DAQ-2025-002334

DAQE-AN124030013-25

{{$d1 }}

Jessica Gibbons
VR CPC Holding, Inc.
PO Box 39
Park City, UT 84060
[e-mail]

Dear Ms. Gibbons:

Re: Approval Order: Modification to Approval Order DAQE-AN124030012-23 to Update Equipment
List and Correct Emission Calculations
Project Number: N124030013

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
29, 2024. VR CPC Holding, Inc. - dba Park City Mountain Resort must comply with the requirements of
this AO, all applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Lucia Mason, 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:LM:jg

cc: Summit County Public Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 25, 2025

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-AN124030013-25
Modification to Approval Order DAQE-AN124030012-23 to
Update Equipment List and Correct
Emission Calculations

Prepared By
Lucia Mason, Engineer
[phone]
[e-mail]

Issued to
VR CPC Holding, Inc. - dba Park City Mountain Resort

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

April 25, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN124030013-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
VR CPC Holding, Inc. VR CPC Holding, Inc. - dba Park City Mountain Resort

Mailing Address Physical Address
PO Box 39 1310 Lowell Avenue
Park City, UT 84060 Park City, UT 84060

Source Contact UTM Coordinates
Name: Jessica Gibbons 452,933 m Easting
Phone: [phone],503,939 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 7999 (Amusement & Recreation Services, NEC)

SOURCE INFORMATION
General Description
VR CPC Holdings, Inc., - dba Park City Mountain Resort (Park City Mountain), operates and maintains a
ski resort located in Park City, Summit County. The company operates natural gas-fired boilers and
heaters, gasoline/diesel-fired emergency engines, a used oil burner, gasoline/diesel fuel dispensing
stations, and abrasive blasting and degreasing operations.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Summit County
Airs Source Size: B

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
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities
DAQE-AN124030013-25
Page 4

Project Description
Park City Mountain is requesting to remove five (5), add nine (9), and move one (1) emergency engine.
Engine details are listed below:

1) Removal of one (1) secondary gasoline emergency engine at C16 Eaglet (28 hp)
2) Removal of one (1) secondary gasoline engine at Peak 5 (230 hp) to be replaced by one already
permitted secondary diesel emergency engine (174 hp)
3) Removal of one (1) main diesel emergency engine at CO4 Payday (564 hp) to be replaced by one (1)
T2 main diesel emergency engine (800 hp)
4) Removal of one (1) main diesel engine at C12 Bonanza (588 hp) to be replaced by one (1) T2 main
diesel emergency engine (800 hp)
5) Removal of one (1) main diesel emergency engine at C15 Silverlode (750 hp) to be replaced by one (1)
T2 main diesel emergency engine (800 hp)
6) Addition of one (1) T2 secondary diesel emergency engine at High Meadow 2 (66 hp)
7) Addition of one (1) T3 secondary diesel emergency engine at Red Pine Gondola (152 hp)
8) Addition of one (1) T3 main diesel emergency engine at Cabriolet (275 hp)
9) Addition of one (1) T3 secondary diesel emergency engine at Cabriolet (100 hp)
10) Addition of one (1) T3 main diesel emergency engine at Over and Out (121 hp)
11) Addition of one (1) T4I secondary diesel emergency engine at Over and Out (50 hp)

This updated permit also corrects the following errors made in past permit modifications:

2016 Modification:
- An engine was permitted at 174 hp instead of its manufacture max rating of 177hp
2017 Modification:
- An engine's emissions were subtracted from the site's PTE using incorrect operating hours
- CO2e emissions from the addition of a used fuel oil heater were not included in the site's PTE
2019 Modification:
- A primary engine was incorrectly permitted as a secondary engine
2023 Amendment:
- Emissions from a removed 7 MMBtu/hr boiler were calculated using incorrect operating hours

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)
CO2 Equivalent -1770.87 7569.13
Carbon Monoxide -2.04 10.45
Nitrogen Oxides -3.38 23.88
Particulate Matter - PM10 -0.33 1.94
Particulate Matter - PM2.5 -0.33 1.94
Sulfur Oxides 0.85 2.22
Volatile Organic Compounds -0.39 3.44

DAQE-AN124030013-25
Page 5

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 3 5
Benzene (Including Benzene From Gasoline) (CAS #71432) 2 10
Formaldehyde (CAS #50000) -2 15
Generic HAPs (CAS #GHAPS) -12 3
Hexane (CAS #110543) -59 190
Naphthalene (CAS #91203) 0 1
Toluene (CAS #108883) 0 4
Xylenes (Isomers And Mixture) (CAS #1330207) 1 3
Change (TPY) Total (TPY)
Total HAPs -0.03 0.12

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 two-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 two (2) 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]

DAQE-AN124030013-25
Page 6

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 VR CPC Holdings - dba Park City Mountain Resort Ski Resort
II.A.2 Main Emergency Generator Engines*
Quantity: Twenty-five (25); new: five (5)
Fuel: Diesel
Cumulative site-wide rating: 13,054 hp
Maximum rating: 1,046 hp
Minimum rating: 121 hp
*Source refers to these as Auxiliary Engines

II.A.3 Secondary Emergency Generator Engines** Quantity: Twenty-nine (29); new: four (4) Fuel: Twenty-six (26) Diesel, new: four (4) Fuel: Three (3) Gasoline (all manufactured prior to 2009) Cumulative site-wide rating: 4,931 hp Maximum rating: 335 hp Minimum rating: 28 hp **Source refers to these as Evacuation & Tertiary Engines
II.A.4 Various Boilers & Heaters
Fuel: Natural Gas or Propane
Size: Less than 5 MMBtu/hr (each)

II.A.5 One (1) Used Oil Burner Fuel: Used Oil Size: 0.24 MMBtu/hr
II.A.6 Fuel Dispensing Stations
Locations: Two (2)
Various diesel and gasoline tanks at each location

II.A.7 Abrasive Blasting Operations Two (2) confined spaces equipped with filters
II.A.8 Degreasing Operations
Location: King Shop

DAQE-AN124030013-25
Page 7

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not exceed the following visible emissions limits from the listed
emission points:

A. All natural gas-fired equipment - 10% opacity

B. All other points - 20% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.2 Generator Engine Requirements
II.B.2.a The owner/operator shall use emergency generator engines for electricity-producing operation only during the periods when electric power from the public utilities is interrupted or during electric motor failures or failures of equipment attached to the motor output shafts for drive connections. The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

A. Engine identification

B. The date the emergency engine was used

C. The duration of operation, in hours

D. The reason for the emergency engine usage.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.b The owner/operator shall comply with all applicable provisions of 40 CFR 60, NSPS Subpart A (General Provisions), Section 60.1 to Section 60.18, and Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines), Section 60.4200 to Section 60.4219 for stationary diesel-fueled engines on site. The owner/operator shall operate the engines in accordance with the most current version of 40 CFR 60 applicable to this source. [40 CFR 60 Subpart A, 40 CFR 60 Subpart IIII]
DAQE-AN124030013-25
Page 8

II.B.2.c The owner/operator shall comply with all applicable provisions of 40 CFR 63, MACT Standards Subpart A (General Provisions), Section 63.1 to Section 63.16, and Subpart ZZZZ (NESHAPs for Stationary Reciprocating Internal Combustion Engines), Section 63.6580 to Section 63.6675, for stationary diesel engines on site. The owner/operator shall operate the engines in accordance with the most current version of 40 CFR 63 applicable to this source. [40 CFR 63 Subpart A, 40 CFR 63 Subpart ZZZZ] II.B.2.d The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the diesel-fired emergency generator engines. [R307-401-8]
II.B.2.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.2.e.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

II.B.3 Boiler Requirements
II.B.3.a The owner/operator shall use natural gas or propane as a fuel source in all boilers and hot water heaters on site. [R307-401-8]

II.B.4 Fuel Dispensing and Storage Requirements
II.B.4.a The owner/operator shall cover all open diesel and gasoline containers and fill pipes with gasketed seals when not in use. [40 CFR 63 Subpart CCCCCC, R307-401-8]

II.B.5 Degreasing Operations Requirements
II.B.5.a The owner/operator shall store VOC- and HAPs-containing materials and VOC- and/or HAPs-laden rags in covered containers (except when in use). [R307-401-8]

II.B.6 Used Oil Fuel Requirements
II.B.6.a The owner/operator shall not burn any used oil unless the used oil is on-specification used oil as defined in UAC R315-15. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN124030012-23 dated January 18, 2023 Is Derived From NOI dated August 29, 2024 Incorporates Additional Information dated September 10, 2024 Incorporates Additional Information dated October 3, 2024 Incorporates Additional Information dated October 15, 2024 Incorporates Additional Information dated October 16, 2024 Incorporates Additional Information dated October 21, 2024 Incorporates Additional Information dated October 22, 2024 Incorporates Additional Information dated December 11, 2024 Incorporates Additional Information dated January 3, 2025 Incorporates Additional Information dated February 4, 2025
DAQE-AN124030013-25
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-IN124030013-25

March 6, 2025

Jessica Gibbons
VR CPC Holding, Inc.
PO Box 39
Park City, UT 84060
[e-mail]

Dear Ms. Gibbons:

Re: Intent to Approve: Modification to Approval Order DAQE-AN124030012-23 to Update
Equipment List and Correct Emission Calculations
Project Number: N124030013

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, Lucia Mason, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Lucia Mason, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:LM:jg

cc: Summit County Public Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN124030013-25
Modification to Approval Order DAQE-AN124030012-23
to Update Equipment List and Correct
Emission Calculations

Prepared By
Lucia Mason, Engineer
[phone]
[e-mail]

Issued to
VR CPC Holding, Inc. - dba Park City Mountain Resort

Issued On
March 6, 2025

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

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............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ............................................................................................................................... 10

DAQE-IN124030013-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
VR CPC Holding, Inc. VR CPC Holding, Inc. - dba Park City Mountain Resort

Mailing Address Physical Address
PO Box 39 1310 Lowell Ave
Park City, UT 84060 Park City, UT 84060

Source Contact UTM Coordinates
Name: Jessica Gibbons 452,933 m Easting
Phone: [phone],503,939 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 7999 (Amusement & Recreation Services, NEC)

SOURCE INFORMATION
General Description
VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) operates and maintains a
ski resort located in Park City, Summit County. The company operates natural gas-fired boilers and
heaters, gasoline/diesel-fired emergency engines, a used oil burner, gasoline/diesel fuel dispensing
stations, and abrasive blasting and degreasing operations.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Summit County
Airs Source Size: B

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
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities
DAQE-IN124030013-25
Page 4

Project Description
Park City Mountain is requesting to remove five (5), add nine (9), and move one (1) emergency engine.
Engine details are listed below:

1) Removal of one (1) secondary gasoline emergency engine at C16 Eaglet (28 hp)
2) Removal of one (1) secondary gasoline engine at Peak 5 (230 hp)
To be replaced by one already permitted secondary diesel emergency engine (174 hp)
3) Removal of one (1) main diesel emergency engine at CO4 Payday (564 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
4) Removal of one (1) main diesel engine at C12 Bonanza (588 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
5) Removal of one (1) main diesel emergency engine at C15 Silverlode (750 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
6) Addition of one (1) T2 secondary diesel emergency engine at High Meadow 2 (66 hp)
7) Addition of one (1) T3 secondary diesel emergency engine at Red Pine Gondola (152 hp)
8) Addition of one (1) T3 main diesel emergency engine at Cabriolet (275 hp)
9) Addition of one (1) T3 secondary diesel emergency engine at Cabriolet (100 hp)
10) Addition of one (1) T3 main diesel emergency engine at Over and Out (121 hp)
11) Addition of one (1) T4I secondary diesel emergency engine at Over and Out (50 hp)

This permit also corrects the following errors made in past permit modifications:

2016 Modification:
- An engine was permitted at 174 hp instead of its manufacturer’s max rating of 177hp
2017 Modification:
- An engine's emissions were subtracted from the site's PTE using incorrect operating hours
- CO2e emissions from the addition of a used fuel oil heater were not included in the site's PTE
2019 Modification:
- A primary engine was incorrectly permitted as a secondary engine
2023 Amendment:
- Emissions from a removed 7 MMBtu/hr boiler were calculated using incorrect operating hours

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)
CO2 Equivalent -1770.87 7569.13
Carbon Monoxide -2.04 10.45
Nitrogen Oxides -3.38 23.88
Particulate Matter - PM10 -0.33 1.94
Particulate Matter - PM2.5 -0.33 1.94
Sulfur Oxides 0.85 2.22
Volatile Organic Compounds -0.39 3.44

DAQE-IN124030013-25
Page 5

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 3 5
Benzene (Including Benzene From Gasoline) (CAS #71432) 2 10
Formaldehyde (CAS #50000) -2 15
Generic HAPs (CAS #GHAPS) -12 3
Hexane (CAS #110543) -59 190
Naphthalene (CAS #91203) 0 1
Toluene (CAS #108883) 0 4
Xylenes (Isomers And Mixture) (CAS #1330207) 1 3
Change (TPY) Total (TPY)
Total HAPs -0.03 0.12

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 Summit County News on March 12, 2025. 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 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 two-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 two (2) years. [R307-401-8]
DAQE-IN124030013-25
Page 6

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT

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 VR CPC Holdings - dba Park City Mountain Resort Ski Resort
II.A.2 Main Emergency Generator Engines* Quantity: Twenty-five (25), new: five (5) Fuel: Diesel Cumulative site-wide rating: 13,054 hp Maximum rating: 1,046 hp Minimum rating: 121 hp *Source refers to these as Auxiliary Engines II.A.3 Secondary Emergency Generator Engines** Quantity: Twenty-nine (29), new: four (4) Fuel: Twenty-six (26) Diesel, new: four (4) Fuel: Three (3) Gasoline (all manufactured prior to 2009) Cumulative site-wide rating: 4,931 hp Maximum rating: 335 hp Minimum rating: 28 hp **Source refers to these as Evacuation & Tertiary Engines
II.A.4 Various Boilers & Heaters Fuel: Natural Gas or Propane Size: Less than 5 MMBtu/hr (each) II.A.5 One (1) Used Oil Burner
Fuel: Used Oil Size: 0.24 MMBtu/hr
DAQE-IN124030013-25
Page 7

II.A.6 Fuel Dispensing Stations Locations: Two (2) Various diesel and gasoline tanks at each location II.A.7 Abrasive Blasting Operations
Two (2) confined spaces equipped with filters
II.A.8 Degreasing Operations Location: King Shop

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 The owner/operator shall not exceed the following visible emissions limits from the listed emission points: A. All natural gas-fired equipment - 10% opacity B. All other points - 20% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Generator Engine Requirements
II.B.2.a The owner/operator shall use emergency generator engines for electricity-producing operation only during the periods when electric power from the public utilities is interrupted or during electric motor failures or failures of equipment attached to the motor output shafts for drive connections. The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. Engine identification B. The date the emergency engine was used C. The duration of operation, in hours D. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
DAQE-IN124030013-25
Page 8

II.B.2.b The owner/operator shall comply with all applicable provisions of 40 CFR 60, NSPS Subpart A (General Provisions), Section 60.1 to Section 60.18, and Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines), Section 60.4200 to Section 60.4219 for stationary diesel-fueled engines on site. The owner/operator shall operate the engines in accordance with the most current version of 40 CFR 60 applicable to this source. [40 CFR 60 Subpart A, 40 CFR 60 Subpart IIII] II.B.2.c The owner/operator shall comply with all applicable provisions of 40 CFR 63, MACT Standards
Subpart A (General Provisions), Section 63.1 to Section 63.16, and Subpart ZZZZ (NESHAPs for Stationary Reciprocating Internal Combustion Engines), Section 63.6580 to Section 63.6675, for stationary diesel engines on site.
The owner/operator shall operate the engines in accordance with the most current version of 40
CFR 63 applicable to this source.
[40 CFR 63 Subpart A, 40 CFR 63 Subpart ZZZZ]

II.B.2.d The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the diesel-fired emergency generator engines. [R307-401-8]
II.B.2.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.e.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
II.B.3 Boiler Requirements
II.B.3.a The owner/operator shall use natural gas or propane as a fuel source in all boilers and hot water heaters on site. [R307-401-8]
II.B.4 Fuel Dispensing and Storage Requirements
II.B.4.a The owner/operator shall cover all open diesel and gasoline containers and fill pipes with gasketed seals when not in use. [40 CFR 63 Subpart CCCCCC, R307-401-8]
II.B.5 Degreasing Operations Requirements
II.B.5.a The owner/operator shall store VOC- and HAP-containing materials and VOC- and/or HAP-laden rags in covered containers (except when in use). [R307-401-8]
II.B.6 Used Oil Fuel Requirements
II.B.6.a The owner/operator shall not burn any used oil unless the used oil is on-specification used oil as defined in UAC R315-15. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN124030012-23 dated January 18, 2023 Is Derived From NOI dated August 29, 2024 Incorporates Additional Information dated September 10, 2024 Incorporates Additional Information dated October 3, 2024
DAQE-IN124030013-25
Page 9
Incorporates Additional Information dated October 15, 2024
Incorporates Additional Information dated October 16, 2024 Incorporates Additional Information dated October 16, 2024 Incorporates Additional Information dated October 21, 2024
Incorporates Additional Information dated December 11, 2024 Incorporates Additional Information dated October 22, 2024 Incorporates Additional Information dated January 3, 2025
Incorporates Additional Information dated February 4, 2025

DAQE-IN124030013-25
Page 10

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-NN124030013-25

March 6, 2025

Summit County News
Legal Advertising Dept.
P.O. Box 128
Heber City, UT 84032

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Summit County News on
March 12, 2025.

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: Mountainland Association of Governments
cc: Summit 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

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN124030013-25
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: VR CPC Holding, Inc.
Location: VR CPC Holding, Inc. - dba Park City Mountain Resort – 1310 Lowell Ave,
Park City, UT
Project Description: VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain)
operates and maintains a ski resort located in Park City, Summit County. The
company operates natural gas-fired boilers and heaters, gasoline/diesel-fired
emergency engines, a used oil burner, gasoline/diesel fuel dispensing stations,
and abrasive blasting and degreasing operations. Park City Mountain is
requesting to remove five (5), add nine (9), and move one (1) emergency engines.
In addition to the engine alterations, this modification will correct several errors
that were made in past approval orders.

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 April 11, 2025, 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: March 12, 2025

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

Jeree Greenwood <[e-mail]>
Legal Notice to be published March 12, 2025
3 messages
Jeree Greenwood <[e-mail]>Thu, Mar 6, 2025 at 8:00 AM
To: Summit County News <[e-mail]>
Please publish the following notice on March 12, 2025. Please also forward to Utahlegals.com
If you can, please reply to this email for my confirmation.
Thank you,
Jeree
--
Jeree Greenwood
Office Technician II | Minor NSR Section
M: [phone]
airquality.utah.gov
-
DAQE-NN124030013-25.pdf
321K
Laurie Wynn <[e-mail]>Sun, Mar 9, 2025 at 9:18 PM
To: Jeree Greenwood <[e-mail]>
Got it - thanks. Please call our front office with a credit card for payment
Best,
Laurie
[Quoted text hidden]
Jeree Greenwood <[e-mail]>Mon, Mar 10, 2025 at 9:06 AM
To: Christine Wilson <[e-mail]>
Good Morning,
It appears they need someone with a credit card to call the office.
Here is the number: [phone].
Thanks
[Quoted text hidden]
3/10/25, 9:06 AM State of Utah Mail - Legal Notice to be published March 12, 2025
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r5835332483807174687&simpl=msg-a:r-768635582706219…1/1
Summit County News
Publication Name:
Summit County News
Publication URL:
Publication City and State:
Coalville, UT
Publication County:
Summit
Notice Popular Keyword Category:
Notice Keywords:
VR
Notice Authentication Number:
202503131431194208957
2892905420
Notice URL:
Back
Notice Publish Date:
Wednesday, March 12, 2025
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: VR CPC Holding, Inc.
Location: VR CPC Holding, Inc. - dba Park City Mountain Resort – 1310 Lowell Ave,
Park City, UT
Project Description: VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) operates and maintains a ski resort located
in Park City, Summit County. The company operates natural gas-fired boilers and heaters, gasoline/diesel-fired
emergency engines, a used oil burner, gasoline/diesel fuel dispensing stations,
and abrasive blasting and degreasing operations. Park City Mountain is requesting to remove five (5), add nine (9), and move one (1)
emergency engines.
In addition to the engine alterations, this modification will correct several errors
that were made in past approval orders.
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 April 11, 2025, 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: March 12, 2025
Published in The Summit County News March 12, 2025.
Back
DAQE-

RN124030013 March 3, 2025 Jessica Gibbons
VR CPC Holding, Inc. - dba Park City Mountain Resort PO Box 39 Park City, UT 84060
[e-mail] Dear Jessica Gibbons,
Re: Engineer Review: Modification to Approval Order (AO) DAQE-AN124030012-23 to Update Equipment List and Correct Emission Calculations Project Number: N124030013 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. VR CPC Holding, Inc. - dba Park City Mountain Resort should complete this review within 10 business days of receipt. VR CPC Holding, Inc. - dba Park City Mountain Resort should contact Lucia Mason at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your
concerns, please email Lucia Mason at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If VR CPC Holding, Inc. - dba Park City Mountain Resort does not respond to this letter within 10 business days, the project will move forward without source concurrence. If VR CPC Holding, Inc. - dba Park City Mountain Resort has concerns that cannot be resolved and the project becomes stagnant, 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
Tim Davis Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N124030013 Owner Name VR CPC Holding, Inc. - dba Park City Mountain Resort Mailing Address PO Box 39
Park City, UT, 84060 Source Name VR CPC Holding, Inc. - dba Park City Mountain Resort
Source Location 1310 Lowell Ave Park City, UT 84060
UTM Projection 452,933 m Easting, 4,503,939 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 7999 (Amusement & Recreation Services, NEC) Source Contact Jessica Gibbons Phone Number [phone] Email [e-mail] Billing Contact Jessica Gibbons Phone Number [phone]
Email [e-mail] Project Engineer Lucia Mason, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted August 29, 2024 Date of Accepted Application October 22, 2024

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 2
SOURCE DESCRIPTION General Description
VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) operates and maintains a ski resort located in Park City, Summit County. The company operates natural gas-fired boilers and heaters, gasoline/diesel-fired emergency engines, a used oil burner,
gasoline/diesel fuel dispensing stations, and abrasive blasting and degreasing operations. NSR Classification: Minor Modification at Minor Source Source Classification Located in Attainment Area Summit County Airs Source Size: B 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
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Project Proposal Modification to Approval Order (AO) DAQE-AN124030012-23 to Update Equipment List and Correct Emission Calculations
Project Description VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) is requesting to remove five (5), add nine (9), and move one (1) emergency engines. Engine details are listed below: - Removal of one (1) secondary gasoline emergency engine at C16 Eaglet (28 hp) - Removal of one (1) secondary gasoline engine at Peak 5 (230 hp)
To be replaced by one already permitted secondary diesel emergency engine (174 hp) - Removal of one (1) main diesel emergency engine at CO4 Payday (564 hp) To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Removal of one (1) main diesel engine at C12 Bonanza (588 hp) To be replaced by one (1) T2 main diesel emergency engine (800 hp) - Removal of one (1) main diesel emergency engine at C15 Silverlode (750 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp) - Addition of one (1) T2 secondary diesel emergency engine at High Meadow 2 (66 hp) - Addition of one (1) T3 secondary diesel emergency engine at Red Pine Gondola (152 hp)
- Addition of one (1) T3 main diesel emergency engine at Cabriolet (275 hp) - Addition of one (1) T3 secondary diesel emergency engine at Cabriolet (100 hp) - Addition of one (1) T3 main diesel emergency engine at Over and Out (121 hp) - Addition of one (1) T4I secondary diesel emergency engine at Over and Out (50 hp)

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 3
This permit updated also corrects the following errors made in past permit modifications:
2016 Modification: - An engine was permitted at 174 hp instead of its manufacture max rating of 177hp 2017 Modification: - An engine's emissions were subtracted from the site's PTE using incorrect operating hours - CO2e emissions from the addition of a used fuel oil heater were not included in the site's PTE 2019 Modification: - A primary engine was incorrectly permitted as a secondary engine 2023 Amendment: - Emissions from a removed 7 MMBtu/hr boiler were calculated using incorrect operating hours
EMISSION IMPACT ANALYSIS Park City Mountain does not exceed the modeling thresholds for criteria pollutants outlined in R307-410-4. The changes taking place in this modification are subject to 40 CFR 63 Subpart ZZZZ. Consequently, Park City Mountain is exempt from Hazardous Air Pollutant modeling as per R307-410-5. Therefore, no modeling is required. [Last updated February 20, 2025]

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 4
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) CO2 Equivalent -1770.87 7569.13 Carbon Monoxide -2.04 10.45
Nitrogen Oxides -3.38 23.88
Particulate Matter - PM10 -0.33 1.94
Particulate Matter - PM2.5 -0.33 1.94
Sulfur Oxides 0.85 2.22
Volatile Organic Compounds -0.39 3.44 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 3 5
Benzene (Including Benzene From Gasoline) (CAS #71432) 2 10
Formaldehyde (CAS #50000) -2 15
Generic HAPs (CAS #GHAPS) -12 3
Hexane (CAS #110543) -59 190 Naphthalene (CAS #91203) 0 1 Toluene (CAS #108883) 0 4
Xylenes (Isomers And Mixture) (CAS #1330207) 1 3
Change (TPY) Total (TPY)
Total HAPs -0.03 0.12
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 5
Review of BACT for New/Modified Emission Units 1. BACT review regarding New Emergency Engines
The source is installing nine (9) new emergency engines with the maximum hp listed below. The EPA Tier ratings for the new engines are the following: - Three (3) T2 Main Diesel Emergency Engine (800 hp) - One (1) T2 Secondary Diesel Emergency Engine at High Meadow 2 (66 hp) - One (1) T3 Secondary Diesel Emergency Engine at Red Pine Gondola (152 hp) - One (1) T3 Main Diesel Emergency Engine at Cabriolet (275 hp) - One (1) T3 Secondary Diesel Emergency Engine at Cabriolet (100 hp)
- One (1) T3 Main Diesel Emergency Engine at Over and Out (121 hp) - One (1) T4I Secondary Diesel Emergency Engine at Over and Out (50 hp) Emissions from the combined emergency engines are as follows: NOx: 1.84 tpy, CO: 0.20 tpy, PM: 0.03 tpy, SO2: 1.02 tpy, VOC: 0.11 tpy, HAP: 7.93 lbs/year Available control technology for diesel engines includes: 1. Add on control: Selective Catalytic Reduction (SCR)
2. Add on control: Diesel Oxidation Catalyst (DOC) 3. Tier 4 Final Engine 4. Tier 4 Intermediate Engine 5. Tier 3 Engine 6. Tier 2 Engine Available fuel control options include: 1. Ultra-low sulfur diesel fuel
Park City Mountain is limited in their engine options due to size constraints associated with ski lift terminals and the low temperature conditions. Tier 4 Final engines use diesel exhaust fluid (DEF) to reduce emissions. DEF has a freezing point of 12 degrees Fahrenheit and would freeze frequently at a ski resort resulting in maintenance concerns. Each emergency engine will not
exceed 100 hours of operation per year for maintenance and testing purposes. Due to the inconsistent and minimal emissions produced by the emergency engines during testing and maintenance, the cost to install higher tier engines or add on controls is considered cost
prohibitive.
For these reasons, the tier certifications listed above are considered BACT in conjunction with operating and maintaining the engines in accordance with manufacturer recommendations and operating each engine no more than 100 hours annually for maintenance checks and readiness testing.
Sulfur dioxide emissions occur when the sulfur in diesel fuel oxidizes during combustion. Park City Mountain will use ultra-low sulfur diesel fuel containing no more than 15 parts per million by weight of sulfur which is considered BACT. BACT is also maintaining visible emissions at or below 20% opacity.
[Last updated March 3, 2025]

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 6
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 two-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 two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 7
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 VR CPC Holdings - dba Park City Mountain Resort Ski Resort II.A.2 Main Emergency Generator Engines* Quantity: Twenty-five (25), new: five (5) Fuel: Diesel Cumulative site-wide rating: 13,054 hp Maximum rating: 1,046 hp Minimum rating: 121 hp *Source refers to these as Auxiliary Engines
II.A.3 Secondary Emergency Generator Engines** Quantity: Twenty-nine (29), new: four (4) Fuel: Twenty-six (26) Diesel, new: four (4) Fuel: Three (3) Gasoline (all manufactured prior to 2009) Cumulative site-wide rating: 4,931 hp Maximum rating: 335 hp Minimum rating: 28 hp **Source refers to these as Evacuation & Tertiary Engines II.A.4 Various Boilers & Heaters Fuel: Natural Gas or Propane Size: Less than 5 MMBtu/hr (each) II.A.5 One (1) Used Oil Burner Fuel: Used Oil
Size: 0.24 MMBtu/hr II.A.6 Fuel Dispensing Stations Locations: Two (2)
Various diesel and gasoline tanks at each location II.A.7 Abrasive Blasting Operations Two (2) confined spaces equipped with filters
II.A.8 Degreasing Operations
Location: King Shop

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 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
The owner/operator shall not exceed the following visible emissions limits from the listed
emission points: A. All natural gas-fired equipment - 10% opacity
B. All other points - 20% opacity
[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.2 Generator Engine Requirements II.B.2.a NEW The owner/operator shall use emergency generator engines for electricity-producing operation only during the periods when electric power from the public utilities is interrupted or during
electric motor failures or failures of equipment attached to the motor output shafts for drive connections. The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time
limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 NEW To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. Engine identification B. The date the emergency engine was used
C. The duration of operation, in hours
D. The reason for the emergency engine usage
[40 CFR 63 Subpart ZZZZ, R307-401-8]

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 9
II.B.2.b NEW The owner/operator shall comply with all applicable provisions of 40 CFR 60, NSPS Subpart A (General Provisions), Section 60.1 to Section 60.18, and Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines), Section
60.4200 to Section 60.4219 for stationary diesel fueled engines on site.
The owner/operator shall operate the engines in accordance with the most current version of 40 CFR 60 applicable to this source. [40 CFR 60 Subpart A, 40 CFR 60 Subpart IIII] II.B.2.c NEW The owner/operator shall comply with all applicable provisions of 40 CFR 63, MACT Standards Subpart A (General Provisions), Section 63.1 to Section 63.16, and Subpart ZZZZ (NESHAPs for Stationary Reciprocating Internal Combustion Engines), Section 63.6580 to Section 63.6675, for stationary diesel engines on site. The owner/operator shall operate the engines in accordance with the most current version of 40 CFR 63 applicable to this source. [40 CFR 63 Subpart A, 40 CFR 63 Subpart ZZZZ]
II.B.2.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the diesel-fired emergency generator engines. [R307-401-8]
II.B.2.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.e.1
NEW
To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

II.B.3 Boiler Requirements
II.B.3.a The owner/operator shall use natural gas or propane as a fuel source in all boilers and hot water heaters on site. [R307-401-8] II.B.4 Fuel Dispensing and Storage Requirements II.B.4.a The owner/operator shall cover all open diesel and gasoline containers and fill pipes with gasketed seals when not in use. [40 CFR 63 Subpart CCCCCC, R307-401-8]
II.B.5 Degreasing Operations Requirements
II.B.5.a NEW The owner/operator shall store VOC- and HAPs- containing materials and VOC- and/or HAPs- laden rags in covered containers (except when in use). [R307-401-8] II.B.6 Used Oil Fuel Requirements
II.B.6.a The owner/operator shall not burn any used oil unless the used oil is on-specification used oil as defined in UAC R315-15. [R307-401-8]

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 10
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN124030012-23 dated January 18, 2024
Is Derived From NOI dated August 29, 2024 Incorporates Additional Information dated September 10, 2024 Incorporates Additional Information dated October 3, 2024 Incorporates Additional Information dated October 15, 2024 Incorporates Additional Information dated October 16, 2024 Incorporates Additional Information dated October 16, 2024 Incorporates Additional Information dated October 21, 2024 Incorporates Additional Information dated December 11, 2024 Incorporates Additional Information dated October 22, 2024 Incorporates Additional Information dated January 3, 2025 Incorporates Additional Information dated February 4, 2025

REVIEWER COMMENTS 1. Comment regarding Modification Request:
VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) is requesting to remove, replace, move or add the following engines: - Removal of one (1) secondary gasoline emergency engine at C16 Eaglet (28 hp) - Removal of one (1) secondary gasoline engine at Peak 5 (230 hp) To be replaced by one already permitted secondary diesel emergency engine (174 hp)* - Removal of one (1) main diesel emergency engine at CO4 Payday (564 hp) To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Removal of one (1) main diesel engine at C12 Bonanza (588 hp) To be replaced by one (1) T2 main diesel emergency engine (800 hp) - Removal of one (1) main diesel emergency engine at C15 Silverlode (720 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp) - Addition of one (1) T2 secondary diesel emergency engine at High Meadow 2 (66 hp) - Addition of one (1) T3 secondary diesel emergency engine at Red Pine Gondola (152 hp)
- Addition of one (1) T3 main diesel emergency engine at Cabriolet (275 hp) - Addition of one (1) T3 secondary diesel emergency engine at Cabriolet (100 hp) - Addition of one (1) T3 main diesel emergency engine at Over and Out (121 hp)
- Addition of one (1) T4I secondary diesel emergency engine at Over and Out (50 hp) *This modification recalculates NOx, CO and PM emissions for this engine using more accurate emission factors.
These changes result in a decrease in all emissions except for SO2 which increases by 0.66 tpy.
Several errors made in previous permit iterations are being corrected through this modification as well. Except for the 0.66 tpy increase of SO2 resulting from the new engines, these changes account for emission increases shown in the Summary of Emissions. A summary of these corrections is listed below. More details are included in Comment #5 (Source Emission Correction Calculations and DAQ Acceptance).

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 11
2016 Modification: - An engine was permitted at 174 hp instead of its manufacture max rating of 177hp 2017 Modification: - An engine's emissions were subtracted from the site's PTE using incorrect operating hours - CO2e emissions from the addition of a used fuel oil heater were not included in the site's PTE 2019 Modification: - A primary engine was incorrectly permitted as a secondary engine 2023 Amendment: - Emissions from a removed 7 MMBtu/hr boiler were calculated using incorrect operating hours All contact information has been updated.
[Last updated March 3, 2025] 2. Comment regarding Source Calculations and DAQ Acceptance: Engines lose ~ 4% power per 1,000 ft of elevation. Thus, engine power was corrected for elevation using the following excel formula: Elevation adjusted HP = ROUND (HP at sea level - (HP at sea level * ROUNDDONW ((elevation of engine (ft) - 7500 (ft))/1,000,0) * 0.04),0) All engines: CO2: 40 CFR 98 Table C-1
CH4, NO2: 40 CFR 98 Table C-2 Global Warming Potentials: 40 CFR 98 Table A-1 NOTE: EPA's Nonroad Compression Ignition (NRCI) Engine data can be found in the source file ------------------------------------------------------------------------------------------------------------------------- Removed Main Engines: NOx: -6.30 tpy, CO: -1.37 tpy, PM: -0.41 tpy, SO2: -0.36 tpy, VOC: -0.46, HAP: -10.59 lb/year
One (1) Main Diesel Emergency Engine at CO4 Payday (564 hp, 100 hours/year)
NOx, CO, PM, SO2, VOC: AP-42, Table 3.3-1 HAP: AP-42 Table 3.3-2 One (1) Main Diesel Engine at C12 Bonanza (588 hp, 500 hours/year) NOx, CO, PM, SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2
One (1) Main Diesel Emergency Engine at C15 Silverlode (720 hp, 100 hours/year) NOx, CO, PM, SO2, VOC: AP-42, Table 3.4-1 HAP: AP-42 Table 3.4-3, 3.4-4 ------------------------------------------------------------------------------------------------------------------------- Added Main Engines:
NOx: 1.70 tpy, CO: 0.16 tpy, PM: 0.02 tpy, SO2: 0.99 tpy, VOC: 0.06, HAP: 6.93 lb/year Three (3) T2 Main Diesel Emergency Engines (800 hp, 100 hours/year) Elevations: 8,250 ft, 9,250 ft, 9,250 ft NOx, CO, PM, VOC: C18 800 hp Performance Data: DM7702
SO2: AP-42 Table 3.4-1

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 12
HAP: AP-42 Table 3.4-3 and 3.4-4 One (1) T3 Main Diesel Emergency Engine at Cabriolet (275 hp 100 hours/year) Elevation: 6,740 ft NOx, CO, PM: NCRI Certification Data Table Certificate# JPKXL04.4NL1-016 SO2, VOC: AP-42, Table 3.3-1 HAP: AP-42 Table 3.3-2
One (1) T3 Main Diesel Emergency Engine at Over and Out (121 hp, 100 hours/year) Elevation: 7,500 ft NOx, CO, PM: NCRI Certification Data Table Certificate# KCEXL0275AAG-046 SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2
------------------------------------------------------------------------------------------------------------------------- Removed Secondary Engines: NOx: -0.08 tpy, CO: -0.09 tpy, PM: -0.01 tpy, SO2: -0.01 tpy, VOC: -0.19 lb/year, HAP: 0 lb/year One (1) Secondary Gasoline Emergency Engine at C16 Eaglet (28 hp, 100 hours/year) NOx, CO, PM, SO2, VOC: AP-42 Table 3.3-1
One (1) Secondary Gasoline Engine at Peak 5 (230 hp) NOx, CO, PM, SO2, VOC: AP-42 Table 3.3-1
-------------------------------------------------------------------------------------------------------------------------
Added Secondary Engines: NOx 0.13: tpy, CO: 0.05 tpy, PM: 0.01 tpy, SO2: 0.04 tpy, VOC: 0.04, HAP: 1.00 lb/year One (1) T2 Secondary Diesel Emergency Engine at High Meadow 2 (66 hp, 100 hours/year) Elevation: 8,045 ft
NOx, CO, PM: 40 CFR Appendix I to Part 1039 - Summary of Previous Emission Standards SO2, VOC: AP-42 Table 3.3-1 HAP: AP-42 Table 3.3-2
One (1) T3 Secondary Diesel Emergency Engine at Red Pine Gondola (152 hp, 100 hours/year) Elevation: 8,520 ft NOx, CO, PM: NCRI Certification Data Table Certificate# LCEXL0275AAG-024 SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2
One (1) T3 Secondary Diesel Emergency Engine at Cabriolet (100 hp, 100 hours/year) Elevation: 6,500 ft NOx, CO, PM: NCRI Certification Data Table Certificate# JPKXL04.4NL1-016 SO2, VOC: AP-42, Table 3.3-1 HAP: AP-42 Table 3.3-2 One (1) T4I Secondary Diesel Emergency Engine at Over and Out (50 hp, 100 hours/year) Elevation: 7,500 ft NOx, CO, PM: NCRI Certification Data Table Certificate# GDICL01.8LEA-007 SO2, VOC: AP-42, Table 3.3-1 HAP: AP-42 Table 3.3-2

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 13
[Last updated February 20, 2025]
3. Comment regarding Source Emission Correction Calculations and DAQ Acceptance: 2016 Modification Errors: In 2016, Park City merged with an adjacent resort and all emissions were combined into a site-wide
emissions spreadsheet. In 2016, the secondary diesel emergency engine located at Cabriolet was incorrectly permitted at 177 hp when the manufacture max power rating was174 hp (documentation is in the source file). This engine was recently relocated and is now permitted at Peak 5. This
modification corrects the engine's power rating and recalculates the engine's NOx, CO, PM, and HAP emissions using more accurate emission factors. NOx: -0.18 tpy, CO: -0.05 tpy, PM: -0.02 tpy, SO2: 0 tpy, VOC: 0 tpy, CO2e: -0.17 tpy, HAP: 0.48
lb/year
One (1) Relocated Secondary Gasoline Engine Moved from Cabriolet (174 hp, 100 hours/year) Elevation: 6,500 NOx, CO, PM, SO2, VOC: AP-42 Table 3.3-1
HAP: AP-42 Table 3.3-2 One (1) Relocated Secondary Diesel Emergency Engine Moved to Peak 5 (174 hp, 100 hours/year) Elevation: 8,325 ft
NOx, CO, PM: Archived NCRI Certification Data Table Certificate# CEX-NR6-00-10 SO2, VOC: AP-42, Table 3.3-1 HAP: AP-42 Table 3.3-2
------------------------------------------------------------------------------------------------------------------------- 2017 Modification Errors: The 2017 AO modification updated several engine sizes and added a waste fuel oil heater. As part of the engine calculations, emissions from the C12 Bonanza main engine (diesel, 488 hp) were subtracted at 500 annual hours of operation when the engine emissions were calculated at 100 hours per year when the engine emissions for the engine were originally calculated in 2016. CO2e emissions for the waste fuel oil heater were also left out of the summary of emissions. These changes
have been corrected using the emission factors and parameters listed below.
NOx: 3.06 tpy, CO: 0.66 tpy, PM: 0.22 tpy, SO2: 0.20 tpy, VOC: 0.24 tpy, CO2e: 275 tpy, HAP: 0 lb/year
One (1) Main Diesel Engine at C12 Bonanza (588 hp) NOx, CO, PM, SO2, VOC: AP-42, Table 3.3-1 HAP: AP-42 Table 3.3-2 CO2: 40 CFR 98 Table C-1 CH4, NO2: 40 CFR 98 Table C-2 Global Warming Potentials: 40 CFR 98 Table A-1 One (1) Used Fuel Oil Heater (rated heat input: 1.68 gal/hr, 8,760 hours/year) CO2e: AP-42, Table 1.11-3 - Small Boilers ≤.25 MMBtu/hr ------------------------------------------------------------------------------------------------------------------------- 2019 Modification Errors:
The 2019 modification removed one (1) gasoline fired emergency generator and added the High Meadow diesel fired emergency generator (site rated hp: 202). The added emergency generator was

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 14
added to the 2019 AO as a secondary engine when it should have been listed as a main engine. The change is reflected in Equipment IDs II.A.2 and II.A.3.
------------------------------------------------------------------------------------------------------------------------- 2023 Administrative Amendment Errors: The 2023 modification replaced one (1) 7 MMBtu/hr boiler with three (3) 2 MMBtu/hour boilers. The 7 MMBtu/hr boiler emissions were originally based on 8,760 hours of operation per year in
2016. In the 2023 modification, the 7 MMBtu/hr boiler emissions were subtracted using 3,960 annual hours of operation. This modification corrects this error. The emission corrections below were calculated using the following emission factors and parameters.
NOx: -1.65 tpy, CO: -1.39 tpy, PM: -0.13 tpy, SO2: -0.01 tpy, VOC: -0.09 tpy, CO2e: -1965 tpy, HAP: -0.03 lb/year One (1) Natural Gas Boiler (7 MMBtu/hr) NOx, CO, PM, SO2, VOC: AP-42,Table 1.4-1, 1.4-2 HAP: AP-42 Table 1.4-3 CO2, CH4, NO2:AP-42 Table 1.4-2 Global Warming Potentials: 40 CFR 98 Table A-1
[Last updated February 20, 2025] 4. Comment regarding Updates to Approved Equipment: Equipment ID II.A.2 in AO DAQE-AN124030012-23 specifies a cumulative site-wide rating of
11,992 hp for twenty-three (23) main diesel-fired emergency generator engines. This modification will remove three (3) and add five (5) main emergency engines. This modification will also correct the High Meadow engine that was incorrectly listed as a secondary engine in 2017. Equipment ID
II.A.2 has been updated accordingly to twenty-six (26) diesel-fired emergency generators, bringing the cumulative site-wide rating to 13,054 hp*. Equipment ID II.A.3 in AO DAQE-AN124030012-23 specifies a cumulative site-wide rating of 5,032 hp for twenty-seven (27) secondary emergency generator engines. Twenty-two (22) of the engines were specified as diesel and five (5) were listed as gasoline. Park City Mountain has requested to remove two (2) secondary gasoline engines and add four (4) secondary diesel engines. This modification also accounts for the incorrectly permitted High Meadow and relocated Peak 5
engine. The Equipment ID II.A.3 now lists twenty-five (25) diesel engines, three (3) gasoline engines, and twenty-eight (28) cumulative secondary engines with a site-wide rating of 4,934 hp*. *Site-wide ratings are based on site rated hp not the engine's maximum hp as listed in other engineering review comments. [Last updated February 20, 2025]
5. Comment regarding Summary of Emissions: Acrolein emissions are less than one lb/year. These emissions have been combined with "generic HAPs." [Last updated February 20, 2025]
6. Comment regarding Federal Standards: NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. This standard applies to the diesel-fired engines on site. NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 15
Combustion Engines. The three (3) gasoline-fired engines were all manufactured prior to 2009; therefore, this standard does not apply to these engines.
MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion Engines. This standard applies to the generator engines on site.
MACT (Part 63), CCCCCC: NESHAP for Source Category: Gasoline Dispensing Facilities. This standard applies to the gasoline dispensing stations on site. [Last updated February 20, 2025] 7. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants 4. Any Title IV affected source
This facility is not a major source and is not a Title IV source; however, the facility is subject to 40 CFR 60 NSPS Subparts A and IIII, and 40 CFR 63 MACT Subparts A, ZZZZ, and CCCCCC regulations. However, Title V does not apply because NSPS Subpart IIII, and MACT Subparts ZZZZ and CCCCCC exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility.
[Last updated February 20, 2025]

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort March 3, 2025 Page 16
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-

RN124030013
March 3, 2025

Jessica Gibbons
VR CPC Holding, Inc. - dba Park City Mountain Resort
PO Box 39
Park City, UT 84060
[e-mail]

Dear Jessica Gibbons,

Re: Engineer Review: Modification to Approval Order (AO) DAQE-AN124030012-23 to Update
Equipment List and Correct Emission Calculations
Project Number: N124030013

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. VR CPC Holding,
Inc. - dba Park City Mountain Resort should complete this review within 10 business days of receipt.

VR CPC Holding, Inc. - dba Park City Mountain Resort should contact Lucia Mason at [phone]
if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your
concerns, please email Lucia Mason at [e-mail] the signed cover letter. Upon receipt of the
signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion
of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO)
for signature by the DAQ Director.

If VR CPC Holding, Inc. - dba Park City Mountain Resort does not respond to this letter within 10
business days, the project will move forward without source concurrence. If VR CPC Holding, Inc. - dba
Park City Mountain Resort has concerns that cannot be resolved and the project becomes stagnant, 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

Tim Davis Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68
Mar-04-2025

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N124030013
Owner Name VR CPC Holding, Inc. - dba Park City Mountain Resort
Mailing Address PO Box 39
Park City, UT, 84060

Source Name VR CPC Holding, Inc. - dba Park City Mountain Resort
Source Location 1310 Lowell Ave
Park City, UT 84060

UTM Projection 452,933 m Easting, 4,503,939 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 7999 (Amusement & Recreation Services, NEC)

Source Contact Jessica Gibbons
Phone Number [phone]
Email [e-mail]

Billing Contact Jessica Gibbons
Phone Number [phone]
Email [e-mail]

Project Engineer Lucia Mason, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted August 29, 2024
Date of Accepted Application October 22, 2024

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 2
SOURCE DESCRIPTION

General Description
VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) operates and
maintains a ski resort located in Park City, Summit County. The company operates natural gas-
fired boilers and heaters, gasoline/diesel-fired emergency engines, a used oil burner,
gasoline/diesel fuel dispensing stations, and abrasive blasting and degreasing operations.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Summit County
Airs Source Size: B

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
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities

Project Proposal
Modification to Approval Order (AO) DAQE-AN124030012-23 to Update Equipment List and
Correct Emission Calculations

Project Description
VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) is requesting to
remove five (5), add nine (9), and move one (1) emergency engines. Engine details are listed
below:

- Removal of one (1) secondary gasoline emergency engine at C16 Eaglet (28 hp)
- Removal of one (1) secondary gasoline engine at Peak 5 (230 hp)
To be replaced by one already permitted secondary diesel emergency engine (174 hp)
- Removal of one (1) main diesel emergency engine at CO4 Payday (564 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Removal of one (1) main diesel engine at C12 Bonanza (588 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Removal of one (1) main diesel emergency engine at C15 Silverlode (750 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Addition of one (1) T2 secondary diesel emergency engine at High Meadow 2 (66 hp)
- Addition of one (1) T3 secondary diesel emergency engine at Red Pine Gondola (152 hp)
- Addition of one (1) T3 main diesel emergency engine at Cabriolet (275 hp)
- Addition of one (1) T3 secondary diesel emergency engine at Cabriolet (100 hp)
- Addition of one (1) T3 main diesel emergency engine at Over and Out (121 hp)
- Addition of one (1) T4I secondary diesel emergency engine at Over and Out (50 hp)
Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 3

This permit updated also corrects the following errors made in past permit modifications:

2016 Modification:
- An engine was permitted at 174 hp instead of its manufacture max rating of 177hp
2017 Modification:
- An engine's emissions were subtracted from the site's PTE using incorrect operating hours
- CO2e emissions from the addition of a used fuel oil heater were not included in the site's PTE
2019 Modification:
- A primary engine was incorrectly permitted as a secondary engine
2023 Amendment:
- Emissions from a removed 7 MMBtu/hr boiler were calculated using incorrect operating hours

EMISSION IMPACT ANALYSIS
Park City Mountain does not exceed the modeling thresholds for criteria pollutants outlined in R307-410-4.
The changes taking place in this modification are subject to 40 CFR 63 Subpart ZZZZ. Consequently, Park
City Mountain is exempt from Hazardous Air Pollutant modeling as per R307-410-5. Therefore, no modeling
is required.

[Last updated February 20, 2025]

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 4
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)
CO2 Equivalent -1770.87 7569.13
Carbon Monoxide -2.04 10.45
Nitrogen Oxides -3.38 23.88
Particulate Matter - PM10 -0.33 1.94
Particulate Matter - PM2.5 -0.33 1.94
Sulfur Oxides 0.85 2.22
Volatile Organic Compounds -0.39 3.44

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 3 5
Benzene (Including Benzene From Gasoline) (CAS #71432) 2 10
Formaldehyde (CAS #50000) -2 15
Generic HAPs (CAS #GHAPS) -12 3
Hexane (CAS #110543) -59 190
Naphthalene (CAS #91203) 0 1
Toluene (CAS #108883) 0 4
Xylenes (Isomers And Mixture) (CAS #1330207) 1 3
Change (TPY) Total (TPY)
Total HAPs -0.03 0.12

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

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 5
Review of BACT for New/Modified Emission Units

1. BACT review regarding New Emergency Engines
The source is installing nine (9) new emergency engines with the maximum hp listed below. The
EPA Tier ratings for the new engines are the following:

- Three (3) T2 Main Diesel Emergency Engine (800 hp)
- One (1) T2 Secondary Diesel Emergency Engine at High Meadow 2 (66 hp)
- One (1) T3 Secondary Diesel Emergency Engine at Red Pine Gondola (152 hp)
- One (1) T3 Main Diesel Emergency Engine at Cabriolet (275 hp)
- One (1) T3 Secondary Diesel Emergency Engine at Cabriolet (100 hp)
- One (1) T3 Main Diesel Emergency Engine at Over and Out (121 hp)
- One (1) T4I Secondary Diesel Emergency Engine at Over and Out (50 hp)

Emissions from the combined emergency engines are as follows:
NOx: 1.84 tpy, CO: 0.20 tpy, PM: 0.03 tpy, SO2: 1.02 tpy, VOC: 0.11 tpy, HAP: 7.93 lbs/year

Available control technology for diesel engines includes:
1. Add on control: Selective Catalytic Reduction (SCR)
2. Add on control: Diesel Oxidation Catalyst (DOC)
3. Tier 4 Final Engine
4. Tier 4 Intermediate Engine
5. Tier 3 Engine
6. Tier 2 Engine

Available fuel control options include:
1. Ultra-low sulfur diesel fuel

Park City Mountain is limited in their engine options due to size constraints associated with ski lift
terminals and the low temperature conditions. Tier 4 Final engines use diesel exhaust fluid (DEF)
to reduce emissions. DEF has a freezing point of 12 degrees Fahrenheit and would freeze
frequently at a ski resort resulting in maintenance concerns. Each emergency engine will not
exceed 100 hours of operation per year for maintenance and testing purposes. Due to the
inconsistent and minimal emissions produced by the emergency engines during testing and
maintenance, the cost to install higher tier engines or add on controls is considered cost
prohibitive.

For these reasons, the tier certifications listed above are considered BACT in conjunction with
operating and maintaining the engines in accordance with manufacturer recommendations and
operating each engine no more than 100 hours annually for maintenance checks and readiness
testing.

Sulfur dioxide emissions occur when the sulfur in diesel fuel oxidizes during combustion. Park
City Mountain will use ultra-low sulfur diesel fuel containing no more than 15 parts per million by
weight of sulfur which is considered BACT. BACT is also maintaining visible emissions at or
below 20% opacity.

[Last updated March 3, 2025]

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 6
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 two-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 two (2) 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]

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 7
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 VR CPC Holdings - dba Park City Mountain Resort
Ski Resort

II.A.2 Main Emergency Generator Engines*
Quantity: Twenty-five (25), new: five (5)
Fuel: Diesel
Cumulative site-wide rating: 13,054 hp
Maximum rating: 1,046 hp
Minimum rating: 121 hp
*Source refers to these as Auxiliary Engines

II.A.3 Secondary Emergency Generator Engines**
Quantity: Twenty-nine (29), new: four (4)
Fuel: Twenty-six (26) Diesel, new: four (4)
Fuel: Three (3) Gasoline (all manufactured prior to 2009)
Cumulative site-wide rating: 4,931 hp
Maximum rating: 335 hp
Minimum rating: 28 hp
**Source refers to these as Evacuation & Tertiary Engines

II.A.4 Various Boilers & Heaters
Fuel: Natural Gas or Propane
Size: Less than 5 MMBtu/hr (each)

II.A.5 One (1) Used Oil Burner
Fuel: Used Oil
Size: 0.24 MMBtu/hr

II.A.6 Fuel Dispensing Stations
Locations: Two (2)
Various diesel and gasoline tanks at each location

II.A.7 Abrasive Blasting Operations
Two (2) confined spaces equipped with filters

II.A.8 Degreasing Operations
Location: King Shop

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
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
The owner/operator shall not exceed the following visible emissions limits from the listed
emission points:

A. All natural gas-fired equipment - 10% opacity

B. All other points - 20% opacity

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2 Generator Engine Requirements
II.B.2.a
NEW
The owner/operator shall use emergency generator engines for electricity-producing operation
only during the periods when electric power from the public utilities is interrupted or during
electric motor failures or failures of equipment attached to the motor output shafts for drive
connections. The owner/operator shall not operate each emergency engine on site for more
than 100 hours per rolling 12-month period during non-emergency situations. There is no time
limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.a.1
NEW
To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following:

A. Engine identification

B. The date the emergency engine was used

C. The duration of operation, in hours

D. The reason for the emergency engine usage

[40 CFR 63 Subpart ZZZZ, R307-401-8]

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 9
II.B.2.b
NEW
The owner/operator shall comply with all applicable provisions of 40 CFR 60, NSPS Subpart
A (General Provisions), Section 60.1 to Section 60.18, and Subpart IIII (Standards of
Performance for Stationary Compression Ignition Internal Combustion Engines), Section
60.4200 to Section 60.4219 for stationary diesel fueled engines on site.

The owner/operator shall operate the engines in accordance with the most current version of
40 CFR 60 applicable to this source.

[40 CFR 60 Subpart A, 40 CFR 60 Subpart IIII]

II.B.2.c
NEW
The owner/operator shall comply with all applicable provisions of 40 CFR 63, MACT
Standards Subpart A (General Provisions), Section 63.1 to Section 63.16, and Subpart ZZZZ
(NESHAPs for Stationary Reciprocating Internal Combustion Engines), Section 63.6580 to
Section 63.6675, for stationary diesel engines on site.

The owner/operator shall operate the engines in accordance with the most current version of
40 CFR 63 applicable to this source.

[40 CFR 63 Subpart A, 40 CFR 63 Subpart ZZZZ]

II.B.2.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in the diesel-fired emergency generator engines. [R307-401-8]

II.B.2.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.2.e.1
NEW
To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements. [R307-401-8]

II.B.3 Boiler Requirements
II.B.3.a The owner/operator shall use natural gas or propane as a fuel source in all boilers and hot
water heaters on site. [R307-401-8]

II.B.4 Fuel Dispensing and Storage Requirements
II.B.4.a The owner/operator shall cover all open diesel and gasoline containers and fill pipes with
gasketed seals when not in use. [40 CFR 63 Subpart CCCCCC, R307-401-8]

II.B.5 Degreasing Operations Requirements
II.B.5.a
NEW
The owner/operator shall store VOC- and HAPs- containing materials and VOC- and/or
HAPs- laden rags in covered containers (except when in use). [R307-401-8]

II.B.6 Used Oil Fuel Requirements
II.B.6.a The owner/operator shall not burn any used oil unless the used oil is on-specification used oil
as defined in UAC R315-15. [R307-401-8]

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 10
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes AO DAQE-AN124030012-23 dated January 18, 2024
Is Derived From NOI dated August 29, 2024
Incorporates Additional Information dated September 10, 2024
Incorporates Additional Information dated October 3, 2024
Incorporates Additional Information dated October 15, 2024
Incorporates Additional Information dated October 16, 2024
Incorporates Additional Information dated October 16, 2024
Incorporates Additional Information dated October 21, 2024
Incorporates Additional Information dated December 11, 2024
Incorporates Additional Information dated October 22, 2024
Incorporates Additional Information dated January 3, 2025
Incorporates Additional Information dated February 4, 2025

REVIEWER COMMENTS

1. Comment regarding Modification Request:
VR CPC Holdings, Inc. - dba Park City Mountain Resort (Park City Mountain) is requesting to
remove, replace, move or add the following engines:

- Removal of one (1) secondary gasoline emergency engine at C16 Eaglet (28 hp)
- Removal of one (1) secondary gasoline engine at Peak 5 (230 hp)
To be replaced by one already permitted secondary diesel emergency engine (174 hp)*
- Removal of one (1) main diesel emergency engine at CO4 Payday (564 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Removal of one (1) main diesel engine at C12 Bonanza (588 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Removal of one (1) main diesel emergency engine at C15 Silverlode (720 hp)
To be replaced by one (1) T2 main diesel emergency engine (800 hp)
- Addition of one (1) T2 secondary diesel emergency engine at High Meadow 2 (66 hp)
- Addition of one (1) T3 secondary diesel emergency engine at Red Pine Gondola (152 hp)
- Addition of one (1) T3 main diesel emergency engine at Cabriolet (275 hp)
- Addition of one (1) T3 secondary diesel emergency engine at Cabriolet (100 hp)
- Addition of one (1) T3 main diesel emergency engine at Over and Out (121 hp)
- Addition of one (1) T4I secondary diesel emergency engine at Over and Out (50 hp)
*This modification recalculates NOx, CO and PM emissions for this engine using more accurate
emission factors.

These changes result in a decrease in all emissions except for SO2 which increases by 0.66 tpy.

Several errors made in previous permit iterations are being corrected through this modification as
well. Except for the 0.66 tpy increase of SO2 resulting from the new engines, these changes account
for emission increases shown in the Summary of Emissions. A summary of these corrections is listed
below. More details are included in Comment #5 (Source Emission Correction Calculations and
DAQ Acceptance).

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 11
2016 Modification:
- An engine was permitted at 174 hp instead of its manufacture max rating of 177hp
2017 Modification:
- An engine's emissions were subtracted from the site's PTE using incorrect operating hours
- CO2e emissions from the addition of a used fuel oil heater were not included in the site's PTE
2019 Modification:
- A primary engine was incorrectly permitted as a secondary engine
2023 Amendment:
- Emissions from a removed 7 MMBtu/hr boiler were calculated using incorrect operating hours

All contact information has been updated.

[Last updated March 3, 2025]

2. Comment regarding Source Calculations and DAQ Acceptance:
Engines lose ~ 4% power per 1,000 ft of elevation. Thus, engine power was corrected for elevation
using the following excel formula:

Elevation adjusted HP = ROUND (HP at sea level - (HP at sea level * ROUNDDONW ((elevation
of engine (ft) - 7500 (ft))/1,000,0) * 0.04),0)

All engines:
CO2: 40 CFR 98 Table C-1
CH4, NO2: 40 CFR 98 Table C-2
Global Warming Potentials: 40 CFR 98 Table A-1

NOTE: EPA's Nonroad Compression Ignition (NRCI) Engine data can be found in the source file

-------------------------------------------------------------------------------------------------------------------------
Removed Main Engines:
NOx: -6.30 tpy, CO: -1.37 tpy, PM: -0.41 tpy, SO2: -0.36 tpy, VOC: -0.46, HAP: -10.59 lb/year

One (1) Main Diesel Emergency Engine at CO4 Payday (564 hp, 100 hours/year)
NOx, CO, PM, SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) Main Diesel Engine at C12 Bonanza (588 hp, 500 hours/year)
NOx, CO, PM, SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) Main Diesel Emergency Engine at C15 Silverlode (720 hp, 100 hours/year)
NOx, CO, PM, SO2, VOC: AP-42, Table 3.4-1
HAP: AP-42 Table 3.4-3, 3.4-4

-------------------------------------------------------------------------------------------------------------------------
Added Main Engines:
NOx: 1.70 tpy, CO: 0.16 tpy, PM: 0.02 tpy, SO2: 0.99 tpy, VOC: 0.06, HAP: 6.93 lb/year

Three (3) T2 Main Diesel Emergency Engines (800 hp, 100 hours/year)
Elevations: 8,250 ft, 9,250 ft, 9,250 ft
NOx, CO, PM, VOC: C18 800 hp Performance Data: DM7702
SO2: AP-42 Table 3.4-1
Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 12
HAP: AP-42 Table 3.4-3 and 3.4-4

One (1) T3 Main Diesel Emergency Engine at Cabriolet (275 hp 100 hours/year)
Elevation: 6,740 ft
NOx, CO, PM: NCRI Certification Data Table Certificate# JPKXL04.4NL1-016
SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) T3 Main Diesel Emergency Engine at Over and Out (121 hp, 100 hours/year)
Elevation: 7,500 ft
NOx, CO, PM: NCRI Certification Data Table Certificate# KCEXL0275AAG-046
SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

-------------------------------------------------------------------------------------------------------------------------
Removed Secondary Engines:
NOx: -0.08 tpy, CO: -0.09 tpy, PM: -0.01 tpy, SO2: -0.01 tpy, VOC: -0.19 lb/year, HAP: 0 lb/year

One (1) Secondary Gasoline Emergency Engine at C16 Eaglet (28 hp, 100 hours/year)
NOx, CO, PM, SO2, VOC: AP-42 Table 3.3-1

One (1) Secondary Gasoline Engine at Peak 5 (230 hp)
NOx, CO, PM, SO2, VOC: AP-42 Table 3.3-1

-------------------------------------------------------------------------------------------------------------------------
Added Secondary Engines:
NOx 0.13: tpy, CO: 0.05 tpy, PM: 0.01 tpy, SO2: 0.04 tpy, VOC: 0.04, HAP: 1.00 lb/year

One (1) T2 Secondary Diesel Emergency Engine at High Meadow 2 (66 hp, 100 hours/year)
Elevation: 8,045 ft
NOx, CO, PM: 40 CFR Appendix I to Part 1039 - Summary of Previous Emission Standards
SO2, VOC: AP-42 Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) T3 Secondary Diesel Emergency Engine at Red Pine Gondola (152 hp, 100 hours/year)
Elevation: 8,520 ft
NOx, CO, PM: NCRI Certification Data Table Certificate# LCEXL0275AAG-024
SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) T3 Secondary Diesel Emergency Engine at Cabriolet (100 hp, 100 hours/year)
Elevation: 6,500 ft
NOx, CO, PM: NCRI Certification Data Table Certificate# JPKXL04.4NL1-016
SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) T4I Secondary Diesel Emergency Engine at Over and Out (50 hp, 100 hours/year)
Elevation: 7,500 ft
NOx, CO, PM: NCRI Certification Data Table Certificate# GDICL01.8LEA-007
SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 13
[Last updated February 20, 2025]

3. Comment regarding Source Emission Correction Calculations and DAQ Acceptance:
2016 Modification Errors:
In 2016, Park City merged with an adjacent resort and all emissions were combined into a site-wide
emissions spreadsheet. In 2016, the secondary diesel emergency engine located at Cabriolet was
incorrectly permitted at 177 hp when the manufacture max power rating was174 hp (documentation
is in the source file). This engine was recently relocated and is now permitted at Peak 5. This
modification corrects the engine's power rating and recalculates the engine's NOx, CO, PM, and HAP
emissions using more accurate emission factors.
NOx: -0.18 tpy, CO: -0.05 tpy, PM: -0.02 tpy, SO2: 0 tpy, VOC: 0 tpy, CO2e: -0.17 tpy, HAP: 0.48
lb/year

One (1) Relocated Secondary Gasoline Engine Moved from Cabriolet (174 hp, 100 hours/year)
Elevation: 6,500
NOx, CO, PM, SO2, VOC: AP-42 Table 3.3-1
HAP: AP-42 Table 3.3-2

One (1) Relocated Secondary Diesel Emergency Engine Moved to Peak 5 (174 hp, 100
hours/year)
Elevation: 8,325 ft
NOx, CO, PM: Archived NCRI Certification Data Table Certificate# CEX-NR6-00-10
SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2

-------------------------------------------------------------------------------------------------------------------------
2017 Modification Errors:
The 2017 AO modification updated several engine sizes and added a waste fuel oil heater. As part of
the engine calculations, emissions from the C12 Bonanza main engine (diesel, 488 hp) were
subtracted at 500 annual hours of operation when the engine emissions were calculated at 100 hours
per year when the engine emissions for the engine were originally calculated in 2016. CO2e
emissions for the waste fuel oil heater were also left out of the summary of emissions. These changes
have been corrected using the emission factors and parameters listed below.
NOx: 3.06 tpy, CO: 0.66 tpy, PM: 0.22 tpy, SO2: 0.20 tpy, VOC: 0.24 tpy, CO2e: 275 tpy, HAP: 0
lb/year

One (1) Main Diesel Engine at C12 Bonanza (588 hp)
NOx, CO, PM, SO2, VOC: AP-42, Table 3.3-1
HAP: AP-42 Table 3.3-2
CO2: 40 CFR 98 Table C-1
CH4, NO2: 40 CFR 98 Table C-2
Global Warming Potentials: 40 CFR 98 Table A-1

One (1) Used Fuel Oil Heater (rated heat input: 1.68 gal/hr, 8,760 hours/year)
CO2e: AP-42, Table 1.11-3 - Small Boilers ≤.25 MMBtu/hr

-------------------------------------------------------------------------------------------------------------------------
2019 Modification Errors:
The 2019 modification removed one (1) gasoline fired emergency generator and added the High
Meadow diesel fired emergency generator (site rated hp: 202). The added emergency generator was
Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 14
added to the 2019 AO as a secondary engine when it should have been listed as a main engine. The
change is reflected in Equipment IDs II.A.2 and II.A.3.

-------------------------------------------------------------------------------------------------------------------------
2023 Administrative Amendment Errors:
The 2023 modification replaced one (1) 7 MMBtu/hr boiler with three (3) 2 MMBtu/hour boilers.
The 7 MMBtu/hr boiler emissions were originally based on 8,760 hours of operation per year in
2016. In the 2023 modification, the 7 MMBtu/hr boiler emissions were subtracted using 3,960
annual hours of operation. This modification corrects this error. The emission corrections below
were calculated using the following emission factors and parameters.
NOx: -1.65 tpy, CO: -1.39 tpy, PM: -0.13 tpy, SO2: -0.01 tpy, VOC: -0.09 tpy, CO2e: -1965 tpy,
HAP: -0.03 lb/year

One (1) Natural Gas Boiler (7 MMBtu/hr)
NOx, CO, PM, SO2, VOC: AP-42,Table 1.4-1, 1.4-2
HAP: AP-42 Table 1.4-3
CO2, CH4, NO2:AP-42 Table 1.4-2
Global Warming Potentials: 40 CFR 98 Table A-1

[Last updated February 20, 2025]

4. Comment regarding Updates to Approved Equipment:
Equipment ID II.A.2 in AO DAQE-AN124030012-23 specifies a cumulative site-wide rating of
11,992 hp for twenty-three (23) main diesel-fired emergency generator engines. This modification
will remove three (3) and add five (5) main emergency engines. This modification will also correct
the High Meadow engine that was incorrectly listed as a secondary engine in 2017. Equipment ID
II.A.2 has been updated accordingly to twenty-six (26) diesel-fired emergency generators, bringing
the cumulative site-wide rating to 13,054 hp*.

Equipment ID II.A.3 in AO DAQE-AN124030012-23 specifies a cumulative site-wide rating of
5,032 hp for twenty-seven (27) secondary emergency generator engines. Twenty-two (22) of the
engines were specified as diesel and five (5) were listed as gasoline. Park City Mountain has
requested to remove two (2) secondary gasoline engines and add four (4) secondary diesel engines.
This modification also accounts for the incorrectly permitted High Meadow and relocated Peak 5
engine. The Equipment ID II.A.3 now lists twenty-five (25) diesel engines, three (3) gasoline
engines, and twenty-eight (28) cumulative secondary engines with a site-wide rating of 4,934 hp*.

*Site-wide ratings are based on site rated hp not the engine's maximum hp as listed in other
engineering review comments.

[Last updated February 20, 2025]

5. Comment regarding Summary of Emissions:
Acrolein emissions are less than one lb/year. These emissions have been combined with "generic
HAPs." [Last updated February 20, 2025]

6. Comment regarding Federal Standards:
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines. This standard applies to the diesel-fired engines on site.

NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 15
Combustion Engines. The three (3) gasoline-fired engines were all manufactured prior to 2009;
therefore, this standard does not apply to these engines.

MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion
Engines. This standard applies to the generator engines on site.

MACT (Part 63), CCCCCC: NESHAP for Source Category: Gasoline Dispensing Facilities.
This standard applies to the gasoline dispensing stations on site.

[Last updated February 20, 2025]

7. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants
4. Any Title IV affected source

This facility is not a major source and is not a Title IV source; however, the facility is subject to 40
CFR 60 NSPS Subparts A and IIII, and 40 CFR 63 MACT Subparts A, ZZZZ, and CCCCCC
regulations. However, Title V does not apply because NSPS Subpart IIII, and MACT Subparts
ZZZZ and CCCCCC exempt sources from the obligation to obtain a permit under 40 CFR part 70
(Title V permit) if the source is not otherwise required by law to obtain a permit. There are no other
reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not
apply to this facility.

[Last updated February 20, 2025]

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68

Engineer Review N124030013: VR CPC Holding, Inc. - dba Park City Mountain Resort
March 3, 2025
Page 16
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

Docusign Envelope ID: D7009B78-B758-4ED5-9EDB-551ACB8E4F68
Lucia Mason <[e-mail]>
Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
26 messages
Lucia Mason <[e-mail]>Wed, Sep 4, 2024 at 4:52 PM
To: [e-mail]
Hi Jessica,
Thank you for submitting a NOI on behalf of Park City Mountain Resort. The DAQ will need more information to continue processing your application. Please
provide the following:
1. Any spreadsheets you used in your NOI
2. A list of the specific engines that are being removed
3. A list of the specific engines that are being added (noting what engine they're replacing, if any)
4. Specification sheets corresponding to the removed, replaced and added engines
5. A Best Available Control Technology (BACT) analysis regarding the engines that are being added to your permit. In your BACT analysis you need to explain
why each engine type was chosen above other options.
Please reach out with any questions.
Best,
Lucia
Jessica Gibbons <[e-mail]>Tue, Sep 10, 2024 at 5:15 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
1. Any spreadsheets you used in your NOI – See attached “Copy – 20240724_Park City Sitewide Emissions Workbook”
2. A list of the specific engines that are being removed – See attached “New, Replacement, Removed Engines” document or the “2024 NOI Updates” tab of the
spreadsheet.
3. A list of the specific engines that are being added (noting what engine they're replacing, if any) - See attached “New, Replacement, Removed Engines”
document or the “2024 NOI Updates” tab of the spreadsheet.
Payday Aux Engine, Bonanza Aux Engine, Silverlode Aux Engine, and Peak 5 Tertiary Engine were all replaced.
4. Specification sheets corresponding to the removed, replaced and added engines – See attached. Spec Sheet PDFs were not found for Doosan D18 or
Cummins 5.9L so nameplates and the “Nonroad-compression-ignition-2011-present” spreadsheet were used. Peak 5 was updated in the 20170131_Park
City NOI to account for modifications to the engine.
5. A Best Available Control Technology (BACT) analysis regarding the engines that are being added to your permit. In your BACT analysis you need to explain
why each engine type was chosen above other options.
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…1/19
For the BACT Analysis, I was not able to find a form to complete this in. The on the DAQ site goes to a database and I was not able to find it by searching.
Could you let me know where to find this.
Please reach out with any other documentation that is needed or questions that come up.
Thank you,

Jessica Gibbons (she/her)
Regional Compliance Specialist
Park City Mountain Resort
Cell: 906-235-3152
Environmental Compliance Hotline: [phone]
Visit the Environmental Compliance Ops Site for Helpful Resources
3E SDS Library

From: Lucia Mason <[e-mail]>
Sent: Wednesday, September 4, 2024 4:52 PM
To: Jessica Gibbons <[e-mail]>
Subject: Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort

ATTENTION: This eMail originated from outside of Vail Resorts and may or may not be legitimate. Although we do our best to screen phishing emails, please
use extra caution before opening any attachments or clicking on any links unless you are absolutely sure the source of the email is trusted. If in doubt
about the legitimacy of this email, please use the Report Phish button for validation.
[Quoted text hidden]
The information contained in this message is confidential and intended only for the use of the individual or entity named above, and may be privileged. Any
unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please reply to the sender immediately, stating that you have
received the message in error, then please delete this e-mail. Thank you.
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…2/19
14 attachments
Doosan D18NAP - New - Over and Out Evac Nameplate.jpg
1815K
Cummins 5.9L - New_ Peak 5 Evav Name Plate.jpeg
888K
Detroit Diesel 12 V71 TA - Old - Payday Aux.JPG
643K
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…3/19
Detroit Diesel 12 V71 TA - Old - Bonanza Aux.JPG
639K
Copy- 20240724_Park City Sitewide Emissions Workbook.xlsx
254K
New, Replacement, Removed Engines.docx
56K
Caterpillar C18 ACERT -New - Payday Aux, Silverlode Aux, Bonanza Aux.pdf
543K
Caterpillar C9 ACERT - New - Cabriolet Aux.pdf
476K
Perkins 1104D-44T - New - Cabriolet Evac.pdf
737K
Caterpillar C2-2 - New - High Meadow 2 Evac.pdf
530K
Cummins QSB4.5 Spec Sheet - New - Red Pine Gondola Evac and Over and Out Aux.pdf
676K
nonroad-compression-ignition-2011-present.xlsx
11771K
Detroit Diesel 8123-7400 - Old - Silverlode.pdf
206K
20170131_Park City Mountain NOI.pdf
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Lucia Mason <[e-mail]>Thu, Sep 12, 2024 at 2:38 PM
To: Christine Bodell <[e-mail]>
Thanks for all your help! It looks like the sorting did mess up the "Engine Emission Factors" and "Engine Emission Calcs" tabs - thanks for pointing that out. That
being said, at a glance some of their emission factors still seem unreasonably large. I'll keep looking into it and reach out again Monday.
Thanks again and hope you have a great weekend!
[Quoted text hidden]
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…4/19
14 attachments
Doosan D18NAP - New - Over and Out Evac Nameplate.jpg
1815K
Cummins 5.9L - New_ Peak 5 Evav Name Plate.jpeg
888K
Detroit Diesel 12 V71 TA - Old - Payday Aux.JPG
643K
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…5/19
Detroit Diesel 12 V71 TA - Old - Bonanza Aux.JPG
639K
Copy- 20240724_Park City Sitewide Emissions Workbook.xlsx
254K
New, Replacement, Removed Engines.docx
56K
Caterpillar C18 ACERT -New - Payday Aux, Silverlode Aux, Bonanza Aux.pdf
543K
Caterpillar C9 ACERT - New - Cabriolet Aux.pdf
476K
Perkins 1104D-44T - New - Cabriolet Evac.pdf
737K
Caterpillar C2-2 - New - High Meadow 2 Evac.pdf
530K
Cummins QSB4.5 Spec Sheet - New - Red Pine Gondola Evac and Over and Out Aux.pdf
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nonroad-compression-ignition-2011-present.xlsx
11771K
Detroit Diesel 8123-7400 - Old - Silverlode.pdf
206K
20170131_Park City Mountain NOI.pdf
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Lucia Mason <[e-mail]>Wed, Sep 18, 2024 at 11:37 AM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
Thank you for the additional information. Unfortunately, Best Available Control Technology (BACT) analyses are done on a case by case basis so there isn't
an associated DAQ form. You can find instructions on how to conduct a BACT analysis in Chapter B Part IV of the attached "NSR Workshop Manual (DRAFT
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…6/19
October 1990)" pdf. In your case "control technologies" refer to either a different engine choice or add-on controls including SCR (selective catalytic reduction) or
DOC (diesel oxidation catalyst) systems.
I have a few questions regarding your second submission.
1. The emission factors for each of the unpermitted engines entered into Park City's Site-wide Emissions Spreadsheet are pulled from AP-42. These
emission factors conflict with the tier ratings many of the engines are given in their spec sheets. Please resubmit your calculations and Form 5 using
emission factors that are specific to each engine and cite how you determined the emission factors.
2. Cummins QSB4.5 (T4 if QSB5 spec sheet applies)
The Cummins spec sheet you provided is for QSB5 engines not QSB4.5 engines as listed in the Park City's Site-wide Emissions
Spreadsheet. Please explain this discrepancy or provide the appropriate spec sheet.
Why do the two engines listed under this make and model (the evac engine located at Red Pine Gondola and the aux engine located at Over and
Out) have different maximum power ratings in Park City's Site-wide Emissions Spreadsheet? Neither power rating matches the power rating
provided in the spec sheet.
3. Cummins B5.9-P (No spec sheet provided)
The date of manufacture (2000) indicates a T1 engine. Please explain why Park City could not install an engine that adheres to more recent
emission standards (ie, why could this engine not be a T4 engine? and if not T4 why not a T3?).
4. Doosan D18NAP (No spec sheet provided)
The "Emission Control Information" name plate says the engine complies with 2016 emission standards. This indicates the engine adheres to T4
emission standards. Please provide additional evidence that the engine adheres to T4 emission limits.
Thanks again for your added information and please feel free to reach out with any questions. You're welcome to contact me via phone as well at [phone].
Lucia
[Quoted text hidden]
NSR Workshop Manual (DRAFT October 1990) (pdf).url
1K
Jessica Gibbons <[e-mail]>Thu, Sep 19, 2024 at 4:10 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

I have a attached the Nonroad Compression Ignition 2011-Present spreadsheet I was using to find information about the engines. I found this on the EPA’s website
at Annual Certification Data for Vehicles, Engines, and Equipment.

I will work on getting more information about the engines and get back to you as soon as possible.

2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…7/19
Thank you for the call today, it was very helpful.

Jessica Gibbons (she/her)
Regional Compliance Specialist
Park City Mountain Resort
Cell: 906-235-3152
Environmental Compliance Hotline: [phone]
Visit the Environmental Compliance Ops Site for Helpful Resources
3E SDS Library

From: Lucia Mason <[e-mail]>
Sent: Wednesday, September 18, 2024 11:38 AM
To: Jessica Gibbons <[e-mail]>
Subject: Re: Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort

Hi Jessica,

Thank you for the additional information. Unfortunately, Best Available Control Technology (BACT) analyses are done on a case by case basis so there isn't
an associated DAQ form. You can find instructions on how to conduct a BACT analysis in Chapter B Part IV of the attached "NSR Workshop Manual (DRAFT
October 1990)" pdf. In your case "control technologies" refer to either a different engine choice or add-on controls including SCR (selective catalytic reduction) or
DOC (diesel oxidation catalyst) systems.

I have a few questions regarding your second submission.
1. The emission factors for each of the unpermitted engines entered into Park City's Site-wide Emissions Spreadsheet are pulled from AP-42. These
emission factors conflict with the tier ratings many of the engines are given in their spec sheets. Please resubmit your calculations and Form 5 using
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…8/19
emission factors that are specific to each engine and cite how you determined the emission factors.
2. Cummins QSB4.5 (T4 if QSB5 spec sheet applies)
o The Cummins spec sheet you provided is for QSB5 engines not QSB4.5 engines as listed in the Park City's Site-wide Emissions
Spreadsheet. Please explain this discrepancy or provide the appropriate spec sheet.
o Why do the two engines listed under this make and model (the evac engine located at Red Pine Gondola and the aux engine located at Over
and Out) have different maximum power ratings in Park City's Site-wide Emissions Spreadsheet? Neither power rating matches the power rating
provided in the spec sheet.
3. Cummins B5.9-P (No spec sheet provided)
o The date of manufacture (2000) indicates a T1 engine. Please explain why Park City could not install an engine that adheres to more
recent emission standards (ie, why could this engine not be a T4 engine? and if not T4 why not a T3?).
4. Doosan D18NAP (No spec sheet provided)
o The "Emission Control Information" name plate says the engine complies with 2016 emission standards. This indicates the engine adheres to
T4 emission standards. Please provide additional evidence that the engine adheres to T4 emission limits.
[Quoted text hidden]

Lucia

[Quoted text hidden]
nonroad-compression-ignition-2011-present.xlsx
11771K
Lucia Mason <[e-mail]>Mon, Sep 23, 2024 at 7:14 AM
To: Jessica Gibbons <[e-mail]>
Sounds good. Thank you!
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Thu, Oct 3, 2024 at 11:33 AM
To: Lucia Mason <[e-mail]>
Hi Lucia,

2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&simp…9/19
Please see Attachment C Engine Information from the 2016 NOI application for the Park City Mountain Resort air permit, for information about the original Cabriolet
Lift Generator 22 – Tert engine. This is the engine that was moved to the Peak 5 Lift Terminal.

I have also attached pictures of the name plate for this engine that were taken this summer. It does look like the HP may have been enter incorrectly originally, it
should be 174.

I am waiting to hear back from some engine manufacturers on the EPA Tier ratings. Than I will be able to get the updated emission factors to you.
[Quoted text hidden]
2 attachments
Peak 5 Evac Engine Name Plate .jpeg
796K
Attachment C_Engine Information (1).pdf
213K
Lucia Mason <[e-mail]>Thu, Oct 3, 2024 at 2:46 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
Sounds good. Thanks for getting back to me. With this updated information I want to make sure my understanding of what engines are being replaced/ added/
removed is accurate. Can you confirm that the changes I have listed below are correct?
1. Removal of one (1) Secondary Gasoline Emergency Engine (28 hp, ≤1995) at C16 Eaglet
2. Removal of one (1) Main Diesel Emergency Engine (564 hp, <1991) at CO4 Payday
1. To be replaced by one (1) T4F Main Diesel Emergency Engine (800 hp, CI, 2019)
3. Removal of one (1) Main Diesel Engine (588 hp, ≤1997) at C12 Bonanza
1. To be replaced by one (1) T4F Main Diesel Emergency Engine (800 hp, CI, 2019)
4. Removal of one (1) Main Diesel Emergency Engine (720 hp, ≤1996) at C15 Silverlode
To be replaced by one (1) T4F Main Diesel Emergency Engine (800 hp, CI, 2019)
5. Removal of one (1) Secondary Gasoline Engine (230 hp, ≤1999) at Peak 5
To be replaced by one (1) already permitted Secondary Diesel Emergency Engine (174 hp, CI, 2000)
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…10/19
6. Addition of one (1) T4I Secondary Diesel Emergency Engine (66 hp, CI, 2018) at High Meadow 2
7. Addition of one (1) T4F Secondary Diesel Emergency Engine (152 hp, CI, 2020) at Red Pine Gondola
8. Addition of one (1) T3 Main Diesel Emergency Engine (275 hp, CI, 2019) at Cabriolet
9. Addition of one (1) T3 Secondary Diesel Emergency Engine (99.9 hp, CI, 2018) at Cabriolet
10. Addition of one (1) T4F Main Diesel Emergency Engine (121 hp, CI, 2019) at Over and Out
11. Addition of one (1) T4 Secondary Diesel Emergency Engine (50 hp, CI, 2016) at Over and Out
These changes, combined with the engine numbers, provided your 2023 AO sum to 54 engines total.
25 Main (Auxiliary) Emergency Diesel Engines
26 Secondary (Evacuation & Tertiary) Diesel Engines
3 Secondary (Evacuation & Tertiary) Gasoline Engines
Part of the reason I ask is because the emission spreadsheet you sent totals to 56 engines. I'm not sure where the discrepancy is coming from. Do you have any
ideas?
Lastly, do you have access to the HP ratings of the removed engines? At the moment I only have the site-rated HP.
Thanks again for your time help,
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Fri, Oct 11, 2024 at 5:03 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

Please see updates to your list below. Sorry for the confusion on the Tier Ratings. I received more information from the lift manufactures who chose the engines.
With that information and using the NCRI Certification data I have made updates below and in the attached revised Emission Workbook and Form 5. I have also
attached communication and lift emissions information I received as well as the BACT Analysis.
1. Removal of one (1) Secondary Gasoline Emergency Engine (28 hp, ≤1995) at C16 Eaglet -Correct, Maximum HP 28
2. Removal of one (1) Main Diesel Emergency Engine (564 hp, <1991) at CO4 Payday – Correct, Maximum HP 564
To be replaced by one (1) T2 Main Diesel Emergency Engine (800 hp, CI, 2019)
3. Removal of one (1) Main Diesel Engine (588 hp, ≤1997) at C12 Bonanza – Correct, Maximum HP 588
To be replaced by one (1) T2 Main Diesel Emergency Engine (800 hp, CI, 2019)
4. Removal of one (1) Main Diesel Emergency Engine (720 hp, ≤1996) at C15 Silverlode – Correct, Maximum HP 750
To be replaced by one (1) T2 Main Diesel Emergency Engine (800 hp, CI, 2019)
5. Removal of one (1) Secondary Gasoline Engine (230 hp, ≤1999) at Peak 5 - Correct, Maximum HP 230
To be replaced by one (1) already permitted Secondary Diesel Emergency Engine (174 hp, CI, 2000) – Correct, Maximum HP 174
5. Addition of one (1) T4I Secondary Diesel Emergency Engine (66 hp, CI, 2018) at High Meadow 2 – Correct
6. Addition of one (1) T3 Secondary Diesel Emergency Engine (152 hp, CI, 2020) at Red Pine Gondola
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…11/19
7. Addition of one (1) T3 Main Diesel Emergency Engine (275 hp, CI, 2019) at Cabriolet - Correct
8. Addition of one (1) T3 Secondary Diesel Emergency Engine (99.9 hp, CI, 2018) at Cabriolet - Correct
9. Addition of one (1) T3 Main Diesel Emergency Engine (121 hp, CI, 2019) at Over and Out
10. Addition of one (1) T4 Secondary Diesel Emergency Engine (50 hp, CI, 2016) at Over and Out – Correct
These changes, combined with the engine numbers, provided your 2023 AO sum to 54 engines total. - Correct
The additional two “engine” in the spreadsheet were from a 2017 permit modification that added 500 HP to the Main Emergency Engines and 500 HP to the
Secondary Emergency Engines. My understanding is that it was done to help avoid going over permitted limits if updates were made.
So there are only 54 engines, those two additional “Extra HP” rows just contribute to the overall emission data.
Please let me know if you need any additional information.
[Quoted text hidden]
6 attachments
Form 5 Emissions Information Criteria GHGs HAP’s Utah Division of Air Quality revised.pdf
323K
Copy- 20240724_Park City Sitewide Emissions Workbook revised.xlsx
291K
C18-800hp DM7702.pdf
89K
20241003_Re Park City Mountain Resort Lift Backup Engine Information.pdf
1010K
nonroad-compression-ignition-2011-present.xlsx
11771K
BACT Analysis PCMR 2024.docx
17K
Lucia Mason <[e-mail]>Tue, Oct 15, 2024 at 8:12 AM
To: Jessica Gibbons <[e-mail]>
Thank you! I'll reach out with any additional questions.
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Oct 15, 2024 at 1:18 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
Thank you so much for all your help. The information you provided is really useful. I have a few follow up notes as per our conversation earlier today:
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…12/19
1. The Peak 5 lift generator is already permitted so its emissions are accounted for in the site's current PTE. It should be removed from the calculations in the
"2024 NOI Updates" tab in the Site-wide Emission Workbook
2. The DAQ will need emission certifications for the following engines:
1. Caterpillar C2.2
2. Cummins QSB4.5
3. Caterpillar C9
4. Perkins 1104D-44TI(C4.4)
5. Doosan D18NAP (emission certifications would be ideal, but the plaque reading "California Regulation for 2016 Nonroad Diesel Engines" is likely
good enough)
Thanks again for your time. Please reach out with any questions.
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Wed, Oct 16, 2024 at 1:23 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
1. The Peak 5 lift generator is already permitted so its emissions are accounted for in the site's current PTE. It should be removed from the calculations in the
"2024 NOI Updates" tab in the Site-wide Emission Workbook
This engine has been removed from the 2024 NOI Updates tab.
2. The DAQ will need emission certifications for the following engines:
1. Caterpillar C2.2 – See attached email from Caterpillar Engine Emissions Certificate Repository
2. Cummins QSB4.5 – Waiting on response
3. Caterpillar C9 – See attached C9 Cert_KCPXL08.8NZS-005 Certificate of Conformity
4. Perkins 1104D-44TI(C4.4) – Waiting on response
5. Doosan D18NAP (emission certifications would be ideal, but the plaque reading "California Regulation for 2016 Nonroad Diesel Engines" is likely
good enough) – Waiting on response
As I find the remaining certificates I will send them your way.
Thank you!

Jessica Gibbons (she/her)
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152
Environmental Compliance Hotline: [phone]
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…13/19
Visit the Environmental Compliance Ops Site for Helpful Resources

[Quoted text hidden]
3 attachments
Copy- 20240724_Park City Sitewide Emissions Workbook revised (1).xlsx
290K
Caterpillar C2-2 ERCR-107847 Emissions Certification Conformance Information Request.pdf
739K
C9 Cert_KCPXL08.8NZS-005.pdf
156K
Lucia Mason <[e-mail]>Wed, Oct 16, 2024 at 1:46 PM
To: Jessica Gibbons <[e-mail]>
Perfect. Thank you!
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Mon, Oct 21, 2024 at 1:04 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

I have attached the emissions certificates for the two Cummins engines. They are the same model (QSB4.5), but have different Family IDs.

One of the lift manufacturers was able to send us the Technical Data Sheet for the Perkins engine. He had it listed as a Tier 3 engine and it does say under
Emissions Capability that it is certified against the requirements of EPA Tier 3 legislation. I am still working on getting the emissions certificate for it and the Doosan
as well.

Thanks!
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…14/19

Jessica Gibbons (she/her)
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152

[Quoted text hidden]
4 attachments
Cummins QSB4.5 Over and Out Cert_KCEXL0275AAG-046.pdf
156K
Cummins QSB4.5 Red Pine Evac Cert_LCEXL0275AAG-024.pdf
156K
Perkins 1104D-44T 91hp Cabriolet Evac TECH DATA SHEET.pdf
1055K
20241021_RE Park City Mountain Resort Lift Backup Engine Information.pdf
1009K
Jessica Gibbons <[e-mail]>Mon, Oct 21, 2024 at 4:23 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
I added the Perkins 1104D-44T certificate as well.
[Quoted text hidden]
5 attachments
Cummins QSB4.5 Over and Out Cert_KCEXL0275AAG-046.pdf
156K
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…15/19
Cummins QSB4.5 Red Pine Evac Cert_LCEXL0275AAG-024.pdf
156K
Perkins 1104D-44T 91hp Cabriolet Evac TECH DATA SHEET.pdf
1055K
20241021_RE Park City Mountain Resort Lift Backup Engine Information.pdf
1009K
Perkins 1104D-44T EPA Cert_JPKXL04.4NL1-016.pdf
155K
Lucia Mason <[e-mail]>Mon, Oct 21, 2024 at 5:16 PM
To: Jessica Gibbons <[e-mail]>
Thanks for the updates. Once I receive the Doosan certificate I'll continue processing Park City Mountain's permit.
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Tue, Oct 22, 2024 at 10:55 AM
To: Lucia Mason <[e-mail]>
Morning Lucia,
Attached is the Doosan certificate. Please let me know what other information you may need.

Thank you,

Jessica Gibbons (she/her)
Regional Compliance Analyst
[Quoted text hidden]
Doosan D18NAP Over and Out Evac Cert_GDICL01.8LEA.pdf
155K
Lucia Mason <[e-mail]>Wed, Oct 23, 2024 at 8:27 AM
To: Jessica Gibbons <[e-mail]>
Thank you. I'll reach out if the DAQ needs additional information.
[Quoted text hidden]
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…16/19
Lucia Mason <[e-mail]>Wed, Oct 23, 2024 at 1:33 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
To recap what we talked about on the phone earlier today:
1. The High Meadow 2, Caterpillar C2.2 Engine is Tier 2 certified according to the email exchange you provided with a Caterpillar representative. The emission
factors for this engine can be pulled from Tier 2 emission factors for the engine size.
2. There are some conversion errors in the "Park City Site Wide Emission Workbook." Double check that all the emission factors are correct.
Thanks for your time. Please reach out with any questions.
Best,
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Wed, Oct 23, 2024 at 2:21 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
Please see the attached revised spreadsheet.

For the C9 KCPXL08.8NZS-005 the “Engine Operation” should be “variable speed” option should be used.
For the Perkins JPKXL04.4NL1-016 the “Engine Operation” should be “constant speed” option should be used.

Please let me know if there are any other inconsistencies or if there is anything else needed.

Thank you for your time,
[Quoted text hidden]
Copy- 20240724_Park City Sitewide Emissions Workbook revised (2).xlsx
286K
Lucia Mason <[e-mail]>Tue, Oct 29, 2024 at 3:28 PM
To: Jessica Gibbons <[e-mail]>
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…17/19
Hi Jessica,
The updated spreadsheet looks good except the High Meadow 2 C2.2 emission factors (NOx 5.1 g/ph-hr, CO 0.9 g/hp-hr, PM 0 g/hp-hr). These numbers still don't
match the factors I see listed in the "non-road-compression-ignition-2011" workbook. Even if they did, the spreadsheet lists the engine as a T3 engine when the
email from a Caterpillar representative you provided lists the engine as a T2 engine.
I propose using the T2 emission standards found in 40 CRF Appendix I to Part 1039 (https://www.ecfr.gov/current/title-40/part-1039/appendix-Appendix I to Part
1039). The same emission standards are listed in g/hp-hr in Table 1 of the "Diesel Engine Tier Breakdown" attachment.
I updated the site-wide emission workbook you provided using the emission standards from Appendix I. NOx emissions are conservatively estimated at the "NOx +
NMHC" value. Take a look at the updated spreadsheet. If you're alright with the adjustments I made I'll incorporate the results into Park City Mountain's AO. If not,
I'll be happy to use the emission factors you submitted for the High Meadow engine if you can show where they're sourced.
Let me know and thanks for your time,
Lucia
[Quoted text hidden]
2 attachments
Diesel Engine Tier Breakdown.pdf
577K
Copy of 10-23 Source Submission- 20240724_Park City Sitewide Emissions Workbook revised.xlsx
286K
Jessica Gibbons <[e-mail]>Tue, Oct 29, 2024 at 4:34 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
I am good with the updates you made to the spreadsheet.

Thank you for the explanation and sorry for the confusion.

Best,
[Quoted text hidden]
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…18/19
Lucia Mason <[e-mail]>Tue, Oct 29, 2024 at 4:35 PM
To: Jessica Gibbons <[e-mail]>
Sounds good! Thanks.
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Nov 26, 2024 at 1:43 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
Just to confirm, have all the new engines in this modification already been installed? The permitting language will change slightly if any of the installations haven't
happened yet.
Happy Thanksgiving!
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Tue, Nov 26, 2024 at 2:35 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
Yes, all of the new engines have been installed.

Let me know if any other questions come up.

Thanks,
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Nov 26, 2024 at 3:30 PM
To: Jessica Gibbons <[e-mail]>
Thank you.
[Quoted text hidden]
2/20/25, 10:53 AM State of Utah Mail - Additional Information (Division of Air Quality), 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r1879490975232483578&simpl=msg-a:r-3434899621155276962&simpl=msg-f:1809852922371850010&sim…19/19
Lucia Mason <[e-mail]>
DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
25 messages
Lucia Mason <[e-mail]>Mon, Dec 2, 2024 at 11:59 AM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
The DAQ has completed Park City Mountain Resort's updated Approval Order (site 12403). Before it's issued you have ten days to review the document. Please
get back to me with any questions or concerns by 12/12. If you approve of the document, please return a signed copy. The updated permit is attached.
Hope you had a great Thanksgiving,
Lucia
#5 SOURCE MM RN124030013.rtf
1577K
Jessica Gibbons <[e-mail]>Fri, Dec 6, 2024 at 12:29 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
I have added a few comments on updates that will need to be made. For the emissions calculations I am seeing different totals in the Emissions Workbook than are
in the Approval Order. I am hoping to discuss this and determine where the differences are coming from. I am using the attached copy which was the one with the
last update on 10/29.
I also made a note of the difference in the number of Main vs Secondary engines. One of the engines that was added to the permit in 2019 was mislabeled as a
Secondary engine instead of a Main so the number pulled from the last approval order was incorrect.

Let me know if you have any questions and if you have a few minutes to discuss the emissions calculations.

Thank you for your time,

Jessica Gibbons (she/her)
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…1/14
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152

From: Lucia Mason <[e-mail]>
Sent: Monday, December 2, 2024 12:00 PM
To: Jessica Gibbons <[e-mail]>
Subject: DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort

ATTENTION: This eMail originated from outside of Vail Resorts and may or may not be legitimate. Although we do our best to screen phishing emails, please
use extra caution before opening any attachments or clicking on any links unless you are absolutely sure the source of the email is trusted. If in doubt
about the legitimacy of this email, please use the Report Phish button for validation.
[Quoted text hidden]
The information contained in this message is confidential and intended only for the use of the individual or entity named above, and may be privileged. Any
unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please reply to the sender immediately, stating that you have
received the message in error, then please delete this e-mail. Thank you.
2 attachments
Copy of 10-23 Source Submission- 20240724_Park City Sitewide Emissions Workbook revised.xlsx
286K
#5 SOURCE MM RN124030013 JG Revisions 12-6.rtf
1586K
Jessica Gibbons <[e-mail]>Wed, Dec 11, 2024 at 2:57 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
I am still working through the spreadsheets and I just want to confirm that we can push back the date for when the approval order needs to be returned signed. I am
hoping to figure it all out by tomorrow but I just wanted to double check.

3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…2/14
Thanks!
[Quoted text hidden]
[Quoted text hidden]
Lucia Mason <[e-mail]>Wed, Dec 11, 2024 at 3:26 PM
To: Jessica Gibbons <[e-mail]>
Yes, it's fine to back up the deadline.
That being said, the emission estimates resulting from the removed and replaced engines must be equal to the emission changes documented in the AO. If the
emission changes resulting from the removed and replacement engines are correct then any other inconsistencies in the spreadsheet won't impact the AO potential
to emit values. I bring this up because if you feel confident in the emission changes resulting from this modification then we can continue moving forward with the
AO and fix the spreadsheet on different timelines.
I don't have a preference between waiting a few days to sort out the spreadsheet or moving forward with the AO now. The choice really comes down to how fast
you would like the AO issued.
Best,
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Wed, Dec 11, 2024 at 3:54 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
Here is what I have so far.

1. In 2016 the company bought two resorts and combined them into one. This approval order from that time and this is the original spreadsheet. 08-01-2016 PCMR
Facility Wide Air Permit and 20160816_AO Equipment Data. The emissions in the spreadsheet match the approval order.

2. In 2017 they submitted an approval order, DAQ-2017-004763 – VR CPC Holding Inc, and used the 20170131_Park City NOI Calculations spreadsheet for the
emission calculations. The emissions from the approval order and this spreadsheet match. However, in the Engine Emission Calculations section of the
spreadsheet, the C12 Bonanza engine that was “removed” was listed at 500 Hours of Operation. The 20160816_AO Equipment Data spreadsheet with the
emissions data that matched that approval order, the Bonanza engine listed Hours of Operation as 100. The 2024 Review of 2017 Update spreadsheet I put
together has the emissions calculations for that. You can see the direct difference in the Emissions Calcs tabs. The emissions for the 2017 approval order were
calculated using the difference between the “old” and “new” engines in the 20170131_Park City NOI Calculations spreadsheet which was incorrect.

3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…3/14
You will also see the Bonanza engine that was added in this approval order was listed as 500 hours which is incorrect however, this engine was one of those that
was replace in this approval order so it has been removed from the overall emissions.

Thank you for your help with this.

Jessica Gibbons (she/her)
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152

From: Jessica Gibbons
Sent: Friday, December 6, 2024 12:29 PM
To: Lucia Mason <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
4 attachments
20160816_AO Equipment Data.xlsx
221K
08-01-2016 PCMR Facility Wide Air Permit.pdf
411K
DAQ-2017-004763 12403 - VR CPC Holding Inc. - dba Park City Mountain Resort.pdf
19734K
20170131_Park City NOI Calculations.xlsx
89K
Lucia Mason <[e-mail]>Wed, Dec 11, 2024 at 3:57 PM
To: Jessica Gibbons <[e-mail]>
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…4/14
Thanks for the explanation. I'll look it over and get back to you.
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Thu, Dec 12, 2024 at 12:23 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
I believe you mentioned you may be able to access documents that were submitted with past approval orders. If you have time would you be able to check if you
have the documents that were submitted for the 1/23/2029 Approval Order? The emissions aren’t quite lining up.

No worries if you can’t I just thought I would check because I have not been able to locate those records.
[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Dec 12, 2024 at 1:10 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
It would take a bit of time to find the spreadsheet submitted with the 1/23/19 modification but I was able to pull up the associated engineering review. An
engineering review is a draft AO with added details about the modification. Specifically, take a look at the "reviewer comments." Let me know if it's useful.
I haven't had time to look over the documents you sent yesterday but I'm planning on starting this afternoon.
Best,
Lucia
[Quoted text hidden]
RN124030011-18.rtf
262K
Lucia Mason <[e-mail]>Tue, Dec 17, 2024 at 9:15 AM
To: Jessica Gibbons <[e-mail]>
Hey Jessica,
Do you have a copy of the site-wide emissions spreadsheet before the changes were made regarding the current modification?
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…5/14
Let me know,
Lucia
[Quoted text hidden]
Lucia Mason <[e-mail]>Tue, Dec 17, 2024 at 4:01 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
As per our conversation on the phone earlier today, I'll wait to continue processing the permit until I hear back from you about the emission estimates. Let me know
if you have any questions.
Best,
Lucia
[Quoted text hidden]
Lucia Mason <[e-mail]>Fri, Jan 3, 2025 at 11:12 AM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
I'm emailing to check the status of Park City Mountain Resort's emission calculations. Let me know if you have any updates or questions.
Happy New Year!
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Fri, Jan 3, 2025 at 4:02 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,

I believe I found the causes of the discrepancies in the emissions we have in our spreadsheet and the emissions that are listed in the current AO.

The first came from the 2017 modification. The modified emissions were determined by subtracting the previously listed emissions from the new emissions.
However when this was done, the Bonanza Aux source that was being removed was listed as running 500 hours when it was only permitted for 100 hours in the
previous approval order, resulting in an incorrect change in emissions.
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…6/14
The difference in emissions can be seen in the attached “2024 Review of 2017 Updates” excel sheet, the “Emissions Updates in AO” tab being the incorrect
emissions submitted in 2017, and the “Actual Emissions Updates” tab being what the total should have been.

The second came from the 2023 modification. The modified emissions were determined by subtracting the previously list emissions from the new emissions.
However when this was done, the boiler that was removed was listed at running 3960 hours a year when it had been listed as running 8760 hours in the previous
Approval Orders. The new boilers were listed as running 3960 hours a year which is accurate, but the wrong amount was subtracted so the totals were off. This can
be reviewed in the attached “2024 Review of 2023 Updates” under the tabs “Actual Emissions Updates” and “Emissions Updates in AO.”

I also summarized the total adjustments including the changes for this approval order in the attached “Adjustments for Approval Order” excel sheet.

It may be easier to discuss over the phone so please give a call if you would like to go over it.
[Quoted text hidden]
3 attachments
2024 Review of 2017 updates.xlsx
246K
2024 Review of 2023 Updates.xlsx
242K
Adjustments for Approval Order.xlsx
12K
Lucia Mason <[e-mail]>Thu, Jan 23, 2025 at 3:19 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
I'm checking in about Park City Mountain's emission estimates. Let me know if you have updates or questions.
Best,
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Tue, Feb 4, 2025 at 6:05 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…7/14
I believe I have completed all of the updates so the total emissions will be correct.

In 2016 the company bought two resorts and combined them into one. This approval order from that time and this is the original spreadsheet. 08-01-2016
PCMR Facility Wide Air Permit and 20160816_AO Equipment Data. The emissions in the spreadsheet match the approval order.
In 2017 they submitted an approval order, DAQ-2017-004763 – VR CPC Holding Inc, and used the 20170131_Park City NOI Calculations spreadsheet for
the emission calculations. The emissions from the approval order and this spreadsheet match. However, in the Engine Emission Calculations section of the
spreadsheet, the C12 Bonanza engine that was “removed” was listed at 500 Hours of Operation. The 20160816_AO Equipment Data spreadsheet with the
emissions data that matched that approval order, the Bonanza engine listed Hours of Operation as 100. The emissions for the 2017 approval order were
calculated using the difference between the “old” and “new” engines in the 20170131_Park City NOI Calculations spreadsheet which was incorrect. The
2017 Update spreadsheet I put together is the original 2016 spreadsheet with just the updates listed in the Emissions Increase tab. Also, it looks like the
CO2e for the Used Oil Burner was missed on this submission so it was added to the 2017 Update. The overall emissions increase in the Facility wide tab
match the emissions in the Emissions Increase tab.
In 2019 there was a modification to add one gasoline engine and add one diesel engine - 1-23-19 Approval Order DAQ-AN124030011-19. The emissions
from the change exchange of engine match the overall change in emissions as can be seen in the Emissions Increase tab of the 2019 Update.
In 2023 there was a modification to remove one 7MMBtu boiler and replace it with three 2MMBtu boilers – PCMR Air Permit AP 20230118. As with the 2017
update, the calculations were made by finding the difference between what was added and what was removed however the hours of operation were
incorrect for what was removed, making the total inaccurate. The 2023 Update has the accurate hours removed, consistent with previous iterations on the
permit. The change in emissions from the removal and addition of engines is the same as the overall change in emissions.
For the most recent modification we are working on now, I found that the old Cabriolet engine that replace the old Peak 5 engine were using different
emission factors resulting in the overall emissions not matching up. In the 2024 Update under the Emissions Increase tab I added the old Cabriolet engine to
the “removed” list and added the new Peak 5 engine to the “added” list to balance out the overall emissions.
As I was going through the various iterations of this spreadsheet I noticed that a number of the calculations in the Engine Emission Calcs tab for
Acetaldehyde Emissions (lb/yr) were incorrect. They included /2000 for the equation when this is already being factored in on the Facility wide tab. I adjusted
these so they were correct which resulted in an overall increase in Acetaldehyde emissions.
This should conclude all of the update and all of the overall increases should match the change in emissions from change in emission sources. I have also added a
spreadsheet Adjustments for Approval Order that has the overall total change in emissions.
As always please call if you would like to discuss over the phone as this is a lot of information.
Thank you!
Jessica Gibbons (she/her)
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152
Environmental Compliance Hotline: [phone]
Visit the Environmental Compliance Ops Site for Helpful Resources
[Quoted text hidden]
11 attachments
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…8/14
08-01-2016 PCMR Facility Wide Air Permit.pdf
411K
20160816_AO Equipment Data.xlsx
221K
DAQ-2017-004763 12403 - VR CPC Holding Inc. - dba Park City Mountain Resort.pdf
19734K
20170131_AO Equipment Data.xlsx
228K
1-23-19 Approval Order DAQE-AN124030011-19.pdf
4860K
PCMR Air Permit AP 20230118.pdf
522K
2017 Update.xlsx
238K
2019 Update.xlsx
233K
2023 Update.xlsx
236K
2024 Update.xlsx
253K
Adjustments for Approval Order.xlsx
11K
Jessica Gibbons <[e-mail]>Wed, Feb 5, 2025 at 3:50 PM
To: Lucia Mason <[e-mail]>
Hi Lucia,
Attached is a revised copy of the 2024 Update with comments on the items that need to be retroactively updated. You will find them highlighted in orange. In the
Engine Emission Calcs tab you will see the information for the 2017 update for Bonanza with incorrect hours and the updates to overall acetaldehyde emission
calculations. In the Used Oil Burner Calcs tab you will see the update for the CO2e that was missed on the 2017 Update. And on the Boilers & Water Heaters Calcs
tab you will see the comments on the 2023 boiler replacement.

Please let me know if you need any other information.

Thanks!
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&simpl…9/14
[Quoted text hidden]
2024 Update revised.xlsx
256K
Lucia Mason <[e-mail]>Wed, Feb 5, 2025 at 4:31 PM
To: Jessica Gibbons <[e-mail]>
Thanks Jessica. I'll look it over tomorrow and work on incorporating the retroactive updates into Park City's permit. I really appreciate the time you put into this.
Hopefully I'll return an updated draft for review soon.
[Quoted text hidden]
Lucia Mason <[e-mail]>Mon, Feb 10, 2025 at 10:02 AM
To: Jessica Gibbons <[e-mail]>
Hey Jessica,
Do you have the spreadsheet Park City submitted with the 2023 NOI? You might have sent it to me before but I'm having a hard time finding it.
Thanks,
Lucia
[Quoted text hidden]
Jessica Gibbons <[e-mail]>Mon, Feb 10, 2025 at 11:17 AM
To: Lucia Mason <[e-mail]>
Hi Lucia,
The spreadsheet wasn’t submitted with the NOI in 2023. I did not have access to the spreadsheet at the time of submission. I have attached the 2023 Update that I
built during this process. On the Emission Increase tab you can see the emissions calculations for the boiler that was removed at 8760 hours per year as well as
the emission calculations for that same boiler at 3960 hours per year. I found this using an older iteration of the spreadsheet with the old boiler in it and changing
the hours/year to 3960. The emissions from the boiler at 3960 hours match those in the 2023 approval order.

Let me know if you need more information.

Thanks!

3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&sim…10/14
Jessica Gibbons (she/her)
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152
Environmental Compliance Hotline: [phone]
Visit the Environmental Compliance Ops Site for Helpful Resources

[Quoted text hidden]
2 attachments
2023 Update.xlsx
237K
PCMR Air Permit AP 20230118.pdf
522K
Lucia Mason <[e-mail]>Wed, Feb 12, 2025 at 11:19 AM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
Thanks for the explanation. I've looked over all the retroactive emission corrections and they look good! However, the 2024 emission changes don't match those
that were originally calculated. For instance, originally the NOx emissions were estimated to drop by 4.60 tpy due to the engine changes but in the "2024 Update"
spreadsheet they're calculated to drop by 4.78 tpy. Do you know what caused the change? I've attached a spreadsheet I put together that summarizes all the
changes and error corrections made in this modification so you can see the information I'm working from.
Feel free to give me a call if talking over the phone is easier.
Best,
Lucia
[Quoted text hidden]
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&sim…11/14
DAQ Retroactive Calculation Comparison.xlsx
47K
Lucia Mason <[e-mail]>Tue, Feb 25, 2025 at 4:38 PM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
I've attached an updated Approval Order draft. I'm still waiting to hear back from one internal reviewer; it's possible I will make some additional small adjustments to
the draft after I hear back from the them. I thought it made sense to send the draft to you now regardless given that you're very familiar with the emission
corrections and engine changes that that took place. Let me know if you have any comments or questions. If you approve of the document I'll reach out once I hear
back from all internal reviews to ask you for a signed copy.
Best,
Lucia
[Quoted text hidden]
DAQE-RN124030013-25.rtf
1609K
Lucia Mason <[e-mail]>Wed, Feb 26, 2025 at 8:23 AM
To: Jessica Gibbons <[e-mail]>
Hey Jessica,
I heard back from the last internal reviewer this morning. I've attached the updated Approval Order. Let me know if you have any comments or questions in the next
10 days (by 3/8). If you approve of the document please return a signed copy.
Thanks!
Lucia
[Quoted text hidden]
DAQE-RN124030013-25.rtf
1605K
Jessica Gibbons <[e-mail]>Fri, Feb 28, 2025 at 6:37 PM
To: Lucia Mason <[e-mail]>
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&sim…12/14
Hi Lucia,
Thank you for sending this over. I have reviewed it with my team and everything looks accurate except for a few instances where an engine with a 174 hp was listed
as having a 147 hp. I highlighted them in the attached draft. Otherwise, we should be ready to sign once these updates are made.
[Quoted text hidden]
DAQE-RN124030013-25 rev.rtf
1613K
Lucia Mason <[e-mail]>Mon, Mar 3, 2025 at 8:02 AM
To: Jessica Gibbons <[e-mail]>
Hi Jessica,
Thanks for catching the incorrect engine rating. I've attached an updated draft. Let me know if you have additional comments.
Thanks!
Lucia
[Quoted text hidden]
DAQE-RN124030013-25.rtf
1604K
Jessica Gibbons <[e-mail]>Tue, Mar 4, 2025 at 10:20 AM
To: Lucia Mason <[e-mail]>
Cc: Deirdra Walsh <[e-mail]>, Michael Lewis <[e-mail]>, Nick Dana <[e-mail]>, Lynne Offret
<[e-mail]>, Amber Bens <[e-mail]>, Jacob Zeihen <[e-mail]>, Owen Greene
<[e-mail]>
Morning Lucia,
Please see the attached, signed Approval Order. Let me know if you need any other information.

Thank you!

Jessica Gibbons (she/her)
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&sim…13/14
Regional Compliance Analyst
Park City Mountain Resort
Cell: 906-235-3152

[Quoted text hidden]
DAQE-RN124030013-25.rtf.pdf
813K
Lucia Mason <[e-mail]>Tue, Mar 4, 2025 at 10:31 AM
To: Jessica Gibbons <[e-mail]>
Thank you! I'll reach out if any additional questions come up.
[Quoted text hidden]
3/4/25, 10:38 AM State of Utah Mail - DAQ Approval Order Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r2959303210376565941&simpl=msg-a:r4450327352593780788&simpl=msg-f:1817720525731432105&sim…14/14
Lucia Mason <[e-mail]>
Modeling Initial Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
2 messages
Lucia Mason <[e-mail]>Thu, Oct 31, 2024 at 12:32 PM
To: Jason Krebs <[e-mail]>, Dave Prey <[e-mail]>
Hi Jason and Dave,
Could you do an initial modeling review of Park City Mountain's application for a minor modification? They're removing five and adding nine emergency engines.
The modification will result in a small increase in SO2 emissions (0.36 tpy).
Let me know if you need any additional information or have any questions.
Thanks,
Lucia
MM, 12403 VR CPC Holding, Inc. - dba Park City Mou…
Jason Krebs <[e-mail]>Thu, Oct 31, 2024 at 2:02 PM
To: Lucia Mason <[e-mail]>
Cc: Dave Prey <[e-mail]>
This project's SO2 emissions and increase do not trigger modeling, and it appears that all other criteria pollutants will decrease. As such, no modeling is necessary,
and I will sign off on the WAL.
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]
195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
2/20/25, 10:52 AM State of Utah Mail - Modeling Initial Review, 12403: VR CPC Holding, Inc. - dba Park City Mountain Resort
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r6630914857442238371&simpl=msg-a:r-6999170741815987467&simpl=msg-f:1814461144846587957 1/1
BACT Analysis Template
1. Project Overview
• Project Name: Park City Mountain Resort Air Permit Modification
• Location: Park City Mountain Resort
• Project Description: To update the air permit to include additional, not permitted
engines.
2. Emission Sources
Source: Payday Auxiliary Engine
Selected Equipment: T2 Main Diesel Emergency Engine – Caterpillar C18 (800 HP, CI 2019)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. It was also the appropriate size of engine. Cummins made a
similar model but it would not provide the necessary output at the lift terminal elevations or fit in the lift
terminals. Tier 4 Final engines are difficult to use in the lift terminal setting because they can be exposed
to cold temperatures and the DEF used in them would freeze. Since they rarely operate, they can run
into regen issues because they never fully warm up.

Source: Bonanza Auxiliary Engine
Selected Equipment: T2 Main Diesel Emergency Engine – Caterpillar C18 (800 HP, CI 2019)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. It was also the appropriate size of engine. Cummins made a
similar model but it would not provide the necessary output at the lift terminal elevations or fit in the lift
terminals. Tier 4 Final engines are difficult to use in the lift terminal setting because they can be exposed
to cold temperatures and the DEF used in them would freeze. Since they rarely operate, they can run
into regen issues because they never fully warm up.

Source: Silverlode Auxiliary Engine
Selected Equipment: T2 Main Diesel Emergency Engine – Caterpillar C18 (800 HP, CI, 2019)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. It was also the appropriate size of engine. Cummins made a
similar model but it would not provide the necessary output at the lift terminal elevations or fit in the lift
terminals. Tier 4 Final engines are difficult to use in the lift terminal setting because they can be exposed
to cold temperatures and the DEF used in them would freeze. Since they rarely operate, they can run
into regen issues because they never fully warm up.

Source: High Meadow Evac Engine
Selected Equipment: T4 Secondary Diesel Emergency Engine Caterpillar C2.2 (66 hp, CI, 2018)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. The size of the engine allowed it to fit in the lift terminal. Tier 4
Final engines are difficult to use in the lift terminal setting because they can be exposed to cold
temperatures and the DEF used in them would freeze. Since they rarely operate, they can run into regen
issues because they never fully warm up.

Source: Red Pine Gondola Evac Engine
Selected Equipment: T3 Secondary Diesel Emergency Engine - Cummins QSB4.5 (152 hp, CI, 2020)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. The size of the engine allowed it to fit in the lift terminal. Tier 4
Final engines are difficult to use in the lift terminal setting because they can be exposed to cold
temperatures and the DEF used in them would freeze. Since they rarely operate, they can run into regen
issues because they never fully warm up.

Source: Cabriolet Auxiliary Engine
Selected Equipment: T3 Main Diesel Emergency Engine – Caterpillar C9 (275 hp, CI, 2019)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. It was also the appropriate size of engine. Tier 4 Final engines are
difficult to use in the lift terminal setting because they can be exposed to cold temperatures and the DEF
used in them would freeze. Since they rarely operate, they can run into regen issues because they never
fully warm up.

Source: Cabriolet Evac Engine
Selected Equipment: T3 Secondary Diesel Emergency Engine – Perkins 1104D-44T(C4.4) (99.9 hp, CI,
2018)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation in an emergency situation. The size of the engine allowed it to fit
in the lift terminal. Tier 4 Final engines are difficult to use in the lift terminal setting because they can be
exposed to cold temperatures and the DEF used in them would freeze. Since they rarely operate, they
can run into regen issues because they never fully warm up.

Source: Over and Out Auxiliary Engine
Selected Equipment: T3 Main Diesel Emergency Engine – Cummins QBB4.5 (121 hp, CI, 2019)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. The size of the engine allowed it to fit in the lift terminal. Tier 4
Final engines are difficult to use in the lift terminal setting because they can be exposed to cold
temperatures and the DEF used in them would freeze. Since they rarely operate, they can run into regen
issues because they never fully warm up.

Source: Over and Out Evac Engine
Selected Equipment: T4 Secondary Diesel Emergency Engine – Doosan D18NAP (50 hp, CI, 2016)
Justification: This model was chosen because it had the power density and power output required to
operate the lift at the given elevation. The size of the engine allowed it to fit in the lift terminal. Tier 4
Final engines are difficult to use in the lift terminal setting because they can be exposed to cold
temperatures and the DEF used in them would freeze. Since they rarely operate, they can run into regen
issues because they never fully warm up.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2019 MODEL YEAR
CERTIFICATE OF CONFORMITY
WITH THE CLEAN AIR ACT
OFFICE OF TRANSPORTATION
AND AIR QUALITY
ANN ARBOR, MICHIGAN 48105
Certificate Issued To:Caterpillar Inc.
(U.S. Manufacturer or Importer)
Certificate Number: KCPXL08.8NZS-005
Effective Date:
07/24/2018
Expiration Date:
12/31/2019
_________________________
Byron J. Bunker, Division Director
Compliance Division
Issue Date:
07/24/2018
Revision Date:
N/A
Model Year: 2019
Manufacturer Type: Original Engine Manufacturer
Engine Family: KCPXL08.8NZS
Mobile/Stationary Indicator: Stationary
Emissions Power Category: 225<=kW<450
Fuel Type: Diesel
After Treatment Devices: No After Treatment Devices Installed
Non-after Treatment Devices: Electronic Control, Engine Design Modification
Pursuant to Section 111 and Section 213 of the Clean Air Act (42 U.S.C. sections 7411 and 7547) and 40 CFR Part 60, and subject to the terms and conditions prescribed in those provisions, this certificate of
conformity is hereby issued with respect to the test engines which have been found to conform to applicable requirements and which represent the following engines, by engine family, more fully described in
the documentation required by 40 CFR Part 60 and produced in the stated model year.
This certificate of conformity covers only those new compression-ignition engines which conform in all material respects to the design specifications that applied to those engines described in the
documentation required by 40 CFR Part 60 and which are produced during the model year stated on this certificate of the said manufacturer, as defined in 40 CFR Part 60.
It is a term of this certificate that the manufacturer shall consent to all inspections described in 40 CFR 1068 and authorized in a warrant or court order. Failure to comply with the requirements of such a
warrant or court order may lead to revocation or suspension of this certificate for reasons specified in 40 CFR Part 60. It is also a term of this certificate that this certificate may be revoked or suspended or
rendered void ab initio for other reasons specified in 40 CFR Part 60.
This certificate does not cover engines sold, offered for sale, or introduced, or delivered for introduction, into commerce in the U.S. prior to the effective date of the certificate.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2018 MODEL YEAR
CERTIFICATE OF CONFORMITY
WITH THE CLEAN AIR ACT
OFFICE OF TRANSPORTATION
AND AIR QUALITY
ANN ARBOR, MICHIGAN 48105
Certificate Issued To:Perkins Engines Co Ltd
(U.S. Manufacturer or Importer)
Certificate Number: JPKXL04.4NL1-016
Effective Date:
10/30/2017
Expiration Date:
12/31/2018
_________________________
Byron J. Bunker, Division Director
Compliance Division
Issue Date:
10/30/2017
Revision Date:
N/A
Model Year: 2018
Manufacturer Type: Original Engine Manufacturer
Engine Family: JPKXL04.4NL1
Mobile/Stationary Indicator: Stationary
Emissions Power Category: 56<=kW<75
Fuel Type: Diesel, Non-Standard Fuel
After Treatment Devices: No After Treatment Devices Installed
Non-after Treatment Devices: Smoke Puff Limiter
Pursuant to Section 111 and Section 213 of the Clean Air Act (42 U.S.C. sections 7411 and 7547) and 40 CFR Part 60, and subject to the terms and conditions prescribed in those provisions, this certificate of
conformity is hereby issued with respect to the test engines which have been found to conform to applicable requirements and which represent the following engines, by engine family, more fully described in
the documentation required by 40 CFR Part 60 and produced in the stated model year.
This certificate of conformity covers only those new compression-ignition engines which conform in all material respects to the design specifications that applied to those engines described in the
documentation required by 40 CFR Part 60 and which are produced during the model year stated on this certificate of the said manufacturer, as defined in 40 CFR Part 60.
It is a term of this certificate that the manufacturer shall consent to all inspections described in 40 CFR 1068 and authorized in a warrant or court order. Failure to comply with the requirements of such a
warrant or court order may lead to revocation or suspension of this certificate for reasons specified in 40 CFR Part 60. It is also a term of this certificate that this certificate may be revoked or suspended or
rendered void ab initio for other reasons specified in 40 CFR Part 60.
This certificate does not cover engines sold, offered for sale, or introduced, or delivered for introduction, into commerce in the U.S. prior to the effective date of the certificate.
The actual engine power may lie outside the limits of the Emissions Power Category shown above. See the certificate application for details.
Lucia Mason <[e-mail]>
Park City Engines
4 messages
Lucia Mason <[e-mail]>Thu, Sep 12, 2024 at 10:41 AM
To: Christine Bodell <[e-mail]>
Copy- 20240724_Park City Sitewide Emissions Workbook.xlsx
250K
Christine Bodell <[e-mail]>Thu, Sep 12, 2024 at 10:49 AM
To: Lucia Mason <[e-mail]>
On Thu, Sep 12, 2024 at 10:42 AM Lucia Mason <[e-mail]> wrote:
RN104060018 (7).rtf
1605K
Christine Bodell <[e-mail]>Thu, Sep 12, 2024 at 10:53 AM
To: Lucia Mason <[e-mail]>
[Quoted text hidden]
RN162090001 (14).rtf
1542K
Christine Bodell <[e-mail]>Thu, Sep 12, 2024 at 10:53 AM
To: Lucia Mason <[e-mail]>
2/20/25, 10:52 AM State of Utah Mail - Park City Engines
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7340843096075521260&simpl=msg-a:r-7178899672120999976&simpl=msg-f:1810009730138122964&simpl…1/2
[Quoted text hidden]
RN162210001 (5).rtf
1539K
2/20/25, 10:52 AM State of Utah Mail - Park City Engines
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-7340843096075521260&simpl=msg-a:r-7178899672120999976&simpl=msg-f:1810009730138122964&simpl…2/2
1
Jessica Gibbons
From:COLLINS Adam <[e-mail]>
Sent:Thursday, October 3, 2024 1:18 PM
To:Jessica Gibbons
Subject:Re: Park City Mountain Resort Lift Backup Engine Information
Attachments:CAT C18-800hp-E Power Curves.png; C18-800hp DM7702.pdf; C9_ACERT_205bkW.pdf
ATTENTION: This eMail originated from outside of Vail Resorts and may or may not be legitimate. Although
we do our best to screen phishing emails, please use extra caution before opening any attachments or
clicking on any links unless you are absolutely sure the source of the email is trusted. If in doubt about the
legitimacy of this email, please use the Report Phish button for validation.

Hi Jessica,

I worked with Wheeler CAT in Salt Lake City for these projects. I believe at the time they told me they had an
employee whose job it was to do State and County EPA compliance with their engines. I never had anything to
do with that as they told me they were taking care of it. I think it was Molly Stephens at Wheeler CAT. I
chose CAT because of the power density and engine availability. I had Cummins quote engines for this as well,
but they were not able to provide the necessary output at the lifts elevation with an engine that would fit in
the existing lift configurations. These C18 engines barely fit in the existing terminals and we had to remove
the entire roof structure on all three lifts to even remove and replace these engines.

The three CAT C18's were spec'd all the same for Payday, Bonanza, Silverlode. They are Tier 2 800hp
Industrial-E rated. I have attached a power graph and the emissions output data that I have for these
engines. The EPA has an engine replacement program where you can use a Tier 3 or even Tier 2 in places
where an older, possibly non emissions rated engine existed. The original engines that we replaced were 18-
liter Detroit Diesel engines. Also, I believe 800hp and above stationary diesel engines are exempt from some
typical EPA regulations. Another reminder that these engines are rarely used under full load to produce
anywhere near the data sheets emissions. 90+% of these diesel engines hours are used with the lift empty, or
idle time warming up.

For the Cabriolet, the CAT C9 is a Tier 3 275hp engine. I chose this engine with CAT because they were
providing the other 3 engines for us. We purchased a tertiary, or evac engine, for the Cabriolet from CAT as
well. So, I put 2 new engines in the Cabriolet in 2019. This lift did not have an auxiliary engine, only an evac
engine that was sized to run faster than a typical evac, but not full speed as an auxiliary engine provides. The
Tier 3 CAT C9 replaced an existing Cummins BT5.9-liter engine. I actually replaced Peak 5's gasoline evac
engine with this Cabriolet take out Cummins 5.9L diesel engine in 2021.

All of the CAT engines that Skytrac supplied are electronically controlled diesel engines. All of the engines we
removed were mechanically injected diesel engines.

In the Ski Lift industry, new Ski Lifts comply with EPA standards, but Ski Lift manufacturers are able to provide
Tier 3 engines because they are stationary back up power units. I believe EPA classifies them as Stationary
Stand-by Power Units. The EPA has regulations on annual run time for these engines, but the maintenance
and ANSI B77 regulations for diesel engines in Ski Lifts fall far short of the EPA annual hour limits. The engine
2
manufactures take care of any of our EPA requirements, otherwise they would not be able to sell these
engines to us. Also, Tier 4 final engines that all have after treatment, DEF, will freeze in a Ski Lift terminal. Ski
Lifts do not operate much on these diesel engines, so when a T4 Final engine is used it runs into regen issues
because the engine never warms up enough to perform an adequate regeneration cycle. T4 Final engines are
a bad fit for the use in a Ski Lift as they rarely, if ever, see a full load.

I'm not sure what the attachments were that you sent, but they did not come through.

Let me know if you need anything else.

Thanks,
From: Jessica Gibbons <[e-mail]>
Sent: Thursday, October 3, 2024 11:18 AM
To: COLLINS Adam <[e-mail]>
Subject: Park City Mountain Resort Lift Backup Engine Information

Good Morning,
My name is Jessica Gibbons, I am a Compliance Specialist at Park City Mountain Resort, I got your contact information
from Alex McCann. We are in the process of reviewing and updating our air permit and I am looking for some
information about some of the backup generator engines that were installed in our lifts by Skytrac in 2019.

Specifically we are looking for spec sheets that would have either the EPA Tier rating and/or emission factors for the
following engines.
 Payday Auxiliary – Caterpillar C18 Serial # WRH12039
 Bonanza Auxiliary – Caterpillar C18 Serial # WRH11960
 Silverlode Auxiliary – Caterpillar C18 Serial # WRH11961
 Cabriolet Auxiliary – Caterpillar C9 Serial # REH13474

Also, if you could give a brief description why these engines were chosen over other options, whether it was cost, fit,
power availability, etc.

Please let me know if you need any more information of if there is someone else I should reach out to for this
information.

Thank you for your time,

Jessica Gibbons (she/her)
Regional Compliance Specialist
Park City Mountain Resort
Cell: 906-235-3152
Environmental Compliance Hotline: [phone]
Visit the Environmental Compliance Ops Site for Helpful Resources
3E SDS Library

The information contained in this message is confidential and intended only for the use of the individual or entity named
above, and may be privileged. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the
intended recipient, please reply to the sender immediately, stating that you have received the message in error, then
please delete this e-mail. Thank you.
You don't often get email from [e-mail]. Learn why this is important
1
Jessica Gibbons
From:Pramod Thimmappa <[e-mail]>
Sent:Wednesday, October 16, 2024 10:31 AM
To:Jessica Gibbons
Subject:ERCR-107847 Emissions Certification/Conformance Information Request
ATTENTION: This eMail originated from outside of Vail Resorts and may or may not be legitimate. Although
we do our best to screen phishing emails, please use extra caution before opening any attachments or
clicking on any links unless you are absolutely sure the source of the email is trusted. If in doubt about the
legitimacy of this email, please use the Report Phish button for validation.

—-—-—-—
Reply above this line.
Pramod Thimmappa updated a comment:
Greetings,
Thank you for reaching out to us,
Engine Serial number C6M09001 is labelled as EPA Emergency Stationary Certified when it was produced. It is
equivalent to Tier 2 Emissions. Engine Family : JH3XL2.22TIC..
Regards,
Engine certification 1
Disclaimer: The information provided has been compiled from sources believed to be reliable and is accurate to the
best of Caterpillar's knowledge; however, Caterpillar does not guarantee the accuracy, completeness, and validity of
the information and cannot be held liable for any errors or omissions. All information provided should be
independently verified and confirmed, and you should not rely solely upon the information provided. One potential
method to independently verify the information provided is to examine the emissions label located on the engine.
New Emissions Resources: Caterpillar is improving the way you get access to the engine emissions and regulatory
information you need. Caterpillar has launched two new applications aimed at providing faster delivery of product
regulatory specific information such as the regulatory status, certification family and emissions certificates for
Caterpillar built products. These applications are:
•The new CAT Compliance Mobile App. Caterpillar’s first engine emissions compliance data mobile app is ready to
download and will deliver real-time engine emissions status data and certificate information right to your fingertips,
24/7.
•The new Caterpillar Engine Emissions Certificate Repository web site. Caterpillar has developed a new web
application where users may enter the serial number, engine family name or approval number of a CAT engine or
machine product to quickly see and/or download the engine emissions certificate.
With these new applications, Caterpillar intends to not only improve the accessibility of information for the users who
need it most, but also build on our commitment to success by offering new streamlined channels to data and support
from those who champion it.
2
To access the new CAT Compliance mobile application, please visit your Google Android or Apple app store and
search "CAT Compliance."
For further details and access to the new Caterpillar Engine Emissions Certificate Repository web site, please visit
the "Caterpillar Engine Emissions Certificate Repository" here: EECR | Caterpillar.
Pramod Thimmappa resolved this as Done.
Pramod Thimmappa changed the status to Resolved.
Pramod Thimmappa changed the status to Closed.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2019 MODEL YEAR
CERTIFICATE OF CONFORMITY
WITH THE CLEAN AIR ACT
OFFICE OF TRANSPORTATION
AND AIR QUALITY
ANN ARBOR, MICHIGAN 48105
Certificate Issued To:Cummins Inc.
(U.S. Manufacturer or Importer)
Certificate Number: KCEXL0275AAG-046
Effective Date:
11/27/2018
Expiration Date:
12/31/2019
_________________________
Byron J. Bunker, Division Director
Compliance Division
Issue Date:
11/27/2018
Revision Date:
N/A
Model Year: 2019
Manufacturer Type: Original Engine Manufacturer
Engine Family: KCEXL0275AAG
Mobile/Stationary Indicator: Stationary
Emissions Power Category: 75<=kW<130
Fuel Type: Diesel
After Treatment Devices: No After Treatment Devices Installed
Non-after Treatment Devices: No Non-After Treatment Devices Installed
Pursuant to Section 111 and Section 213 of the Clean Air Act (42 U.S.C. sections 7411 and 7547) and 40 CFR Part 60, and subject to the terms and conditions prescribed in those provisions, this certificate of
conformity is hereby issued with respect to the test engines which have been found to conform to applicable requirements and which represent the following engines, by engine family, more fully described in
the documentation required by 40 CFR Part 60 and produced in the stated model year.
This certificate of conformity covers only those new compression-ignition engines which conform in all material respects to the design specifications that applied to those engines described in the
documentation required by 40 CFR Part 60 and which are produced during the model year stated on this certificate of the said manufacturer, as defined in 40 CFR Part 60.
It is a term of this certificate that the manufacturer shall consent to all inspections described in 40 CFR 1068 and authorized in a warrant or court order. Failure to comply with the requirements of such a
warrant or court order may lead to revocation or suspension of this certificate for reasons specified in 40 CFR Part 60. It is also a term of this certificate that this certificate may be revoked or suspended or
rendered void ab initio for other reasons specified in 40 CFR Part 60.
This certificate does not cover engines sold, offered for sale, or introduced, or delivered for introduction, into commerce in the U.S. prior to the effective date of the certificate.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2020 MODEL YEAR
CERTIFICATE OF CONFORMITY
WITH THE CLEAN AIR ACT
OFFICE OF TRANSPORTATION
AND AIR QUALITY
ANN ARBOR, MICHIGAN 48105
Certificate Issued To:Cummins Inc.
(U.S. Manufacturer or Importer)
Certificate Number: LCEXL0275AAG-024
Effective Date:
07/08/2019
Expiration Date:
12/31/2020
_________________________
Byron J. Bunker, Division Director
Compliance Division
Issue Date:
07/08/2019
Revision Date:
N/A
Model Year: 2020
Manufacturer Type: Original Engine Manufacturer
Engine Family: LCEXL0275AAG
Mobile/Stationary Indicator: Stationary
Emissions Power Category: 75<=kW<130
Fuel Type: Diesel
After Treatment Devices: No After Treatment Devices Installed
Non-after Treatment Devices: No Non-After Treatment Devices Installed
Pursuant to Section 111 and Section 213 of the Clean Air Act (42 U.S.C. sections 7411 and 7547) and 40 CFR Part 60, and subject to the terms and conditions prescribed in those provisions, this certificate of
conformity is hereby issued with respect to the test engines which have been found to conform to applicable requirements and which represent the following engines, by engine family, more fully described in
the documentation required by 40 CFR Part 60 and produced in the stated model year.
This certificate of conformity covers only those new compression-ignition engines which conform in all material respects to the design specifications that applied to those engines described in the
documentation required by 40 CFR Part 60 and which are produced during the model year stated on this certificate of the said manufacturer, as defined in 40 CFR Part 60.
It is a term of this certificate that the manufacturer shall consent to all inspections described in 40 CFR 1068 and authorized in a warrant or court order. Failure to comply with the requirements of such a
warrant or court order may lead to revocation or suspension of this certificate for reasons specified in 40 CFR Part 60. It is also a term of this certificate that this certificate may be revoked or suspended or
rendered void ab initio for other reasons specified in 40 CFR Part 60.
This certificate does not cover engines sold, offered for sale, or introduced, or delivered for introduction, into commerce in the U.S. prior to the effective date of the certificate.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2016 MODEL YEAR
CERTIFICATE OF CONFORMITY
WITH THE CLEAN AIR ACT
OFFICE OF TRANSPORTATION
AND AIR QUALITY
ANN ARBOR, MICHIGAN 48105
Certificate Issued To:Doosan Infracore Co., Ltd.
(U.S. Manufacturer or Importer)
Certificate Number: GDICL01.8LEA-007
Effective Date:
12/07/2015
Expiration Date:
12/31/2016
_________________________
Byron J. Bunker, Division Director
Compliance Division
Issue Date:
12/07/2015
Revision Date:
N/A
Model Year: 2016
Manufacturer Type: Original Engine Manufacturer
Engine Family: GDICL01.8LEA
Mobile/Stationary Indicator: Both
Emissions Power Category: 19<=kW<37
Fuel Type: Diesel
After Treatment Devices: Diesel Oxidation Catalyst
Non-after Treatment Devices: Electronic/Electric EGR - Cooled
Pursuant to Section 111 and Section 213 of the Clean Air Act (42 U.S.C. sections 7411 and 7547) and 40 CFR Parts 60 and 1039, and subject to the terms and conditions prescribed in those provisions, this
certificate of conformity is hereby issued with respect to the test engines which have been found to conform to applicable requirements and which represent the following engines, by engine family, more
fully described in the documentation required by 40 CFR Parts 60 and 1039 and produced in the stated model year.
This certificate of conformity covers only those new compression-ignition engines which conform in all material respects to the design specifications that applied to those engines described in the
documentation required by 40 CFR Parts 60 and 1039 and which are produced during the model year stated on this certificate of the said manufacturer, as defined in 40 CFR Parts 60 and 1039.
It is a term of this certificate that the manufacturer shall consent to all inspections described in 40 CFR 1068 and authorized in a warrant or court order. Failure to comply with the requirements of such a
warrant or court order may lead to revocation or suspension of this certificate for reasons specified in 40 CFR Parts 60 and 1039. It is also a term of this certificate that this certificate may be revoked or
suspended or rendered void ab initio for other reasons specified in 40 CFR Parts 60 and 1039.
This certificate does not cover engines sold, offered for sale, or introduced, or delivered for introduction, into commerce in the U.S. prior to the effective date of the certificate.

August 29, 2024

Alan Humpherys
Utah Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4830

Subject: VR CPC Holding, Incorporated dba Park City Mountain Resort, Modification to
Approval Order (AO) DAQE-AN124030012-23

Dear Mr. Alan Humpherys:

VR CPC Holdings, Inc. doing business as Park City Mountain Resort (“PCMR”) is requesting to
make changes to the existing approval order DAQE-AN124030012-23 dated January 18, 2023 to
add to and update the approved equipment list. Below is a brief summary of changes to be made.
Supporting background information and emission calculations are included with this submittal.

II.A.2 Main Emergency Generator Engines
Quantity: Twenty-six (26)
Cumulative site-wide rating: 12,872 hp
Maximum rating: 1,046 hp
Minimum rating: 150 hp

II.A.3 Secondary Emergency Generator Engines
Quantity: Twenty-eight (28)
Fuel: Twenty-five (25) Diesel
Fuel: Three (3) Gasoline (all manufactured prior to 2009)
Cumulative site-wide rating: 4,932 hp
Maximum rating: 335 hp
Minimum rating: 35 hp

Please reach out to 303-404-8000 or [e-mail] if you have any questions
or require any further information.

Docusign Envelope ID: 4AE7E6EF-F374-4D77-BA68-872B177406C3
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
8/29/2024
4
VR CPC Holdings, Inc.- dba Park City Mountain Resort
PO Box 39
Park City, UT 84060
[phone]
Jessica Gibbons
[phone]
[e-mail]
Park City Mountain Resort
1310 Lowell Ave.
Park City, UT 84060
Summit
Zone 12 Datum NAD83
452,933 m Easting
4,503,939 m Northing
7999
AN124030012-23 01 18 23
Modifying equipment list as follows:
Main Emergency Generator Engines Quantity: 26
-Cumulative Site-Wide Rating 12872 HP
Secondary Emergency Generator Engines Quantity: 28 - 25 Diesel Fuel, 3 Gasoline
-Cumulative Site-Wide Rating: 4932 HP

4
Docusign Envelope ID: 4AE7E6EF-F374-4D77-BA68-872B177406C3
[e-mail]
Deirdra Walsh 435-647-5402 Aug-29-2024
VP& COO Park City Mountain
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1.Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2.Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3.Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4.Does new emission unit affect existing
permitted process limits?
Yes No
5.Condition(s) Changing:
6.Description of Permit/Process Change**
7.New or modified materials and quantities used in process. **
Material Quantity Annually
8.New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
VR CPC Holdings, Inc.
Park City Mountain Resort
DAQE - AN124030012-23
Additional Emergency Generator Engines
Increase in cumulative horsepower
4
NA
4
NA
Modifying equipment list as follows:
Main Emergency Generator Engines Quantity: 26
-Cumulative Site-Wide Rating 12872 HP
Secondary Emergency Generator Engines Quantity: 28 - 25 Diesel Fuel, 3 Gasoline
-Cumulative Site-Wide Rating: 4932 HP
NA
See Appendix A
Docusign Envelope ID: 4AE7E6EF-F374-4D77-BA68-872B177406C3
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
VR CPC Holdings, Inc.
Park City Mountain Resort
2.27 -0.10 2.20
2.27 -0.10 2.20
2.27 -0.10 2.20
27.26 -0.80 26.50
1.37 2.00 3.40
12.49 -0.51 12.00
3.83 -0.33 3.50
9,382.00
0.20
0.02
9,340.00 50.00 9,390.00
Acetaldehyde (CAS #75070) 0.00 0.00 0.00 0.00
Acrolein (CAS #107028)0.00 0.00 0.00 0.00
Benzene (CAS #71432)0.00 0.00 0.01 0.00
Formaldehyde (CAS #50000)0.01 0.01 0.00 0.00
Generic HAPs (CAS #GHAPS)0.01 -0.01 0.00 -0.00
Hexane (CAS #110543)0.12 -0.00 0.12 0.00
Naphthalene (CAS #91203)0.00 0.00 0.00 -0.00
Toluene (CAS #108883)0.00 0.00 0.00 0.00
Xylenes (CAS #1330207)0.00 0.00 0.00 0.00
0.15 -0.01 0.14 -0.00
Docusign Envelope ID: 4AE7E6EF-F374-4D77-BA68-872B177406C3
Utah Division of Air Quality
New Source Review Section
Form 17
Comp __any: _________________
Site/Source: _________________
Date: _______________________
Diesel Powered Standby Generator
Company Information
1. Company Name and Address:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
2. Company Contact:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
3. Installation Address:
____________________________________________ County where facility is located: __________________
____________________________________________
____________________________________________ Latitude, Longitude and UTM Coordinates of Facility
____________________________________________ __________________________________________
Phone Number: _______________________________ __________________________________________
Fax Number: _______________________________
Standby Generator Information
4. Engines:
Maximum Maximum Emission Rate Date the engine
Manufacturer Model Rated Hours of Rate of NOx was constructed
Horsepower or Kilowatts Operation grams/BHP-HR or reconstructed
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
Attach Manufacturer-supplied information
5. Calculated emissions for this equipment:
PM10____________ Lbs/hr _____________Tons/yr PM2.5____________ Lbs/hr _____________Tons/yr
NOx_____________Lbs/hr______________Tons/yr SOx ____________ Lbs/hr______________Tons/yr
CO _____________Lbs/hr______________Tons/yr VOC ____________Lbs/hr______________Tons/yr
CO2 ____________Tons/yr CH4 ____________ Tons/yr
N2O ____________Tons/yr
HAPs___________ Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
VR CPC Holdings, Inc.
Park City Mountain Resort
8/29/2024
VR CPC Holdings, Inc.- dba Park City Mountain Resort
PO Box 39
Park City, UT 84060
Jessica Gibbons
PO Box 39
Park City, UT 84060
3034048000 3034048000
1310 Lowell Ave.
Park City, UT 84060
3034048000
40.65394317312325, -111.50825245270715
See Appendix A Engine Info and Emission Calculations
Docusign Envelope ID: 4AE7E6EF-F374-4D77-BA68-872B177406C3

Instructions Form 17 - Diesel Powered Standby Generator

Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!
Lines 1 Fill in the name, address, phone number, and fax number of the business applying for the and 2: permit exemption.
Line 3 Fill in the address where the equipment will be located. Directions to business if needed for remote locations,
i.e., five miles south of Deseret on highway 101, turn left at farmhouse, go 1.5 miles. Identify the county the
equipment will be located. Also enter the latitude, longitude and UTM coordinates of the facility. Line 4 Fill in the manufacturer, model, maximum rated horsepower or kilowatts, maximum hours of operation, emission
rate for NOx in grams/BHP-hr, and the date the engine was constructed or reconstructed. Attach manufacturer
emission information. Note: Maximum rated horsepower not to exceed 1000hp or 750 kilowatts. Also maximum hours not to exceed
300 hours. Line 5 Supply calculations for all criteria pollutants, greenhouse gases and hazardous air pollutants. Use EPA AP-42
or manufacturers’ data to complete your calculations. Fill in the name, address, phone number, and fax number
of the business applying for the

U:\aq\ENGINEER\GENERIC\Forms 2010\Form17 Diesel-fired Standby Generators.doc
Revised 12/20/10
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Appendix A
Engine Info

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Emission Factors

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Emission Calculations

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Total Emissions Calculations

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Certificate Of Completion
Envelope Id: 4AE7E6EFF3744D77BA68872B177406C3 Status: Completed
Subject: Complete with Docusign: 20240829_PCMR Notice of Intent to Modify Air Permit.pdf
Source Envelope:
Document Pages: 54 Signatures: 1 Envelope Originator:
Certificate Pages: 5 Initials: 0 Jessica Gibbons
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
390 Interlocken Crescent, Ste. 1000
Broomfield, CO 80021
[e-mail]
IP Address: 150.195.198.49
Record Tracking
Status: Original
8/29/2024 2:58:48 PM
Holder: Jessica Gibbons
[e-mail]
Location: DocuSign
Signer Events Signature Timestamp
Deirdra Walsh
[e-mail]
VP& COO Park City Mountain
Deirdra Walsh
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 45.62.182.186
Sent: 8/29/2024 3:03:18 PM
Resent: 8/29/2024 3:38:33 PM
Resent: 8/29/2024 3:41:27 PM
Viewed: 8/29/2024 3:56:54 PM
Signed: 8/29/2024 3:56:59 PM
Electronic Record and Signature Disclosure:
Accepted: 8/29/2024 3:07:20 PM
ID: 91cd9eb7-cdf6-412f-a784-9fa6dc20c96d
In Person Signer Events Signature Timestamp
Editor Delivery Events Status Timestamp
Agent Delivery Events Status Timestamp
Intermediary Delivery Events Status Timestamp
Certified Delivery Events Status Timestamp
Carbon Copy Events Status Timestamp
Jessica Gibbons
[e-mail]
Security Level: Email, Account Authentication
(None)
Sent: 8/29/2024 3:03:18 PM
Resent: 8/29/2024 3:57:01 PM
Viewed: 8/29/2024 3:59:01 PM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Witness Events Signature Timestamp
Notary Events Signature Timestamp
Envelope Summary Events Status Timestamps
Envelope Sent Hashed/Encrypted 8/29/2024 3:03:18 PM
Envelope Updated Security Checked 8/29/2024 3:38:26 PM
Envelope Updated Security Checked 8/29/2024 3:41:27 PM
Envelope Updated Security Checked 8/29/2024 3:41:27 PM
Certified Delivered Security Checked 8/29/2024 3:56:54 PM
Signing Complete Security Checked 8/29/2024 3:56:59 PM
Envelope Summary Events Status Timestamps
Completed Security Checked 8/29/2024 3:56:59 PM
Payment Events Status Timestamps
Electronic Record and Signature Disclosure
ELECTRONIC RECORD AND SIGNATURE DISCLOSURE
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Electronic Record and Signature Disclosure created on: 8/6/2014 11:44:49 AM
Parties agreed to: Deirdra Walsh
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Lucia Mason <[e-mail]>
Fwd: NOI Submittal
2 messages
Alan Humpherys <[e-mail]>Thu, Aug 29, 2024 at 5:22 PM
To: Lucia Mason <[e-mail]>
Cc: Jon Black <[e-mail]>
Lucia,
Can you please process this project?
Site ID: 12403
Peer: EQ
Thanks,
Alan
---------- Forwarded message ---------
From: <[e-mail]>
Date: Thu, Aug 29, 2024 at 5:15 PM
Subject: NOI Submittal
To: <[e-mail]>
Recipient Data:
Time Finished: 2024-08-29 17:15:42 MDT
IP: 150.195.198.118
ResponseID: R_6UTZ837uRTgY5sR
Link to View Results: Click Here
URL to View Results: https://utahgov.iad1.qualtrics.com/apps/single-response-reports/reports/rUqhrqXn1KjZSbLlZy91654eRPmmJw
K7D8EjCKIgvzfg1dglPqUGVA4ACjxO53hVD%2ED8bU-FTjcQyACoOFmgWhkY7yqz3dVmlj-sz9AYiTSxw-WgCw86gXdD3YCW8Vg46Hjt60GJSxD3
BF8rCKxnkLBsNd-cccEYhjsokLI311Ypy2zXRQ0usycGkpCfyFI2Pp1cSBJCCLBlLJaRzm6OfR89%2ENyn5R%2E%2Ecwsacjo5ppWZhUMvDxKVmxngcq4p
0Ll4vUmUJByl9xDZ-Ht34xIZUOVfHVuxJLYIjxLq3XRIUUMye8vpsnZuSXiiAChMXVBjUDKoqYmnMbBTwzk7FDotcg
Response Summary:
Company Name:
Vail Resorts
2/20/25, 10:51 AM State of Utah Mail - Fwd: NOI Submittal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1808766089929007541&simpl=msg-f:1808766089929007541&simpl=msg-a:r1197091886421262315 1/2
Site Name:
Park City Mountain
Contact Name:
Deirdra Walsh
Contact Email Address:
[e-mail]
Please Attach a copy of your complete application here
https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_3lW6UN6xm8cDKYJ
Please sign acknowledging you are the responsible party to provide DAQ with this NOI.
https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_2di5coUK7JiH1Kn
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Complete_with_Docusign_20240829_PCMR_Notice_.pdf
3293K
Lucia Mason <[e-mail]>Thu, Aug 29, 2024 at 5:29 PM
To: Alan Humpherys <[e-mail]>
Sounds good. Have a good weekend!
[Quoted text hidden]
2/20/25, 10:51 AM State of Utah Mail - Fwd: NOI Submittal
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1808766089929007541&simpl=msg-f:1808766089929007541&simpl=msg-a:r1197091886421262315 2/2