of control technologies considered
BACT for diesel-fired emergency engines, Hill AFB has determined the following meets BACT
requirements:
• Good combustion, maintenance and operating practices
• Use of low-sulfur diesel fuel
• Compliance with applicable NSPS IIII requirements
o Use of a tier certified engine
o Limit on hours of operation for maintenance and testing operations
• Compliance with applicable NESHAP ZZZZ requirements
SCR has not been determined to be BACT for the new diesel-fired engine as the engine is for
emergency use. In addition to the above BACT, the unit will be equipped with a turbocharger
and charge air cooler which help control air pollutant emissions.