DAQ-2025-002569

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
salt lake community
Notice Authentication Number:
202504211003037399654
2273419277
Notice URL:
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Notice Publish Date:
Sunday, April 20, 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: Salt Lake Community College Location: Salt Lake Community College - Redwood
Campus – Redwood Campus, 4600 South Redwood Road, Salt Lake City, UT Project Description: Salt Lake Community College has requested
a modification to update equipment and operations at their Redwood Campus Location. The facility is adding on a paint booth, a baghouse for
their wood shop, and a 350 kW emergency generator. The emergency generator is limited to 100 hours of operation annually for
maintenance and testing and is a tier 3 certified engine. The completed engineering evaluation and air quality impact analysis showed the
proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an
Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality, and draft Approval
Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116.
Written comments received by the Division at this same address on or before May 20, 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: April 20, 2025 SLT0032534
Back
DAQE-IN105050005-25
April 17, 2025
Sherie Thornton
Salt Lake Community College
P.O. Box 30808
Salt Lake City, UT 84130
[e-mail]
Dear Ms. Thornton:
Re: Intent to Approve: Modification to Approval Order DAQE-AN105050004-17 to Add and Update
Equipment
Project Number: N105050005
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, Dylan Frederick, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dylan Frederick, can be reached at
[phone] or [e-mail], if you have any questions.
Sincerely,
{{$s }}
Alan D. Humpherys, Manager
New Source Review Section
ADH:DF:jg
cc: Salt Lake County 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
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN105050005-25
Modification to Approval Order DAQE-AN105050004-17 to Add
and Update Equipment

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Salt Lake Community College - Redwood Campus

Issued On
April 17, 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............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-IN105050005-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Salt Lake Community College Salt Lake Community College - Redwood Campus

Mailing Address Physical Address
P.O. Box 30808 4600 South Redwood Road
Salt Lake City, UT 84130 Salt Lake City, UT 84130

Source Contact UTM Coordinates
Name: Sherie Thornton 420,204 m Easting
Phone: [phone],502,625 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 8221 (Colleges, Universities, & Professional Schools)

SOURCE INFORMATION
General Description
Salt Lake Community College (SLCC) operates a heating plant and other auxiliary equipment on the
Redwood Campus in Salt Lake County, with four (4) dual-fuel-fired boilers. The facility also includes a
woodworking shop and paint shop as part of campus activities and uses emergency generators for backup
power during times of power outages.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units
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
DAQE-IN105050005-25
Page 4

Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
SLCC has requested to add a new diesel-fired 350 kW emergency generator, a paint booth, and a
baghouse. Emissions and limitations from these new sources have been incorporated into the approval
order.

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 24.53 35992.00
Carbon Monoxide 0.16 24.87
Nitrogen Oxides 0.73 32.33
Particulate Matter - PM10 0.30 2.80
Particulate Matter - PM2.5 0.30 2.80
Sulfur Dioxide 0 1.18
Volatile Organic Compounds 0.58 2.40

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 470 530
Hexane (CAS #110543) 0 1020
Change (TPY) Total (TPY)
Total HAPs 0.24 0.78

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 Salt Lake Tribune and Deseret News on April 20, 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.

DAQE-IN105050005-25
Page 5

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]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT

II.A.1 Redwood Campus
DAQE-IN105050005-25
Page 6

II.A.2 Dual Fuel Boilers Fuel: Natural Gas or #2 Diesel Manufactured in 1999 Boiler #1 Rating: 22.4 MMBtu/hr NSPS Applicability: 40 CFR 60 Subpart Dc Boiler #2 Rating: 20.1 MMBtu/hr NSPS Applicability: 40 CFR 60 Subpart Dc Boiler #3 Rating: 16.3 MMBtu/hr NSPS Applicability: 40 CFR 60 Subpart Dc Boiler #4 8.1 MMBtu/hr Applicability: None
II.A.3 Emergency Engines Manufactured Pre-2006 Fuel: #2 Diesel
MACT Applicability: 40 CFR 63 Subpart ZZZZ
6-1 Student Center E.
Rating: 150 kW
006-2 Student Center W.
Rating: 44 kW
005 Rampton Tech. Bld.
Rating: 175 kW
09A-100A Library Cooling Tower Mech. Room A
Rating: 100 kW
003-1-104G Applied Tech Mechanical
Rating: 60 kW
010-1-149 Lifetime Activities Center Mech.
Rating: 100 kW
011 Science and Industry Bld.
Rating: 150 kW
1 Redwood Central Heat Plant
Rating: 150 kW

DAQE-IN105050005-25
Page 7

II.A.4 Emergency Engines Manufactured 2006 and Later Fuel: #2 Diesel NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ 051 Gundersen Facilities Services Bldg. Rating: 40 kW 008 Business Bldg. Rating: 30 kW 027 Eccles Child Development Lab Rating: 25 kW 012 Academic and Admin Bldg. Rating: 350 kW 002A Chiller Plant/Cooling Tower Rating: 80 kW 005 Rampton Tech Bldg. (NEW) Rating: 350 kW (530 bhp) Manufacturer Year: 2017 Tier 3 Certified
II.A.5 One (1) Paint Booth (NEW)

II.A.6 One (1) Baghouse (NEW) Flow Rate: 3500 ACFM Controls: Cabinet shop II.A.7 Underground Storage Tank
30,000 Gallon Underground #2 Diesel Fuel Storage Tank

DAQE-IN105050005-25
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. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Limitations and Testing Requirements
II.B.1.a The owner/operator shall not exceed the following opacity limits for each listed piece of equipment: A. Each boiler - 10% B. The paint booth - 10% C. The baghouse - 10% D. Each emergency engine - 20% E. All other points - 20%. [R307-201, R307-401-8] II.B.1.b Opacity observations of emissions from stationary sources shall be in accordance with 40 CFR 60, Appendix A, Method 9. [R307-201]
II.B.1.c The owner/operator shall comply with all applicable requirements of R307-325, "Ozone Nonattainment and Maintenance Areas: General Requirements." [R307-325] II.B.1.d The owner/operator shall comply with all applicable requirements of R307-343, "Wood Furniture Manufacturing Operations." [R307-343]
II.B.2 Fuels II.B.2.a The owner/operator shall not use diesel fuels that exceed a sulfur content of 15 ppm by weight. [40 CFR 60 Subpart IIII, R307-401-8]
II.B.2.a.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of fuel oil and diesel fuel shall be either by the owner/operator's own testing or by test reports from the fuel oil or diesel fuel marketer. [R307-203-1] II.B.3 Dual-Fuel-Fired Boilers
II.B.3.a The owner/operator shall operate the boilers using natural gas as a primary fuel and #2 diesel fuel oil as a backup fuel during periods of gas curtailment, gas supply interruption, startups, or for periodic testing, maintenance, or operator training on liquid fuel. [R307-401-8] II.B.3.b The owner/operator shall not operate each boiler for more than 48 hours per rolling 12-month period for periodic testing, maintenance, and operator training on liquid fuels. [40 CFR 63 Subpart JJJJJJ, R307-401-8]
DAQE-IN105050005-25
Page 9

II.B.3.b.1 The owner/operator shall keep the following records for periods of diesel fuel usage: A. The date the boiler was used B. The duration, in hours, of each boiler usage C. The reason for each boiler's usage. [R307-401-8] II.B.4 Emergency Engines
II.B.4.a 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. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.4.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. The date the emergency engine was used
B. The duration of operation in hours

C. The reason for the emergency engine usage.
[40 CFR 60 Subpart ZZZZ, R307-401-8]

II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.4.b The owner/operator shall install a 350 kW emergency engine certified by the manufacturer to meet an emission rate of 3.0 g/hp-hr NOx. [R307-401-8]

II.B.4.b.1 The owner/operator shall keep records documenting the manufacturer guarantee of the NOx emission rate for the lifespan of the engine. The owner/operator shall follow all manufacturer recommendations for testing and maintenance of the equipment. [R307-401-8]
II.B.4.c The owner/operator shall not perform engine testing for more than 52 days per rolling 12-month period. Engine testing shall not occur before 8 AM and after 5 PM. [R307-401-8, R307-410]

II.B.4.c.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 for engine testing shall be kept in a log and shall include the following: A. The date of the test B. The start and end time of any test. [R307-410]
II.B.5 Paint Workshop
II.B.5.a The owner/operator shall install particulate arrestor filters in the paint booth to control particulate emissions from the paint booth. [R307-401-8]
II.B.5.b The owner/operator shall only use high-volume low-pressure spray guns in the paint booth.
[R307-401-8]

DAQE-IN105050005-25
Page 10

II.B.5.c The owner/operator shall not emit more than the following from evaporative sources associated with the paint workshop on site: 0.53 tons per rolling 12-month period of VOCs. [R307-401-8] II.B.5.c.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]

II.B.5.c.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]
II.B.5.c.3 The owner/operator shall keep records each month of the following:
A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used
C. The density of each material used
D. The volume of each VOC- and HAP-emitting material used

E. The amount of VOCs and the amount of each HAP emitted from each material
F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from
each material
G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons).
[R307-401-8]

II.B.6 Wood Shop II.B.6.a The owner/operator shall use a baghouse to control particulate emissions from the wood cabinet
shop. All emissions will be routed through the baghouse before venting to the atmosphere.
[R307-401-8]

II.B.6.b The owner/operator shall operate the wood shop baghouse for no more than 500 hours per rolling 12-month period. [R307-401-8]
DAQE-IN105050005-25
Page 11

II.B.6.b.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 the baghouse shall be kept in a log and shall include the following: A. The date the baghouse was used B. The duration of operation in hours. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN105050004-17 dated March 2, 2017 Is Derived From NOI dated March 22, 2021 Incorporates Additional Information dated February 23, 2022 Incorporates Additional Information dated March 10, 2022 Incorporates Additional Information dated March 28, 2022 Incorporates Additional Information dated May 31, 2023 Incorporates Additional Information dated June 5, 2023 Incorporates Additional Information dated June 20, 2023 Incorporates Additional Information dated September 22, 2023 Incorporates Additional Information dated March 7, 2025

DAQE-IN105050005-25
Page 12

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-NN105050005-25
April 17, 2025
Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880
RE: Legal Notice of Intent to Approve
This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on April 20, 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: Wasatch Front Regional Council
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
DAQE-NN105050005-25
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: Salt Lake Community College
Location: Salt Lake Community College - Redwood Campus – Redwood Campus, 4600
South Redwood Road, Salt Lake City, UT
Project Description: Salt Lake Community College has requested a modification to update equipment
and operations at their Redwood Campus Location. The facility is adding on a
paint booth, a baghouse for their wood shop, and a 350 kW emergency generator.
The emergency generator is limited to 100 hours of operation annually for
maintenance and testing and is a tier 3 certified engine.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before May 20, 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: April 20, 2025

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

DAQE-

RN105050005 March 18, 2025
Sherie Thornton
Salt Lake Community College P.O. Box 30808 Salt Lake City, UT 84130
[e-mail]
Dear Sherie Thornton,
Re: Engineer Review: Modification to Approval Order DAQE-AN105050004-17 to Add and Update Equipment Project Number: N105050005
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. Salt Lake Community College should complete this review within 10 business days of receipt.
Salt Lake Community College should contact Dylan Frederick at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dylan Frederick 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 Salt Lake Community College does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Salt Lake Community College 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
4/11/2025

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N105050005 Owner Name Salt Lake Community College Mailing Address P.O. Box 30808
Salt Lake City, UT, 84130 Source Name Salt Lake Community College- Redwood Campus
Source Location Redwood Campus 4600 South Redwood Road Salt Lake City, UT 84130
UTM Projection 420,204 m Easting, 4,502,625 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 8221 (Colleges, Universities, & Professional Schools) Source Contact Sherie Thornton Phone Number [phone] Email [e-mail] Billing Contact Sherie Thornton
Phone Number [phone] Email [e-mail]
Project Engineer Dylan Frederick, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted April 1, 2021 Date of Accepted Application September 22, 2023

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 2
SOURCE DESCRIPTION General Description
Salt Lake Community College (SLCC) operates a heating plant and other auxiliary equipment on the Redwood Campus in Salt Lake County, with four dual-fuel fired boilers. The facility also includes a wood working shop and paint shop as part of campus activities, and uses emergency
generators for backup power during times of power outages. NSR Classification: Minor Modification at Minor Source Source Classification Located in , Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA, Salt Lake County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source Project Proposal
Modification to Approval Order DAQE-AN105050004-17 to Add and Update Equipment Project Description SLCC has requested to add a new diesel-fired 350 kW emergency generator, a paint booth, and a baghouse. Emissions and limitations from these new sources have been incorporated into the approval order. EMISSION IMPACT ANALYSIS
A 1-hour NO2 model was completed by the DAQ (see memo DAQE-MN105050005-24). The 1-hour NO2 model predicted the maximum total concentration would be 98.5% of the NAAQS. The following operational restrictions were added as a result of the modeling: • Testing of the new emergency generator shall be allowed 52 days per year between the hours of 8am and 5pm. No other criteria pollutants or HAPs were modeled as they are below the modeling thresholds contained in R307-410-4 and R307-410-5, or the source is in a non-attainment area for the pollutant. [Last updated June 11, 2024]

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 3
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 24.53 35992.00 Carbon Monoxide 0.16 24.87
Nitrogen Oxides 0.73 32.33
Particulate Matter - PM10 0.30 2.80
Particulate Matter - PM2.5 0.30 2.80
Sulfur Dioxide 0 1.18
Volatile Organic Compounds 0.58 2.40 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 470 530
Hexane (CAS #110543) 0 1020
Change (TPY) Total (TPY)
Total HAPs 0.24 0.78
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Emergency Engine
SLCC has requested to add a 350 kW emergency generator. The generator will operate up to 100 hours a year for testing and maintenance. Emissions from this testing will include NOx, CO, SO2, PM10, PM2.5, VOCs, and HAPs, primarily NOx and CO.
The proposed engine is certified to tier 3 emission standards, and emits up to 0.73 tons per year of NOx, and 0.16 tons per year of CO, plus smaller amounts of other pollutants. More stringent controls could be added, such as purchasing a tier 4 certified engine, or installing add on controls such as selective catalytic reduction, oxidation catalysts, or diesel particulate filters. Due to the low
amount of emissions from this engine, it would not be economically feasible to implement additional controls or upgrade the proposed engine. The current tier-3 emission standards are accepted as BACT for the emergency engine.
BACT for control of emissions from the emergency generator will be the installation of an engine certified by the manufacturer to 3.0 g/hp-hr of NOx. [Last updated March 14, 2025] 2. BACT review regarding Paint Shop SLCC has requested to add a paint booth to the Redwood facility. The facility uses multiple materials that emit VOCs and HAPs and primarily is used in the campus furniture shop. The paint spray booth can control emissions with paint arrestor filters to reduce particulate emissions. Additionally, the paint spray booth can utilize high-volume low-pressure (HVLP) spray guns to reduce overspray and efficiently coat surfaces with less material. This reduces the total volume of VOC materials used in the facility. SLCC has proposed particulate filters with a capture efficiency of 99% that are regularly maintained, and use HVLP spray guns to reduce VOC and HAP emissions. Further add on controls would not be economically feasible to implement as not all painting occurs within the spray booth and the total annual emissions are conservatively estimated at less than 1 ton per year of VOCs. Further emission reductions could be achieved with good workplace practices and VOC content limits established in R307-325 and R307-343. The source could keep VOC materials stored in closed containers, clean spills as soon as reasonably possible, and follow the VOC content limits listed in R307-343-4. These measures are all technically feasible. BACT for the Spray Booth will be the use of HVLP spray guns and installation of particulate arrestor filters, an opacity limit of 10%, and compliance with 307-325 and R307-343. [Last
updated March 14, 2025] 3. BACT review regarding Baghouse
SLCC requested to add a baghouse to control emissions from the wood shop at the campus. The baghouse captures emissions whenever sawing or sanding is conducted in the shop. The baghouse is expected to operate 144 hours a year. It is estimated conservatively to operate 500 hours a year and emit up to 0.3 tons per year of PM10 and PM2.5. Due to the low emissions from this equipment, additional add on controls would not be economically feasible to implement, and purchasing a different baghouse would also be economically infeasible. Therefore, operating the baghouse according to manufacturer instructions is considered BACT. BACT for control of PM10 and PM2.5 from the woodshop will be the installation of a baghouse and a 10% opacity limit. [Last updated March 14, 2025]

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 5

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

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 6
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 SLCC Campus II.A.2 Dual Fuel Boilers Fuel: Natural Gas or #2 Diesel Manufactured in 1999 Boiler #1 Rating: 22.4 MMBtu/hr NSPS Applicability: 40 CFR 60 Subpart Dc
Boiler #2
Rating: 20.1 MMBtu/hr NSPS Applicability: 40 CFR 60 Subpart Dc Boiler #3 Rating: 16.3 MMBtu/hr NSPS Applicability: 40 CFR 60 Subpart Dc
Boiler #4
8.1 MMBtu/hr Applicability: None

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 7
II.A.3 Emergency Engines Manufactured Pre-2006 Fuel: #2 Diesel MACT Applicability: 40 CFR 63 Subpart ZZZZ
6-1 Student Center E. Rating: 150 kW
006-2 Student Center W.
Rating: 44 kW 005 Rampton Tech. Bld. Rating: 175 kW 09A-100A Library Cooling Tower Mech. Room A Rating: 100 kW 003-1-104G Applied Tech Mechanical Rating: 60 kW
010-1-149 Lifetime Activities Center Mech. Rating: 100 kW
011 Science and Industry Bld
Rating: 150 kW
1 Redwood Central Heat Plant Rating: 150 kW

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 8
II.A.4 Emergency Engines Manufactured 2006 and Later Fuel: #2 Diesel NSPS Applicability:40 CFR 60 Subpart IIII
MACT Applicability:40 CFR 63 Subpart ZZZZ
051 Gundersen Facilities Services Bld. Rating: 40 kW 008 Business Bld. Rating: 30 kW 027 Eccles Child Development Lab Rating: 25 kW
012 Academic and Admin Bld. Rating: 350 kW
002A Chiller Plant/Cooling Tower
Rating: 80 kW
005 Rampton Tech Bld.(NEW) Rating: 350 kW (530 bhp) Manufacturer Year: 2017 Tier 3 Certified
II.A.5 NEW One (1) Paint Booth (NEW) II.A.6 NEW One (1) Baghouse (NEW) Flow Rate: 3500 ACFM
Controls: Cabinet shop II.A.7 Underground Storage Tank 30,000 Gallon Underground #2 Diesel Fuel Storage Tank

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 Limitations and Testing Requirements

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 9
II.B.1.a NEW The owner/operator shall not exceed the following opacity limits for each listed piece of equipment: A. Each boiler - 10% B. The paint booth - 10%
C. The baghouse - 10%
D. Each emergency engine - 20%
E. All other points - 20%. [R307-201, R307-401-8]
II.B.1.b Opacity observations of emissions from stationary sources shall be in accordance with 40 CFR
60, Appendix A, Method 9. [R307-201] II.B.1.c NEW The owner/operator shall comply with all applicable requirements of R307-325, "Ozone Nonattainment and Maintenance Areas: General Requirements". [R307-325]
II.B.1.d NEW The owner/operator shall comply with all applicable requirements of R307-343, "Wood Furniture Manufacturing Operations". [R307-343] II.B.2 Fuels II.B.2.a NEW The owner/operator shall not use diesel fuels that exceed a sulfur content of 15 ppm by weight. [40 CFR 60 Subpart IIII, R307-401-8]
II.B.2.a.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of fuel oil and diesel fuel shall be either by the owner/operator's own testing or by test reports from the fuel oil or diesel fuel marketer. [R307-203-1]
II.B.3 Dual Fuel Fired Boilers
II.B.3.a NEW The owner/operator shall operate the boilers using natural gas as a primary fuel and #2-diesel fuel oil as a backup fuel during periods of gas curtailment, gas supply interruption, startups, or for periodic testing, maintenance, or operator training on liquid fuel. [R307-401-8]
II.B.3.b NEW The owner/operator shall not operate each boiler for more than 48 hours per rolling 12-month period for periodic testing, maintenance, and operator training on liquid fuels. [40 CFR 63 Subpart JJJJJJ, R307-401-8] II.B.3.b.1 NEW The owner/operator shall keep the following records for periods of diesel fuel usage: A. The date the boiler was used B. The duration, in hours, of each boiler usage
C. The reason for each boiler's usage. [R307-401-8]
II.B.4 Emergency Engines

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 10
II.B.4.a NEW 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. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.4.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. The date the emergency engine was used
B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.4.a.2
NEW
To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ] II.B.4.b NEW The owner/operator shall install a 350 kW emergency engine certified by the manufacturer to meet an emission rate of 3.0 g/hp-hr NOx. [R307-401-8]
II.B.4.b.1
NEW
The owner/operator shall keep records documenting the manufacturer guarantee of the NOx
emission rate for the lifespan of the engine. The owner/operator shall follow all manufacturer recommendations for testing and maintenance of the equipment. [R307-401-8]
II.B.4.c
NEW
The owner/operator shall not perform engine testing for more than 52 days per rolling 12-
month period. Engine testing shall not occur before 8 AM and after 5 PM. [R307-401-8, R307-410]
II.B.4.c.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 for engine testing shall be kept in a log and shall include the following: 1. The date of the test
2. The start and end time of any test. [R307-410]
II.B.5 NEW Paint Workshop
II.B.5.a NEW The owner/operator shall install particulate arrestor filters in the paint booth to control particulate emissions from the paint booth. [R307-401-8]

II.B.5.b NEW The owner/operator shall only use high-volume low-pressure spray guns in the paint booth. [R307-401-8] II.B.5.c NEW The owner/operator shall not emit more than the following from evaporative sources associated with the paint workshop on site:
0.53 tons per rolling 12-month period of VOCs. [R307-401-8]

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 11
II.B.5.c.1 NEW The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]
II.B.5.c.2 NEW The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]

II.B.5.c.3 NEW The owner/operator shall keep records each month of the following:
A. The name (as per SDS) of the VOC- and HAP-emitting material
B. The maximum percent by weight of VOCs and each HAP in each material used
C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from
each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons)
[R307-401-8]
II.B.6
NEW
Wood Shop
II.B.6.a NEW The owner/operator shall use a baghouse to control particulate emissions from the wood cabinet shop. All emissions will be routed through the baghouse before venting to the atmosphere. [R307-401-8]
II.B.6.b NEW The owner/operator shall operate the wood shop baghouse for no more than 500 hours per rolling 12-month period. [R307-401-8]

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 12
II.B.6.b.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 the baghouse shall be kept in a log and shall include the
following:
A. The date the baghouse was used
B. The duration of operation in hours. [R307-401-8]

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 13
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN105050004-17 dated March 2, 2017
Is Derived From NOI dated March 22, 2021 Incorporates Additional Information dated February 23, 2022 Incorporates Additional Information dated March 10, 2022 Incorporates Additional Information dated March 28, 2022 Incorporates Additional Information dated May 31, 2023 Incorporates Additional Information dated June 5, 2023 Incorporates Additional Information dated June 20, 2023 Incorporates Additional Information dated September 22, 2023 Incorporates Additional Information dated March 7, 2025
REVIEWER COMMENTS
1. Comment regarding Emission Estimates: Emission estimates for the facility were determined with the following methods: Emergency Engine - AP-42 Tables 3.3-1, 3.3-2, 3.4-1, 3.4-3 and 3.4-4 were used to determine emission factors for all criteria pollutants and HAPs. Inputs of 100 hours of operation for emergency engines were used, with an engine rating of 350 kW.
Baghouse - The baghouse being added to the permit operates up to 500 hours per year to control
wood shop particulate matter. The baghouse is conservatively estimated to have a grain loading rate of 0.04 gr/scf and a has a maximum flow rate of 3500 scfm. Using these inputs, a total of 0.30 TPY of PM10 was calculated. PM2.5 is conservatively assumed to be equal to PM10 emissions.
Paint Shop Emissions - A mass balance for VOCs and HAPs was performed using material usage
estimates and SDS sheets provided by SLCC. The volume of VOC-containing materials used was multiplied by the VOC content specified in each material's SDS sheet to determine an annual total of VOCS for the facility. To determine the total number of HAPs, the VOCs of any material that did
not list a HAP in its respective SDS sheet were subtracted from the annual total of VOCs. [Last updated March 14, 2025]
2. Comment regarding NSPS and MACT Applicability: 40 CFR 60 Subpart Kb Subpart Kb contains the Standards of Performance for Volatile Organic Liquid (VOL) Storage Vessels (Including Petroleum Liquid Storage Vessels) for which construction, reconstruction, or modification commenced after July 23, 1984. Subpart Kb applies to storage vessels with a capacity greater than 75 m3 but less than 151 m3, containing a VOL that, as stored, has a maximum true vapor pressure (VP) equal to or greater than 27.6 kPa. The SLCC 30,000-gallon, or 114 m3, tank only stores #2 Diesel fuel with a VP of 0.27 kPa. SLCC is not subject to this subpart. 40 CFR 63 MACT Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 14
Internal Combustion Engines (RICE) applies to owners and operators RICE engines at a major or area source of HAP emissions. A stationary RICE located at an area source of HAP emissions is new
if construction of the stationary RICE commenced on or after June 12, 2006. SLCC operates fourteen emergency diesel fueled engines, therefore MACT Subpart ZZZZ applies to the emergency engines at this source. The emergency engines manufactured and installed prior to 2006 are existing sources. The existing emergency stationary CI RICE engines must comply with the requirements in Table 2d in 40 CFR 63 Subpart ZZZZ and any other applicable requirements within the Subpart.
The emergency engines manufactured and installed after 2006 are new stationary RICE engines.
New or reconstructed stationary RICE located at an area source must meet the requirements of 40 CFR 63 Subpart ZZZZ by meeting the requirements of 40 CFR part 60 Subpart IIII. 40 CFR 60 NSPS Subpart IIII The Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE) applies to owners and operators of stationary CI ICE that commenced construction after July 11, 2005, where the stationary CI ICE are manufactured after April 1, 2006. Owners and operators of 2007 model year and later emergency stationary CI ICE must comply with the emission standards in 40 CFR 60.4205. The emergency engines manufactured and installed after 2006 will be subject to NSPS Subpart IIII. Requirements such as those mentioned above (i.e. monitoring, recordkeeping, and reporting, among
others) apply. 40 CFR 60 NSPS Subpart Dc
The Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units applies to each new steam generating unit that have a maximum design heat input capacity greater than or equal to 10 MMBtu/hr and less than 100 MMBtu/hr. The applicability date for NSPS Subpart Dc is June 9, 1989. Steam generating unit means a device that combusts any fuel and produces steam, heats water, or heats any heat transfer medium. SLCC operates four boilers rated at 8.1, 16.3, 20.1, and 22.4 MMBtu/hr. The three boilers rated over the 10 MMBtu/hr limit are subject to 40 CFR 60 NSPS Subpart Dc. The 8.1 MMBtu/hr boiler is not subject to this subpart.
40 CFR 63 MACT Subpart JJJJJJ
The National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources applies to industrial, commercial, or institutional boilers located at an area source of HAP emissions. The on-site boilers are institutional boilers and gas-fired boilers as defined in 40 CFR 63.11237. A gas-fired boiler burns only gaseous fuels during normal operation and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel.
40 CFR 63.11195 exempts gas-fired boilers from the applicability and requirements of MACT
Subpart JJJJJJ as long as operations using diesel fuel do not exceed 48 hours; therefore, MACT Subpart JJJJJJ does not apply to the boilers on site.

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 2025 Page 15
[Last updated August 12, 2024]
3. Comment regarding Title V Applicability: Title V of the 1990 CAA (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, but is subject to 40 CFR 60 NSPS Subparts A, Dc, and IIII, and 40 CFR 63 MACT Subparts A and ZZZZ regulations. NSPS Subparts IIII and MACT Subparts ZZZZ each except a source 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.
However, Subpart Dc applies to sources operating a steam generating units constructed, modified, or
reconstructed after June 9, 1989 operating at 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. Boilers within the latter description become subject to Title V due to the limitation on liquid fuel use in this Subpart. SLCC operates three applicable boilers, manufactured in 1999. The
three boilers, rated at 20.1, 16.3, and 22.4 MMBtu/hr, operate on liquid fuel during times of natural gas curtailment and emergencies. Therefore, Title V applies to this source as an area source. [Last updated August 12, 2024]
4. Comment regarding Disconnected 8.1 MMBtu/hr Boiler : During the process of revising the NOI for SLCC, a request was made to include a 8.1 MMBtu/hr boiler that was installed in 2019 and not updated in the permit. After discussion regarding BACT
requirements for the boiler, SLCC Redwood elected to uninstall the boiler and disconnect it from natural gas service as it could not be retrofitted to meet modern BACT requirements. This boiler is not the 8.1 MMBtu/hr boiler listed in the equipment list. [Last updated August 12, 2024]

Engineer Review N105050005: Salt Lake Community College- Redwood Campus March 18, 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
Dylan Frederick <[e-mail]>
SLCC Redwood Information Request
6 messages
Dylan Frederick <[e-mail]>Mon, Dec 2, 2024 at 3:04 PM
To: Sherie Thornton <[e-mail]>
Good afternoon,
I have hit a roadblock in issuing the permit for SLCC redwood regarding the cyclone baghouse system at the wood shop. I haven't been able to find any information
on the baghouse efficiency or emission rate. I was wondering if you knew how often the machine ran or how much material the baghouse collects, or how much
wood is used at the shop so we can make an estimate of the particulates these activities generate. Thanks for your help,
Dylan
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Sherie Thornton <[e-mail]>Mon, Dec 2, 2024 at 3:18 PM
To: Dylan Frederick <[e-mail]>
I’m out of the office today but will get that info asap.
Get Outlook for iOS
From: Dylan Frederick <[e-mail]>
Sent: Monday, December 2, 2024 3:04:51 PM
To: Sherie Thornton <[e-mail]>
Subject: SLCC Redwood Informaon Request

3/14/25, 4:51 PM State of Utah Mail - SLCC Redwood Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r4870064982775811916&simpl=msg-a:r-6348104921967768612&simpl=msg-f:1817368738668148835&simpl…1/3
CAUTION: This is an external message from: [e-mail]. If you have quesons regarding its validity, please review how to idenfy suspicious emails.
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Dec 3, 2024 at 2:07 PM
To: Sherie Thornton <[e-mail]>
Thank you Sherie!
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Jan 21, 2025 at 5:42 PM
To: Sherie Thornton <[e-mail]>
Sherie,
I wanted to check in, have you made any progress on this request?
[Quoted text hidden]
Dylan Frederick <[e-mail]>Thu, Mar 6, 2025 at 3:39 PM
To: Sherie Thornton <[e-mail]>
Sherie,
I am writing to check in on the status of the last information request I sent. Have you made any headway on the requests I made in December?
[Quoted text hidden]
Sherie Thornton <[e-mail]>Fri, Mar 7, 2025 at 12:29 PM
To: Dylan Frederick <[e-mail]>
Dylan,
I apologize for the delayed response. Based on the shop’s usage of about 1 hour per day, 3 days a week, for 48 weeks, the total usage is
approximately 144 hours per year. This translates to an estimated 10,800 board feet of wood per year.
Please let me know if you need any additional information.
Best Regards,

Sherie Thornton MS. GSP.
Environmental Health and Safety Manager
3/14/25, 4:51 PM State of Utah Mail - SLCC Redwood Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r4870064982775811916&simpl=msg-a:r-6348104921967768612&simpl=msg-f:1817368738668148835&simpl…2/3
Office: 801-957-4902
Cell: 801-664-9074
"Please note: I work remotely on Fridays but am available via email and cell phone. For urgent matters or emergencies, feel
free to call me immediately."

From: Dylan Frederick <[e-mail]>
Sent: Thursday, March 6, 2025 3:39 PM
To: Sherie Thornton <[e-mail]>
Subject: Re: SLCC Redwood Informaon Request

[Quoted text hidden]
3/14/25, 4:51 PM State of Utah Mail - SLCC Redwood Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r4870064982775811916&simpl=msg-a:r-6348104921967768612&simpl=msg-f:1817368738668148835&simpl…3/3

DAQE-MN105050005-24 M E M O R A N D U M TO: Dylan Frederick, NSR Engineer
FROM: Dave Prey, Air Quality Modeler DATE: March 22, 2024
SUBJECT: Modeling Analysis Review for the Notice of Intent for Salt Lake Community College – Redwood Campus, Salt Lake County, Utah __________________________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.
I. OBJECTIVE
Salt Lake Community College (SLCC) is seeking a modified approval order for their Redwood
Campus, located in Salt Lake County, Utah. SLCC operates a heating plant and other auxiliary equipment on the Redwood Campus in Salt Lake County, with four dual-fuel fired boilers. The facility also includes a wood working shop and paint shop as part of campus activities, and uses emergency generators for backup power during times of power curtailment. SLCC has requested the addition of a new 350 kW emergency generator, a paint booth, and a baghouse. Emissions from these new sources have been incorporated into the approval order. This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility would be in compliance with State and Federal concentration standards.
II. APPLICABLE RULE(S) Utah Air Quality Rules:
R307-401-6 Condition for Issuing an Approval Order R307-410-3 Use of Dispersion Models R307-410-4 Modeling of Criteria Pollutants in Attainment Areas
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
DF
D
DP
DAQE-MN105050005-24 Page 2
III. MODELING METHODOLOGY
A. Applicability
Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a modified approval order. The emission rate for NOx warranted a modeling review to demonstrate compliance with the one-hour NO2 NAAQS. Modeling was performed by the UDAQ. B. Assumptions
1. Topography/Terrain The Plant is at an elevation 4300 feet with terrain features that have little effect on concentration predictions. a. Zone: 12
b. Approximate Location: UTM (NAD83): 420275 meters East
4502869 meters North 2. Urban or Rural Area Designation
After a running of EJ Screen it was concluded the area is “urban” for air modeling purposes. 3. Ambient Air
Ambient air boundaries used for the Redwood campus are based on access areas around the heat plant and generators such as side-walks but not the parking lot next to it for staff use.
4. Building Downwash The source was modeled with the AERMOD model. All structures at the plant were used in the model to account for their influence on downwash. 5. Meteorology
Five (5) years of off-site surface and upper air data were used in the analysis consisting of the following:
Surface – Salt Lake Airport, UT NWS: 2017-2022 Upper Air – Salt Lake Airport, UT NWS: 2017-2022
DAQE-MN105050005-24 Page 3
6. Background
The background concentrations were based on concentrations measured in Midvale, Utah.
7. Receptor and Terrain Elevations The modeling domain used consisted of receptors including property boundary receptors. This area of the state contains mountainous terrain and the modeling domain has simple and
complex terrain features in the near and far fields. Therefore, receptor points representing actual terrain elevations from the area were used in the analysis.
8. Model and Options The State-accepted AERMOD model was used to predict air pollutant concentrations under a simple/complex terrain/wake effect situation. In quantifying concentrations, the regulatory default option was selected.
9. Air Pollutant Emission Rates
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
BOILER1 420275 4502869 1.96 8.58 8760
BOILER2 420270 4502870 1.76 7.71 8760
BOILER3 420266 4502870 1.43 6.26 8760
BOILER4 420263 4502870 0.71 3.11 8760
EGEN 420508 4502757 14.54 0.73 100
Total 20.40 26.39 10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
BOILER1 POINT 4300.9 8.2 27.0 446 18.01 0.61
BOILER2 POINT 4300.9 8.2 27.0 446 18.01 0.61
BOILER3 POINT 4300.9 8.2 27.0 446 18.01 0.61
BOILER4 POINT 4300.9 8.2 27.0 446 18.01 0.61
EGEN POINT 4298.8 3.7 12.0 853 75.68 0.10

DAQE-MN105050005-24 Page 4
IV. RESULTS AND CONCLUSIONS
A. National Ambient Air Quality Standards The below table provides a comparison of the predicted total air quality concentrations with the
NAAQS. The predicted total concentrations are less than the NAAQS.
Air Pollutant Period Prediction Class II Significant Impact Level
Background Nearby Sources* Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2 1-Hour 138.3 7.5 46.9 0.0 185.2 188 98.5%
V. PERMIT CONDITIONS
The following suggested permit language should be included under the Terms and Conditions in the AO:
• Testing of the new emergency generator shall be allowed 52 days per year between the hours of 8am and 5pm. DP:jg

Nox CO PM10 PM2.5 VOC SO2 HAPs CO2e Source
0.73 0.16 0.05 0.05 0.06 0 0 25 Engine
0.3 0.3 Baghouse
0.524 0.235 Paint operation
0.73 0.16 0.35 0.35 0.584 0 0.235 25 Total
3500 scf/mscf/hr gr/scf lb/hr hours/yea PM10 tpy
3500 210000 0.04 1.2 500 0.3
Paintbooth
Material used specific gravity
Bin QT Primer 1.173
Crown Acetone 0.792
Crown Alchohol 0.792
Fast dry wood paste filler 1.6
Gel Stain Dark Walnut 0.91
Krylon Aerosol Primer 0.77
Magnalac lacquer stain 0.95
Man o War Spar Varnish 0.91
Sunnyside paint thinner 0.8
Fabulon Polyuruthane Super Stain 0.89
Pratt and Lambert Red seal interior finish 1.41
Pratt and Lambert stainshield solid 100% acrylic latex siding stain 1.34
Messmers UV plus MC series natural clear 0.87
Sunnyside VOC compliant Lacquer thinner 0.85
M.L. Campbell Woodsong Stain base and prestain 0.81
volume used annually in oz Volume in ml Amount by weight in lbs %weight VOCs
768 22712.448 58.73520471 50
3072 90849.792 158.6301181 100
3072 90849.792 158.6301181 100
128 3785.408 13.35270354 20
768 22712.448 45.56610084 60.7
1152 34068.672 57.83389722 90
3072 90849.792 190.2760255 100
128 3785.408 7.59435014 95
3072 90849.792 160.2324425 100
128 3785.408 7.427441346 63
1536 45424.896 141.20484 47
3072 90849.792 268.3893412 5
128 3785.408 7.260532551 49
3072 90849.792 170.2469702 100
64 1892.704 3.379903084 100
Total in tpy
Total HAPs
total VOCs in lbs Notes
29.36760235 *No HAPs
158.6301181 *No HAPs
158.6301181 *no HAPs
2.670540709 *volume not specified, "small can" assumed to be 64 oz
27.65862321
52.0505075
190.2760255
7.214632633
160.2324425 *no HAPs
4.679288048 *less than 1% HAPs
66.36627478 *less than 1% HAPs
13.41946706
3.55766095
170.2469702
3.379903084
0.524190087
0.235237165
Material used specific gravity
Bin QT Primer 1.173
Crown Acetone 0.792
Crown Alchohol 0.792
Fast dry wood paste filler 1.6
Gel Stain Dark Walnut 0.91
Krylon Aerosol Primer 0.77
Magnalac lacquer stain 0.95
Man o War Spar Varnish 0.91
Sunnyside paint thinner 0.8
Fabulon Polyuruthane Super Stain 0.89
Pratt and Lambert Red seal interior finish 1.41
Pratt and Lambert stainshield solid 100% acrylic latex siding stain 1.34
Messmers UV plus MC series natural clear 0.87
Sunnyside VOC compliant Lacquer thinner 0.85
M.L. Campbell Woodsong Stain base and prestain 0.81
volume used annually in oz Volume in ml Amount by weight in lbs %weight VOCs
768 22712.448 58.73520471 50
3072 90849.792 158.6301181 100
3072 90849.792 158.6301181 100
128 3785.408 13.35270354 20
768 22712.448 45.56610084 60.7
1152 34068.672 57.83389722 90
3072 90849.792 190.2760255 100
128 3785.408 7.59435014 95
3072 90849.792 160.2324425 100
128 3785.408 7.427441346 63
1536 45424.896 141.20484 47
3072 90849.792 268.3893412 5
128 3785.408 7.260532551 49
3072 90849.792 170.2469702 100
64 1892.704 3.379903084 100
Total in tpy
total VOCs in lbs Notes
29.36760235 *No HAPs
158.6301181 *No HAPs
158.6301181 *no HAPs
2.670540709 *volume not specified, "small can" assumed to be 64 oz
27.65862321
52.0505075
190.2760255
7.214632633
160.2324425 *no HAPs
4.679288048 *less than 1% HAPs
66.36627478 *less than 1% HAPs
13.41946706
3.55766095
170.2469702
3.379903084
0.524190087
Dylan Frederick <[e-mail]>
Request for SLCC
Sherie Thornton <[e-mail]>Tue, Jan 30, 2024 at 12:02 PM
To: Dylan Frederick <[e-mail]>

Thank you,

This is the information from last year…
Identifier:182408
Type: Vertical
Description: Emergency Engine 005 Rampton Tech. Bld.
Status: Operating
Stack Height:10.0 FEET
Stack Shape: Circular
Stack Diameter:1.00 FEET (12.00 inches)
Exit Gas Temp:72 °F
Exit Gas Flow Rate:12 ACTUAL CUBIC FEET PER SECOND
Exit Gas Velocity:15.27887 FEET PER SECOND
Related Unit Processes:182597 - Emergency Engine 005 Technology Bldg. Cooling Tower, 1 - Emergency Engine 005
Rampton Tech. Bld.

Sherie Thornton
Environmental Health and Safety Manager
Office: 801-957-4902

7/3/24, 8:35 AM State of Utah Mail - Request for SLCC
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1789543167761290779&simpl=msg-f:1789543167761290779 1/2

From: Dylan Frederick <[e-mail]>
Sent: Thursday, January 25, 2024 2:46 PM
To: Sherie Thornton <[e-mail]>
Subject: Request for SLCC

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
[Quoted text hidden]
7/3/24, 8:35 AM State of Utah Mail - Request for SLCC
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1789543167761290779&simpl=msg-f:1789543167761290779 2/2
1/24/24, 3:03 PM State of Utah Mail - Update for SLCC Redwood Campus approval order
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r5475314996158585112&simpl=msg-a:r-64022641642635…1/2
Dylan Frederick <[e-mail]>
Update for SLCC Redwood Campus approval order
5 messages
Dylan Frederick <[e-mail]>Tue, Dec 19, 2023 at 12:51 PM
To: Chris McCarty <[e-mail]>, Sherie Thornton <[e-mail]>, Kameron Howell
<[e-mail]>
Hey all,
Just giving an update on the approval order for the SLCC redwood campus, the project is currently being reviewed by a
peer and should be ready for your own review soon. I will update you in the next two weeks.
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Dylan Frederick <[e-mail]>Wed, Jan 24, 2024 at 2:25 PM
To: Chris McCarty <[e-mail]>, Sherie Thornton <[e-mail]>, Kameron Howell
<[e-mail]>
Hey all,
I'm sending another update, the project took a bit of time to finish peer review but it is currently in the compliance review
stage and should be in management's hands soon. I will require someone review the draft permit before it is issued, who
should I send it to?
[Quoted text hidden]
Sherie Thornton <[e-mail]>Wed, Jan 24, 2024 at 2:27 PM
To: Dylan Frederick <[e-mail]>, Chris McCarty <[e-mail]>, Kam Howell
<[e-mail]>
Please send it to me, Sherie Thornton said [e-mail]
Get Outlook for iOS
From: Dylan Frederick <[e-mail]>
Sent: Wednesday, January 24, 2024 2:25:20 PM
To: Chris McCarty <[e-mail]>; Sherie Thornton <[e-mail]>; Kam Howell
<[e-mail]>
Subject: Re: Update for SLCC Redwood Campus approval order

CAUTION: This is an external message from: [e-mail]. If you have quesons regarding its validity, please review how
to idenfy suspicious emails.
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1/24/24, 3:03 PM State of Utah Mail - Update for SLCC Redwood Campus approval order
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r5475314996158585112&simpl=msg-a:r-64022641642635…2/2
Dylan Frederick <[e-mail]>Wed, Jan 24, 2024 at 2:29 PM
To: Sherie Thornton <[e-mail]>
Cc: Chris McCarty <[e-mail]>, Kam Howell <[e-mail]>
Thanks Sherie. I will list you as the primary contact for this permit, is that ok? If so could you provide a work phone
number?
[Quoted text hidden]
Sherie Thornton <[e-mail]>Wed, Jan 24, 2024 at 2:45 PM
To: Dylan Frederick <[e-mail]>
Dylan,
My phone number is 801-957-4902.

Thank you,

Sherie Thornton
Environmental Health and Safety Manager
Office: 801-957-4902

[Quoted text hidden]
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…1/17
Dylan Frederick <[e-mail]>
RE: Update NOI for SLCC Redwood Campus - New Boiler
1 message
Rich Millet <[e-mail]>Wed, Feb 23, 2022 at 9:31 AM
To: Dylan Frederick <[e-mail]>
Cc: Kameron Howell <[e-mail]>, Wayne Sagendorf <[e-mail]>
Dylan I have completed Form 19, to the best of my ability, see the attached PDF file. I have also
attached a PDF copy of the boiler specifications from the manufacturer. The specification sheet
lists the emissions from the boiler. I have also attached three pictures of the three data plates that
are attached to the boiler.

Please let me know if this is sufficient to include the new boiler in the NOI for our Redwood
Campus we submitted last year.

Thank you for your help.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 17, 2022 10:28 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Emissions Data for Emergency Generator at the Technology
Building Cooling Tower

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…2/17
I've looked through the documents you sent me for the NOI, and it looks like the new boiler was not requested in the NOI.
I've linked some DAQ documents to add the Boiler into the permit and resubmit the NOI.

Fill out the document "Form 19" to the best of your ability, and then use the two attached sheets to estimate the annual
emissions from the boiler. For natural gas boilers, federal language allows for up to 48 hours of fuel use for periodic
testing, maintenance, or operator training before the boiler becomes applicable to 40 CFR 63 Subpart JJJJJJ. This
subpart imposes emission standards on institutional boilers such as the one you've described. I believe the subpart allows
for fuel use during any time of gas curtailment and wouldn't count against the 48 hours mentioned above. Here is the list
of excluded boilers in the subpart if you're curious: https://www.law.cornell.edu/cfr/text/40/63.11195. If the boiler is running
all the time, estimate 48 hours of fuel oil use and 8712 hours of natural gas use to account for the rest of the year, then
add the two emission totals together and write that total on form 19. If you're ok with tracking the hours the boiler
operates, you can submit a reduced total of hours the boiler operates on natural gas.

If you can, please also fill out form 2 and 4 so that I have the correct address and contact information for the campus, as
well as an overview of what is being updated in the permit. I should have asked for this before, so my apologies for piling
more work on you now.

Finally, you will need to include a BACT analysis for this boiler, as it is a high enough rating that it cannot be excluded
from the NOI process. This would be evaluating the feasibility of installing low-NOx burners or ultra-low NOx on the boiler,
including the cost of upgrading compared to the potential emission reductions. I can help with this if this is confusing, but I
would at least need a cost estimate for purchasing and installing the upgraded burners. It's likely this would not be
considered economically feasible given the size of the boiler, but get an estimate anyways to have a paper trail to prove
this. You should be able to contact the boiler manufacturer to get an estimate for this.

So to summarize, fill out the forms I've attached, fill out the emission spreadsheets for the boiler (48 hours for fuel oil,
8712 hours for natural gas unless you'd like a restriction on hours written into the permit), and then write an analysis that
considers the feasibility of adding Low-NOx or Ultra-Low NOx burners to the boiler.

I also attached everything I received previously so you have it together in one file.

I wanted to also say my apologies for the long turnover time, I had fallen behind on the project and I'm hoping that this
can be a chance to reset and get the project out.

Feel free to call, email me, or request a video conference if you need any help getting the requested information. Thank
you, hope you had a good new year and that you're doing well.

On Wed, Feb 16, 2022 at 3:22 PM Rich Millet <[e-mail]> wrote:
Hi Dylan this is Rich Millet at SLCC. I submitted an NOI with you almost a year ago. I was
reminded this week that SLCC put a new boiler into operation back in February 2019. I don’t
have a copy of the NOI I submitted but I thought the new boiler was part of that NOI. Would you
please tell me if the NOI includes the new boiler? If not what do I need to do to get it included?
The new boiler is 8.1 MMBtu/hour unit that runs on natural gas with diesel #2 as backup if the
natural gas is curtailed.

Thank you for your help!
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…3/17

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Rich Millet
Sent: Monday, March 15, 2021 2:46 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Emissions Data for Emergency Generator at the Technology
Building Cooling Tower

Please see the attached PDF file for my updated BACT analysis. Hopefully this enable you to
submit our NOI for Redwood Campus.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Monday, March 15, 2021 1:40 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Emissions Data for Emergency Generator at the Technology
Building Cooling Tower

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…4/17
That is exactly what I was looking for. I would write in the analysis that the engine is a tier-3 certified engine, and that
add on controls/upgrading to a tier 4 engine would not be cost effective given the low emissions predicted. That should
be enough to move forward. Let me know when you've revised the BACT analysis for the engine with this new
information, and I'll take one last look and see if we can get the modification process started.

On Mon, Mar 15, 2021 at 12:28 PM Rich Millet <[e-mail]> wrote:
Dylan,

I just received an e-mail message from Generac giving me the emissions data for the
replacement generator at our Technology Building Cooling Tower, please see the attached
PDF file. This information was not in the owner’s manual or in any of the paperwork we
originally received from Generac. I have also included a picture of the data plate on the
generator. As you can see from the data plate, this engine or generator was made on 2017-
01-03 that is why the statement of exhaust emissions is for a 2016 FPT diesel fueled
generator.

Will this be sufficient for you to process the NOI for SLCC’s Redwood Campus?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, March 10, 2021 9:47 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

I'm not 100% sure where they include that information, but yes I'd try checking the owner's manual.

On Wed, Mar 10, 2021 at 8:13 AM Rich Millet <[e-mail]> wrote:
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…5/17
Thank you for the update. Do you know where I could find the a certificate showing what
emissions the engine is has? Is this information supposed to be in the owner’s manual?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, March 9, 2021 4:48 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its
validity, please review how to identify suspicious emails.
Rich,

Sorry for the delay, I've had a busy couple of weeks. I looked at the BACT submission, and I think I would accept
the arguments for the first two items, but for the generator, could you change the analysis to quantify how the new
generator improved emissions? We obviously like upgraded engines, I just wanted to see if you had a certification
statement that shows what the new engine emits. Again, if the engine replaced two older ones then that is already
good, we just want the application to be clear as to why further improvements are infeasible. Describing the
engine emission rates would help. Once that is done I can gather the application materials you've sent me and I'll
forward this to my manager to make the project official.

Let me know if you have any questions,

Thank you

On Tue, Mar 9, 2021 at 4:03 PM Rich Millet <[e-mail]> wrote:
Do you an update on my NOI application?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…6/17
801-520-0260 Cell

From: Rich Millet
Sent: Friday, February 19, 2021 1:37 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

Dylan please see the attached PDF document for BACT Analysis of the three additions to
SLCC Redwood Campus’ NOI application. Please let me know if my analysis is
adequate?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 18, 2021 1:01 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its
validity, please review how to identify suspicious emails.
Rich,

Simply put, for each new source of emissions that will be included in the permit, you should include a list of
potential emission controls that could be applied to reduce the total emissions coming from the equipment. The
analysis then considers each of these potential controls, and considers the economic, environmental, and
energy costs of each option, and eliminates options that are impractical based on the feasibility of
implementing the controls or the potential economic/environmental/energy costs.

If I recall, there was a painting operation, a small baghouse, and an emergency engine that were being added?
So for the painting and emergency engine, see what options there are to reduce emissions. This might be
installing a particulate filter, or upgrading the engine to one with stricter emission standards. For the baghouse,
I would consider other controls for particulate matter and just make a comparison on how effective those other
controls would be if they were installed instead of the baghouse. I remember the total emissions you calculated
being pretty low, so there isn't much room to improve emissions from these sources and its likely any additional
controls are economically infeasible, but the analysis has to be done for each new source of emissions
regardless.
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…7/17

I hope that helps, let me know if I can be of any further assistance.

On Thu, Feb 18, 2021 at 12:52 PM Rich Millet <[e-mail]> wrote:
Please remind me, what is the BACT analysis?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 18, 2021 12:46 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its
validity, please review how to identify suspicious emails.
Good Afternoon,

I had wondered what had happened with your application. I had last indicated that there was no BACT
analysis submitted with the attachments you last sent me, and I believe that was the last thing I heard from
your end. Since this wasn't a complete application, I was waiting to see this analysis before sending the
application to my manager to make the process official. That should be the only thing remaining that is
needed to complete the application. Let me know if you have any questions about what to do for the BACT
analysis.

On Thu, Feb 18, 2021 at 11:28 AM Rich Millet <[e-mail]> wrote:
Hi Dylan,

It has been a few months since I last communicated with you. What is status of the
updated NOI for our Redwood Campus?

Rich Millet, CSP
Salt Lake Community College
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…8/17
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Rich Millet
Sent: Thursday, August 27, 2020 8:39 AM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Status of Application

In order to help me partially complete Form 13 – Spray Booths, I contacted
Professional Automotive Equipment, the company that services our paint booth, and
they gave me the answers to Box Numbers 1, 2, 3, 8, 9, 11, 12, and 13. The person
from Professional Automotive Equipment is familiar with our processes and he
estimated that we use 200 pounds of oil based paints and solvents per year. I made
a mistake on my equation in Box 13. It should be 200 lbs./2000 lbs. = 0.1 or 10% of
one ton.

I hope this helps.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 26, 2020 4:43 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have questions regarding
its validity, please review how to identify suspicious emails.
Rich,

All this looks good, only thing I might do is make the calculation for form 13 a little bit clearer, I can't tell
what is written to come up with 0.1 tons per year. Did you have a BACT analysis ready for the new stuff
being added to the permit? I can review that as well and tell you if I need any more information for that as
well.
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:1725572260770584…9/17

On Wed, Aug 26, 2020 at 4:23 PM Rich Millet <[e-mail]> wrote:
Here are the three DEQ forms and associated paper work to update our NOI.
Please review this information and tell what else you need from me

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 26, 2020 12:01 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have questions
regarding its validity, please review how to identify suspicious emails.
I think if you have the relevant SDS sheets and the volume that is used, this should be enough to go
forward. At this time, we prefer electronic submissions as they're easier to access and share for review
purposes. Is there anything else you need for the NOI or has everything been compiled? If everything
is ready, I can take a quick look before you officially submit the NOI to make sure everything is
accounted for and looks correct.

On Wed, Aug 26, 2020 at 11:42 AM Rich Millet <[e-mail]> wrote:
You are correct concerning the size and the amount of oil based paints that we
use. The size of the spray booth is 14’ X 24’ = 336 square feet. The attached
Excel file is a list of the oil based paints and solvents that we use. Per your
recommendation we have provided the upper end of the volume of the chemical
projected to be used, see the far right column of the Excel file. I have also
attached a partially completed copy of Form 13 Spray Booths. Do you need
more information than what I have provided to complete this part of our
application? I have attached electronic copies of the Safety Data Sheets on the
list or I can provide hard copies if you would prefer.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…10/17
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 26, 2020 11:06 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have questions
regarding its validity, please review how to identify suspicious emails.
Rich,

Thanks for the update. If I recall, the spray booth was a very small source of VOC emissions, maybe
some particulates. Questions 1,2, and 3 seem to be questions that are necessary for modeling if it is
determined that the site should model for its impact on PM10 NAAQS. I don't think that would end
up being necessary for the site based on what I remember, so I think for now its fine if you leave that
part of the form blank. If you have been able to get the rest of the information on that form filled out, I
think that should be sufficient.

On Wed, Aug 26, 2020 at 10:33 AM Rich Millet <[e-mail]> wrote:
Dylan I wanted to update you regarding our NOI Status application.

Form 17 – Diesel Powered Standby Generator, we have completed the
information for this form.
Form 10 - Fabric Filters for our Cabinet Shop, with the assistance of an
old colleague I believe have completed this form.
Form 13 - Spray Booths for our Paint Shop, I am still struggling to
complete this form. I don’t know how to get the answers to Questions 1,
2, and 3. We do not have any drawings of the spray booth. Do you have
any suggestions on how to get this information?
With the fire in our ATC building in June, the Print Shop has been
effectively shut down, so as you agreed below we will not consider the
Print Shop in our application.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…11/17
From: Rich Millet
Sent: Monday, July 6, 2020 12:35 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Print Shop No Longer at Redwood
Campuss

Dylan due to the fire mentioned in the previous messages our Print Shop will
no longer be located at our Redwood Campus for the foreseeable future.
Since it is no longer functioning do we need to include it in our updated NOI
application?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Monday, June 29, 2020 9:41 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Building Fire Caused Delay

CAUTION: This is an external message from: [e-mail]. If you have questions
regarding its validity, please review how to identify suspicious emails.
Rich,

I had only heard about the fire in passing. It's a good thing no one was injured. I'm not worried
about the delay, just keep working on getting what information you can. This is the benefit of
having pre-NOI meetings before submitting the application, as this doesn't cause a delay on the
actual project to update the permit. Thank you for the update.

On Mon, Jun 29, 2020 at 9:06 AM Rich Millet <[e-mail]> wrote:
Dylan I don’t know if you heard but we had a fire at our Redwood Campus
this last week. The fire was in our Applied Technology Center building and
the building is basically destroyed. It appears that all that is left of the
building is the outside walls. Gratefully no one was injured during the fire.
Unfortunately our Print shop was in this building and all of their equipment
and computers were destroyed. If you recall we needed the Print Shop to
give me an updated list of the amounts of chemicals they were using. With
the fire and the loss of computers there is going to be a delay in getting this
information.
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…12/17

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
M: N/A
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…13/17
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…14/17
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…15/17
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

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Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
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Division Name
Dylan Frederick
Environmental Engineer | Minor NSR Section
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…16/17
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airquality.utah.gov
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P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
1/24/24, 12:19 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1725572260770584867&simpl=msg-f:172557226077058…17/17
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
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5 attachments
IMG_6197.JPG
4731K
IMG_6198.JPG
6045K
IMG_6199.JPG
5508K
Form19 (Natural Gas Boilers and Liquid Heaters) for Miura Boiler.pdf
130K
Boiler Specifications EX-200SGO-07.pdf
94K
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…1/21
Dylan Frederick <[e-mail]>
RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency
Generator, Paint Shop and Baghouse for Cabinetry Shop
Rich Millet <[e-mail]>Thu, Mar 10, 2022 at 10:40 AM
To: Dylan Frederick <[e-mail]>
Cc: Kameron Howell <[e-mail]>
Dylan on February 3, 2022, we had Kaidan Mickelson from Miura, the manufacturer of our new
boiler, come to our Redwood campus. He attempted to tune our new boiler so we could achieve a
Low NOx result. He was unable to get our NOx level below 30 PPM. He was able to reduce the
NOx level to 72 PPM. Our boiler does not have a Low NOx burner, so this is the best that we can
do without completely replacing the boiler. That option is not economically feasible.

I have attached the maintenance report that we received from Miura. Is this adequate for this NOI?

Thank you for your help!

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, March 1, 2022 2:32 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and
Baghouse for Cabinetry Shop

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…2/21

I think that should be sufficient. With that email, I would include a written submission explaining that you tried to get a
retrofit for a low-Nox boiler but the manufacturer determined it was infeasible, and that you've tuned it and will conduct
regular maintenance on it instead. That should be enough, thank you.

On Tue, Mar 1, 2022 at 2:28 PM Rich Millet <[e-mail]> wrote:
Dylan we have contacted Miura America, the manufacturer of the new boiler, mentioned in this
NOI. They do not have a retro fit option to make this boiler a Low NOx boiler. They are going to
come to our heat plant on Thursday, March 3, 2022 and attempt to tune the boiler to get the
lowest NOx reading possible. They will then provide us with a measurement of the NOx
readout.

I will send you an email after they complete the tuning with the value of the NOx. Will this be
acceptable for the Best Available Control Technology (BACT) analysis?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, February 23, 2022 3:42 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and
Baghouse for Cabinetry Shop

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

Per our phone conversation, I modified Form 2 so that the description reads a bit better and describes the entire
project. I also noticed the SIC code was wrong, so I corrected it. If this is ok with you, please add a signature to this
document. Thanks for calling in, please let me know if you have any further questions, thank you.

On Wed, Feb 23, 2022 at 2:26 PM Dylan Frederick <[e-mail]> wrote:
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…3/21
Rich,
The last AO issued for this facility was "DAQE-AN105050004-17". For the description in section 8 of that form, this
will encompass all the changes you need to make, so maybe write something like "Modification to add new 8.1
MMBtu/hr boiler, new emergency engine, painting operations and baghouse for wood shop." Otherwise I think
everything else was filled out correctly. I also got the Form 19 and boiler information you submitted, I think that is
filled out best you can so we should be good there. I think all we need is a BACT analysis for the boiler and emission
calculations for it. The inventory I got for the boiler isn't what we are looking for I think, It was pretty hard to read
everything they had in there. Let me know if the attached spreadsheets are ok to include as they are filled out now,
these reflect the potential to emit of the boiler with no restrictions.

The BACT analysis just needs to detail what controls can be implemented on this boiler as if it was newly installed.
See what information you can get on an estimate for adding a Low-NOx 30 ppm burner to the boiler, and we can
evaluate if that is feasible or not (experience says this probably wouldn't be cost effective but we need to be sure).

Please let me know if you have any further questions on what to do moving forward.
On Wed, Feb 23, 2022 at 11:16 AM Rich Millet <[e-mail]> wrote:
I have filled out Form #2 the best that I can. It would not allow me to complete some
sections. I do not know the AO number. This AO was for items that were identified during
an inspection conducted by Debbie Olson, from the DEQ on February 25, 2020. During this
inspection several non-compliance items were identified including the replacement of two
emergency generators with one generator, a new boiler in our Heat plant, operations in our
paint shop and a baghouse used in our cabinetry shop.

Would you please tell me the AO number for this project and anything else that I need to
do? Thank you very much!

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 17, 2022 10:28 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Emissions Data for Emergency Generator at the
Technology Building Cooling Tower

1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…4/21
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validity, please review how to identify suspicious emails.
Rich,

I've looked through the documents you sent me for the NOI, and it looks like the new boiler was not requested in
the NOI. I've linked some DAQ documents to add the Boiler into the permit and resubmit the NOI.

Fill out the document "Form 19" to the best of your ability, and then use the two attached sheets to estimate the
annual emissions from the boiler. For natural gas boilers, federal language allows for up to 48 hours of fuel use for
periodic testing, maintenance, or operator training before the boiler becomes applicable to 40 CFR 63 Subpart
JJJJJJ. This subpart imposes emission standards on institutional boilers such as the one you've described. I
believe the subpart allows for fuel use during any time of gas curtailment and wouldn't count against the 48 hours
mentioned above. Here is the list of excluded boilers in the subpart if you're curious: https://www.law.
cornell.edu/cfr/text/40/63.11195. If the boiler is running all the time, estimate 48 hours of fuel oil use and 8712
hours of natural gas use to account for the rest of the year, then add the two emission totals together and write
that total on form 19. If you're ok with tracking the hours the boiler operates, you can submit a reduced total of
hours the boiler operates on natural gas.

If you can, please also fill out form 2 and 4 so that I have the correct address and contact information for the
campus, as well as an overview of what is being updated in the permit. I should have asked for this before, so my
apologies for piling more work on you now.

Finally, you will need to include a BACT analysis for this boiler, as it is a high enough rating that it cannot be
excluded from the NOI process. This would be evaluating the feasibility of installing low-NOx burners or ultra-low
NOx on the boiler, including the cost of upgrading compared to the potential emission reductions. I can help with
this if this is confusing, but I would at least need a cost estimate for purchasing and installing the upgraded
burners. It's likely this would not be considered economically feasible given the size of the boiler, but get an
estimate anyways to have a paper trail to prove this. You should be able to contact the boiler manufacturer to get
an estimate for this.

So to summarize, fill out the forms I've attached, fill out the emission spreadsheets for the boiler (48 hours for fuel
oil, 8712 hours for natural gas unless you'd like a restriction on hours written into the permit), and then write an
analysis that considers the feasibility of adding Low-NOx or Ultra-Low NOx burners to the boiler.

I also attached everything I received previously so you have it together in one file.

I wanted to also say my apologies for the long turnover time, I had fallen behind on the project and I'm hoping that
this can be a chance to reset and get the project out.

Feel free to call, email me, or request a video conference if you need any help getting the requested information.
Thank you, hope you had a good new year and that you're doing well.

On Wed, Feb 16, 2022 at 3:22 PM Rich Millet <[e-mail]> wrote:
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…5/21
Hi Dylan this is Rich Millet at SLCC. I submitted an NOI with you almost a year ago. I
was reminded this week that SLCC put a new boiler into operation back in February
2019. I don’t have a copy of the NOI I submitted but I thought the new boiler was part of
that NOI. Would you please tell me if the NOI includes the new boiler? If not what do I
need to do to get it included? The new boiler is 8.1 MMBtu/hour unit that runs on natural
gas with diesel #2 as backup if the natural gas is curtailed.

Thank you for your help!

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Rich Millet
Sent: Monday, March 15, 2021 2:46 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Emissions Data for Emergency Generator at the
Technology Building Cooling Tower

Please see the attached PDF file for my updated BACT analysis. Hopefully this enable
you to submit our NOI for Redwood Campus.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Monday, March 15, 2021 1:40 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Emissions Data for Emergency Generator at the
Technology Building Cooling Tower
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…6/21

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its
validity, please review how to identify suspicious emails.
Rich,

That is exactly what I was looking for. I would write in the analysis that the engine is a tier-3 certified engine,
and that add on controls/upgrading to a tier 4 engine would not be cost effective given the low emissions
predicted. That should be enough to move forward. Let me know when you've revised the BACT analysis for
the engine with this new information, and I'll take one last look and see if we can get the modification process
started.

On Mon, Mar 15, 2021 at 12:28 PM Rich Millet <[e-mail]> wrote:
Dylan,

I just received an e-mail message from Generac giving me the emissions data for the
replacement generator at our Technology Building Cooling Tower, please see the
attached PDF file. This information was not in the owner’s manual or in any of the
paperwork we originally received from Generac. I have also included a picture of the
data plate on the generator. As you can see from the data plate, this engine or
generator was made on 2017-01-03 that is why the statement of exhaust emissions is
for a 2016 FPT diesel fueled generator.

Will this be sufficient for you to process the NOI for SLCC’s Redwood Campus?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, March 10, 2021 9:47 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its
validity, please review how to identify suspicious emails.
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…7/21
Rich,

I'm not 100% sure where they include that information, but yes I'd try checking the owner's manual.

On Wed, Mar 10, 2021 at 8:13 AM Rich Millet <[e-mail]> wrote:
Thank you for the update. Do you know where I could find the a certificate showing
what emissions the engine is has? Is this information supposed to be in the owner’s
manual?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, March 9, 2021 4:48 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

CAUTION: This is an external message from: [e-mail]. If you have questions regarding
its validity, please review how to identify suspicious emails.
Rich,

Sorry for the delay, I've had a busy couple of weeks. I looked at the BACT submission, and I think I would
accept the arguments for the first two items, but for the generator, could you change the analysis to
quantify how the new generator improved emissions? We obviously like upgraded engines, I just wanted
to see if you had a certification statement that shows what the new engine emits. Again, if the engine
replaced two older ones then that is already good, we just want the application to be clear as to why
further improvements are infeasible. Describing the engine emission rates would help. Once that is done I
can gather the application materials you've sent me and I'll forward this to my manager to make the
project official.

Let me know if you have any questions,

Thank you

On Tue, Mar 9, 2021 at 4:03 PM Rich Millet <[e-mail]> wrote:
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…8/21
Do you an update on my NOI application?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Rich Millet
Sent: Friday, February 19, 2021 1:37 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

Dylan please see the attached PDF document for BACT Analysis of the three
additions to SLCC Redwood Campus’ NOI application. Please let me know if my
analysis is adequate?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 18, 2021 1:01 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application, What is a BACT

CAUTION: This is an external message from: [e-mail]. If you have questions
regarding its validity, please review how to identify suspicious emails.
Rich,

Simply put, for each new source of emissions that will be included in the permit, you should include a
list of potential emission controls that could be applied to reduce the total emissions coming from the
equipment. The analysis then considers each of these potential controls, and considers the economic,
environmental, and energy costs of each option, and eliminates options that are impractical based on
the feasibility of implementing the controls or the potential economic/environmental/energy costs.
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:1726935500850379…9/21

If I recall, there was a painting operation, a small baghouse, and an emergency engine that were being
added? So for the painting and emergency engine, see what options there are to reduce emissions.
This might be installing a particulate filter, or upgrading the engine to one with stricter emission
standards. For the baghouse, I would consider other controls for particulate matter and just make a
comparison on how effective those other controls would be if they were installed instead of the
baghouse. I remember the total emissions you calculated being pretty low, so there isn't much room to
improve emissions from these sources and its likely any additional controls are economically infeasible,
but the analysis has to be done for each new source of emissions regardless.

I hope that helps, let me know if I can be of any further assistance.

On Thu, Feb 18, 2021 at 12:52 PM Rich Millet <[e-mail]> wrote:
Please remind me, what is the BACT analysis?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 18, 2021 12:46 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have questions
regarding its validity, please review how to identify suspicious emails.
Good Afternoon,

I had wondered what had happened with your application. I had last indicated that there was no
BACT analysis submitted with the attachments you last sent me, and I believe that was the last thing
I heard from your end. Since this wasn't a complete application, I was waiting to see this analysis
before sending the application to my manager to make the process official. That should be the only
thing remaining that is needed to complete the application. Let me know if you have any questions
about what to do for the BACT analysis.

On Thu, Feb 18, 2021 at 11:28 AM Rich Millet <[e-mail]> wrote:
Hi Dylan,
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…10/21

It has been a few months since I last communicated with you. What is status of
the updated NOI for our Redwood Campus?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Rich Millet
Sent: Thursday, August 27, 2020 8:39 AM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Status of Application

In order to help me partially complete Form 13 – Spray Booths, I contacted
Professional Automotive Equipment, the company that services our paint
booth, and they gave me the answers to Box Numbers 1, 2, 3, 8, 9, 11, 12, and
13. The person from Professional Automotive Equipment is familiar with our
processes and he estimated that we use 200 pounds of oil based paints and
solvents per year. I made a mistake on my equation in Box 13. It should be
200 lbs./2000 lbs. = 0.1 or 10% of one ton.

I hope this helps.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 26, 2020 4:43 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…11/21
CAUTION: This is an external message from: [e-mail]. If you have questions
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Rich,

All this looks good, only thing I might do is make the calculation for form 13 a little bit clearer, I
can't tell what is written to come up with 0.1 tons per year. Did you have a BACT analysis ready
for the new stuff being added to the permit? I can review that as well and tell you if I need any
more information for that as well.

On Wed, Aug 26, 2020 at 4:23 PM Rich Millet <[e-mail]> wrote:
Here are the three DEQ forms and associated paper work to update our
NOI. Please review this information and tell what else you need from me

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 26, 2020 12:01 PM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have questions
regarding its validity, please review how to identify suspicious emails.
I think if you have the relevant SDS sheets and the volume that is used, this should be enough
to go forward. At this time, we prefer electronic submissions as they're easier to access and
share for review purposes. Is there anything else you need for the NOI or has everything been
compiled? If everything is ready, I can take a quick look before you officially submit the NOI to
make sure everything is accounted for and looks correct.

On Wed, Aug 26, 2020 at 11:42 AM Rich Millet <[e-mail]> wrote:
You are correct concerning the size and the amount of oil based paints that
we use. The size of the spray booth is 14’ X 24’ = 336 square feet. The
attached Excel file is a list of the oil based paints and solvents that we
use. Per your recommendation we have provided the upper end of the
volume of the chemical projected to be used, see the far right column of
the Excel file. I have also attached a partially completed copy of Form 13
Spray Booths. Do you need more information than what I have provided to
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…12/21
complete this part of our application? I have attached electronic copies of
the Safety Data Sheets on the list or I can provide hard copies if you would
prefer.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 26, 2020 11:06 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Status of Application

CAUTION: This is an external message from: [e-mail]. If you have
questions regarding its validity, please review how to identify suspicious emails.
Rich,

Thanks for the update. If I recall, the spray booth was a very small source of VOC
emissions, maybe some particulates. Questions 1,2, and 3 seem to be questions that are
necessary for modeling if it is determined that the site should model for its impact on PM10
NAAQS. I don't think that would end up being necessary for the site based on what I
remember, so I think for now its fine if you leave that part of the form blank. If you have been
able to get the rest of the information on that form filled out, I think that should be sufficient.

On Wed, Aug 26, 2020 at 10:33 AM Rich Millet <[e-mail]> wrote:
Dylan I wanted to update you regarding our NOI Status application.

Form 17 – Diesel Powered Standby Generator, we have completed
the information for this form.
Form 10 - Fabric Filters for our Cabinet Shop, with the assistance
of an old colleague I believe have completed this form.
Form 13 - Spray Booths for our Paint Shop, I am still struggling to
complete this form. I don’t know how to get the answers to
Questions 1, 2, and 3. We do not have any drawings of the spray
booth. Do you have any suggestions on how to get this
information?
With the fire in our ATC building in June, the Print Shop has been
effectively shut down, so as you agreed below we will not consider
the Print Shop in our application.
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…13/21

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Rich Millet
Sent: Monday, July 6, 2020 12:35 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Update NOI for SLCC Redwood Campus - Print Shop No Longer at
Redwood Campuss

Dylan due to the fire mentioned in the previous messages our Print Shop
will no longer be located at our Redwood Campus for the foreseeable
future. Since it is no longer functioning do we need to include it in our
updated NOI application?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

From: Dylan Frederick <[e-mail]>
Sent: Monday, June 29, 2020 9:41 AM
To: Rich Millet <[e-mail]>
Subject: Re: Update NOI for SLCC Redwood Campus - Building Fire Caused Delay

CAUTION: This is an external message from: [e-mail]. If you have
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Rich,

I had only heard about the fire in passing. It's a good thing no one was injured. I'm not
worried about the delay, just keep working on getting what information you can. This is
the benefit of having pre-NOI meetings before submitting the application, as this doesn't
cause a delay on the actual project to update the permit. Thank you for the update.
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…14/21

On Mon, Jun 29, 2020 at 9:06 AM Rich Millet <[e-mail]> wrote:
Dylan I don’t know if you heard but we had a fire at our Redwood
Campus this last week. The fire was in our Applied Technology Center
building and the building is basically destroyed. It appears that all that
is left of the building is the outside walls. Gratefully no one was injured
during the fire. Unfortunately our Print shop was in this building and all
of their equipment and computers were destroyed. If you recall we
needed the Print Shop to give me an updated list of the amounts of
chemicals they were using. With the fire and the loss of computers
there is going to be a delay in getting this information.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
M: N/A
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…15/21

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…16/21

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…17/21

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Image
removed by
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Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…18/21

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…19/21

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Image
removed by
sender.

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…20/21
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
1/24/24, 12:23 PM State of Utah Mail - RE: Update NOI for SLCC Redwood Campus - New Boiler, New Emergency Generator, Paint Shop and Bag…
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1726935500850379198&simpl=msg-f:172693550085037…21/21
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Miura Low NOx Report for SLCC 03-03-2022.pdf
72K
1/24/24, 12:24 PM State of Utah Mail - FW: Finishing NOI for SLCC Redwood Campus - Miura Can't Retrofit Boiler to Make it Low NOx
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767884847589275586&simpl=msg-f:1767884847589275586 1/3
Dylan Frederick <[e-mail]>
FW: Finishing NOI for SLCC Redwood Campus - Miura Can't Retrofit Boiler to Make
it Low NOx
1 message
Rich Millet <[e-mail]>Mon, Jun 5, 2023 at 11:32 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
Dylan,

Please see the email message string below that contains an email from Frederick Han at Miura.
They “do not provide any retro fits to the EX-200 burner to make it low NOx”.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Frederick Han <[e-mail]>
Sent: Thursday, June 1, 2023 12:02 PM
To: Kam Howell <[e-mail]>
Cc: Rich Millet <[e-mail]>
Subject: RE: Finishing NOI for SLCC Redwood Campus

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Kam,

Thank you for reaching out.

I have confirmed with our factory that we do not provide any retro fits to the EX-200 burner to make it low NOx.
1/24/24, 12:24 PM State of Utah Mail - FW: Finishing NOI for SLCC Redwood Campus - Miura Can't Retrofit Boiler to Make it Low NOx
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767884847589275586&simpl=msg-f:1767884847589275586 2/3

We provide Low NOx options in our LX model boilers. I’ve attached a brochure for more information.

Let me know if you have any questions.

Frederick Han
West Division Maintenance Manager

MIURA AMERICA CO., LTD. (MAC)
Los Angeles Office
16016 Foothill Blvd.
Irwindale, CA 91702
Office: [phone]
Mobile: [phone]
www.miuraboiler.com

From: Kam Howell <[e-mail]>
Sent: Thursday, June 1, 2023 9:13 AM
To: Frederick Han <[e-mail]>
Cc: Rich Millet <[e-mail]>
Subject: FW: Finishing NOI for SLCC Redwood Campus

Fred,

Please send me an email stating Miura can not retrofit our boilers to low NoX.

Kam

1/24/24, 12:24 PM State of Utah Mail - FW: Finishing NOI for SLCC Redwood Campus - Miura Can't Retrofit Boiler to Make it Low NOx
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767884847589275586&simpl=msg-f:1767884847589275586 3/3
Miura-LX-Series-Steam-Boiler-Brochure_FINAL-V1.1.pdf
9839K
1/24/24, 12:27 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1767439644781528047&dsqt=1&simpl=msg-f:1767439644…1/3
Dylan Frederick <[e-mail]>
Finishing NOI for SLCC Redwood Campus
Rich Millet <[e-mail]>Wed, May 31, 2023 at 1:36 PM
To: Dylan Frederick <[e-mail]>
Cc: Josh Sylvester <[e-mail]>, James Roberts <[e-mail]>
Dylan,

I gave the attached list of paints to James Roberts, our Lead Painter, for him to review. James
compiled the list back in 2021 and told me that this list is still accurate.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Friday, May 19, 2023 1:07 PM
To: Rich Millet <[e-mail]>
Subject: Re: Finishing NOI for SLCC Redwood Campus

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

My apologies, I thought you were still focusing on recovering and wouldn't be able to review the sheet until next week.
Here is the VOC calculation, this was based on the SDS sheets you provided for me and the total amount of paint and
VOC containing materials used in the paint workshop. If this calculation looks ok to you, just let me know here.

On Fri, May 19, 2023 at 10:34 AM Rich Millet <[e-mail]> wrote:
Dylan,
1/24/24, 12:27 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1767439644781528047&dsqt=1&simpl=msg-f:1767439644…2/3

Just a reminder from our telephone conversation on May 18, 2023 that you were going to send
me a copy of the spreadsheet with the paints we use at SLCC for me to review with our Painting
Lead for accuracy.

Thanks!

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, May 17, 2023 6:22 PM
To: Rich Millet <[e-mail]>
Subject: Finishing NOI for SLCC Redwood Campus

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

It's been a while, I've been trying to reach out to you for a bit but it seems I had the wrong email entered for some time
and my emails weren't going through to you. I wanted to apologize for the delay in getting this project done, I've had
some errors on my end and personal issues that pushed this project back quite a bit, but hopefully we can get that all
fixed in the next few weeks. I was informed you'll be retiring soon so I wanted to try and get all this done before you
head out.

Do you have time for a call in Thursday or Friday? Please let me know what availability you have so I can go over what
I need to complete this application.

Thanks,

Dylan
1/24/24, 12:27 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1767439644781528047&dsqt=1&simpl=msg-f:1767439644…3/3

--

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

SLCC Redwood Paint workshop Emissions.xlsx
12K
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…1/8
Dylan Frederick <[e-mail]>
Finishing NOI for SLCC Redwood Campus - New Boiler Expense
13 messages
Rich Millet <[e-mail]>Mon, Jun 5, 2023 at 12:07 PM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
Dylan,

One of the items you required from SLCC to finish the NOI for our Redwood Campus is an
estimate of how much it would cost to install two new low NOx boilers. The attached PDF is the
cost to install one new 250 BHP boiler at our South City campus (and yes I submitted an NOI for
the new boiler at South City back in 2021 and no I haven’t heard back concerning that NOI). The
new 250 BHP boiler back in November 2022 cost $250,000.00. Since we have two boilers in
question for the Redwood NOI the estimated cost for two boilers is at least $500,000.00, if not
more. That amount of money is economically infeasible for SLCC.

I believe SLCC has made a good faith effort to reduce the level of NOx released by having the
manufacturer tune the boilers in question to as low as possible.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Kam Howell <[e-mail]>
Sent: Thursday, June 1, 2023 10:35 AM
To: Rich Millet <[e-mail]>
Subject: South Boiler

Rich,

Please see that 1 250 HP costs 250,000.
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…2/8

Kam
SLCC South Boiler and DA Budget.pdf
593K
Dylan Frederick <[e-mail]>Tue, Jun 6, 2023 at 3:33 PM
To: Rich Millet <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
Rich,
Thanks for getting this estimate. I've gone over what you submitted and I'm a bit confused, isn't there only the one Miura
boiler? This would be boiler #5, 8.1 MMBtu/hr, with the other boilers being listed in the permit already. I've attached the
page where the boilers are currently listed here.
There are some issues I have to address with this estimate if that is correct, but please confirm that I have the above
information correct .
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Boiler Equipment list SLCC Redwood.pdf
92K
Rich Millet <[e-mail]>Wed, Jun 7, 2023 at 10:32 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
SLCC put in a new Miura boiler (boiler #5) with 8.1 MMBtu/hour that runs on natural gas with diesel
#2 as backup if the natural gas is curtailed into operation back in February 2019 and initially that
was not included in the NOI. However we do have another Miura boiler that I believe was part of
the Approval Order that was issued in 2017. So we do have two identical Miura boilers.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…3/8

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, June 6, 2023 3:33 PM
To: Rich Millet <[e-mail]>
Cc: Kam Howell <[e-mail]>; Josh Sylvester <[e-mail]>
Subject: Re: Finishing NOI for SLCC Redwood Campus - New Boiler Expense

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Rich,

Thanks for getting this estimate. I've gone over what you submitted and I'm a bit confused, isn't there only the one Miura
boiler? This would be boiler #5, 8.1 MMBtu/hr, with the other boilers being listed in the permit already. I've attached the
page where the boilers are currently listed here.

There are some issues I have to address with this estimate if that is correct, but please confirm that I have the above
information correct .

On Mon, Jun 5, 2023 at 12:07 PM Rich Millet <[e-mail]> wrote:
Dylan,

One of the items you required from SLCC to finish the NOI for our Redwood Campus is an
estimate of how much it would cost to install two new low NOx boilers. The attached PDF is the
cost to install one new 250 BHP boiler at our South City campus (and yes I submitted an NOI for
the new boiler at South City back in 2021 and no I haven’t heard back concerning that NOI). The
new 250 BHP boiler back in November 2022 cost $250,000.00. Since we have two boilers in
question for the Redwood NOI the estimated cost for two boilers is at least $500,000.00, if not
more. That amount of money is economically infeasible for SLCC.

I believe SLCC has made a good faith effort to reduce the level of NOx released by having the
manufacturer tune the boilers in question to as low as possible.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…4/8
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Kam Howell <[e-mail]>
Sent: Thursday, June 1, 2023 10:35 AM
To: Rich Millet <[e-mail]>
Subject: South Boiler

Rich,

Please see that 1 250 HP costs 250,000.

Kam

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Dylan Frederick <[e-mail]>Wed, Jun 14, 2023 at 6:54 PM
To: Rich Millet <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
Rich,
Sorry for taking a while to get back to you. I spent a bit of time reviewing the materials submitted and got some
clarification from my manager, and there is an issue with the analysis you've presented for the boiler.
While the cost estimate of a new upgraded boiler you've given would be considered economically infeasible on its own,
the issue is that the boiler that is currently installed was not previously permitted. As this boiler was installed without
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…5/8
notifying the DAQ and without prior approval, I can't consider the cost of buying a new upgraded boiler alone. The correct
way to do this would be to consider the incremental cost of upgrading to this more efficient boiler burner. Thus, the cost
would have to be the $250,000 figure you provided minus the cost of the 'current' boiler.
My manager also noted that it is unlikely we can reasonably accept that nothing can be done to improve the NOx
emissions of the boiler, as new rules have been proposed and adopted that requires stringent standards for new boilers
being installed in the Salt Lake County area, as well as others. The applicable rule is R307-316 "NOx Emission Controls
for Natural Gas-Fired Boilers Greater Than 5.0 MMBtu." This rule would fully take effect in May 2024 and requires any
natural gas boiler over 5 MMBtu/hr to meet a NOx standard of 9 ppm. This standard is also being adopted for boilers
between 2 and 5 MMbtu/hr. If this is considered reasonable to implement a 9 ppm NOx standard at a state-wide level
now, it is reasonable to assume that it is economically feasible to install a boiler/burner that meets at least some low-NOx
standard. I don't think we can accept anything less than 30 ppm for this boiler given that context, and 9 ppm may be
feasible if the cost analysis is done correctly as stated in the above paragraph.
I would at minimum need the cost of the current boiler provided to consider this BACT analysis complete. I will check
tomorrow with my manager to clarify if he would want a cost estimate for a 9 ppm boiler included as well.
This standard does not apply to the other Miura boiler as it was permitted in 2017 and was granted approval for
construction. Please let me know if you'd like any clarification on what I've discussed here, thank you.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Rich Millet <[e-mail]>Tue, Jun 20, 2023 at 9:56 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>, Chris McCarty
<[e-mail]>
Dylan,

SLCC employee, Chris McCarty, will be the contact person who will be handling any EHS concerns
here at SLCC after I retire until a permanent replacement is named. Chris’s email address is
[e-mail] . He is included in this email message.

Would you please let all of us here at SLCC know what your manager said concerning a cost
estimate for a 9 ppm boiler?
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Jul 18, 2023 at 1:22 PM
To: Rich Millet <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>, Chris McCarty
<[e-mail]>
Hey all,
I'm not sure if this message got passed on or not, I'll try to send a reminder here.
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…6/8
So the issue with what we've received so far is that the economic analysis given that argued the existing 8.1 MMbtu/hr
boiler that was requested to be added to the permit can't improve emissions at all. So it would at best be tuned to 72 ppm
NOx. This is an issue because the Redwood SLCC campus is located in an ozone non-attainment zone according to
EPA regulations, and the State of Utah has just adopted R307-316 which requires any new or modified boilers meet a
standard of 9ppm NOx. As the rule is not currently in effect, you are not currently required to meet it, however, it does set
the standard that this is what is expected going forward for all sources in Utah. So, we can't accept the argument that no
controls can be applied to the boiler, as we'd expect it can meet some Low-NOx standard at minimum. The economic
reason why this was not possible that Rich provided did not make a comparison of how much an upgraded Low-NOx
burner would cost compared to the current one, it only presented the full cost of an upgrade. Because this boiler was
installed without being permitted first, the economic analysis would need to start from what the cost to upgrade is,
compared to the boiler with no controls.
This is a complicated part of the process so if there needs to be any clarifications, please let me know and I can call and
try to explain what we are asking for better if need be. Thanks for your help,
Dylan
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Chris McCarty <[e-mail]>Wed, Jul 19, 2023 at 12:42 PM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
Hi Dylan,

I’ll be working on gathering some cost estimates for you. Hopefully, I can find the needed information in a week or two.

Thanks,

Chris McCarty
Project Manager
Salt Lake Community College
(O) [phone]
[Quoted text hidden]
Chris McCarty <[e-mail]>Fri, Aug 4, 2023 at 1:52 PM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>
Hi Dylan,
1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…7/8

Below is the best information I believe you are requesting about the boilers. I am happy to follow-up with a conversation or
get more information if we need to. I am not familiar with many of the previous conversations on this topic.

From Miuraz:

“The EX boiler sold to you in 2018 was $134,000 on it’s own with out ancillaries.
This does not include tax.”

“Let me look into this for you in regards to the sale in 2018.

We have the LXN-250SGN model which is a low NOx boiler with 8.3 mmbtu output. (250 horsepower).
The boiler itself is listed at roughly $210,000. I cannot provide an exact amount due to the many options we offer, but it
will be close to that amount.

This does not include tax and freight or other ancillaries needed to install the boiler.”
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Aug 8, 2023 at 3:11 PM
To: Chris McCarty <[e-mail]>
Cc: Kam Howell <[e-mail]>
Chris,
If you'd like I can meet with you in a video call or phone call and go over the information we currently have. Is there a
time this week that would work for you?
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Chris McCarty <[e-mail]>Tue, Aug 8, 2023 at 4:01 PM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>
Hi Dylan,

I can make some time on Friday if that works or maybe next week if you aren’t available then.

1/24/24, 12:28 PM State of Utah Mail - Finishing NOI for SLCC Redwood Campus - New Boiler Expense
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1767887039028641336&simpl=msg-f:17678870390286413…8/8
Thanks,
Chris McCarty
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Aug 8, 2023 at 4:27 PM
To: Chris McCarty <[e-mail]>
Friday should work for me. What would be the best way to meet?
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Chris McCarty <[e-mail]>Wed, Aug 9, 2023 at 7:06 AM
To: Dylan Frederick <[e-mail]>
Hi Dylan,

How about zoom? 11? Would that work? I can send out an invite.

Thanks,
Chris
[Quoted text hidden]
Dylan Frederick <[e-mail]>Wed, Aug 9, 2023 at 9:18 AM
To: Chris McCarty <[e-mail]>
Chris,
Friday at 11 should work, and yeah a zoom meeting would be great. I'll see you then.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…1/10
Dylan Frederick <[e-mail]>
SLCC Redwood Heat Plant Boiler Burner Replacement
14 messages
Rich Millet <[e-mail]>Mon, Mar 28, 2022 at 11:32 AM
To: Dylan Frederick <[e-mail]>
Cc: Kameron Howell <[e-mail]>
Dylan,

Here are the emissions estimate statements for the new burners for our two boilers with the
different types of fuel. Each boiler is dual fired, for natural gas and diesel fuel when the natural gas
is shut off or curtailed. Unfortunately I do not have the current emissions data for these two
boilers. The installation of the new burners in these two boilers should take place within the next
two months if there are no hiccups or problems.

The Y65211 is for the Superior boiler #3

The CB-200 is the Clever Brooks boiler #1

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

4 attachments
Y65211 - NTDLG-252 - Emission Estimate - Natural Gas.pdf
32K
Y65211 - NTDLG-252 - Emission Estimate - No. 2 Oil.pdf
31K
CB-200-500-150ST 30 PPM NOx Emissions_EmissionGas.pdf
35K
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…2/10
CB-200-500-150ST 30 PPM NOx Emissions_EmissionOil.pdf
35K
Dylan Frederick <[e-mail]>Mon, Mar 28, 2022 at 1:07 PM
To: Rich Millet <[e-mail]>
Rich,
Thank you. I'll add this to the project.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Rich Millet <[e-mail]>Mon, Apr 11, 2022 at 2:16 PM
To: Dylan Frederick <[e-mail]>
Dylan do you need anything more from me for this NOI?

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

From: Dylan Frederick <[e-mail]>
Sent: Monday, March 28, 2022 1:07 PM
To: Rich Millet <[e-mail]>
Subject: Re: SLCC Redwood Heat Plant Boiler Burner Replacement

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…3/10
Rich,

Thank you. I'll add this to the project.

On Mon, Mar 28, 2022 at 11:32 AM Rich Millet <[e-mail]> wrote:
Dylan,

Here are the emissions estimate statements for the new burners for our two boilers with the
different types of fuel. Each boiler is dual fired, for natural gas and diesel fuel when the natural
gas is shut off or curtailed. Unfortunately I do not have the current emissions data for these two
boilers. The installation of the new burners in these two boilers should take place within the next
two months if there are no hiccups or problems.

The Y65211 is for the Superior boiler #3

The CB-200 is the Clever Brooks boiler #1

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…4/10
[Quoted text hidden]
Rich Millet <[e-mail]>Tue, Jun 20, 2023 at 11:23 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Chris McCarty <[e-mail]>
Dylan I sent you the below email message and the attached PDF files back on March 28, 2022
regarding the replacement of burners in two of our existing boilers. These should be part of our
Redwood NOI application as well.

Rich Millet, CSP
Salt Lake Community College
Environmental, Health and Safety Manager
801-957-4902 Office
801-520-0260 Cell

Remember that tomorrow is your reward for working safely today!

[Quoted text hidden]
4 attachments
Y65211 - NTDLG-252 - Emission Estimate - Natural Gas.pdf
32K
Y65211 - NTDLG-252 - Emission Estimate - No. 2 Oil.pdf
31K
CB-200-500-150ST 30 PPM NOx Emissions_EmissionGas.pdf
35K
CB-200-500-150ST 30 PPM NOx Emissions_EmissionOil.pdf
35K
Chris McCarty <[e-mail]>Fri, Jul 7, 2023 at 11:33 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>
Hi Dylan,

I am following up on this to see what next steps we need to complete to update our Redwood NOI. I also signed up for
SLEIS. Is there anything I should be made aware of for the NOI at our South City and Jordan locations? Happy to help
gather whatever information we need.
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…5/10

Thanks,

Chris McCarty
Project Manager
Salt Lake Community College
(O) [phone]
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Jul 11, 2023 at 1:02 PM
To: Chris McCarty <[e-mail]>
Chris,
I'll send you an email at the end of the day to determine what further information we need to complete this NOI. I'm pretty
sure we just need a BACT that accurately addresses the 8.1 MMBtu/hr boiler burner, but I want to double check in case I
missed anything. I am not assigned to the south city and jordan locations, only the Redwood Campus.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Chris McCarty <[e-mail]>Wed, Jul 12, 2023 at 12:22 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan,

Thank you for the update. I look forward to closing out the NOI process for our Redwood campus. Do you by chance
know how I can find out who is following along with our other NOIs?

Thanks,

Chris McCarty
Project Manager
Salt Lake Community College
(O) [phone]

1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…6/10
From: Dylan Frederick <[e-mail]>
Sent: Tuesday, July 11, 2023 1:03 PM
To: Chris McCarty <[e-mail]>
Subject: Re: SLCC Redwood Heat Plant Boiler Burner Replacement

CAUTION: This is an external message from: [e-mail]. If you have questions regarding its validity,
please review how to identify suspicious emails.
Chris,
[Quoted text hidden]
[Quoted text hidden]
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Dylan Frederick <[e-mail]>Thu, Aug 24, 2023 at 4:32 PM
To: Chris McCarty <[e-mail]>
Chris,
Since the last time we spoke, I've discussed with my manager the details of the boiler situation that we discussed over
Zoom on the 11th. Unfortunately, he's made it clear that the boiler BACT issues we discussed are not enough to accept
the determination that the boiler can be installed without any controls. The cost estimate provided tells me that it is within
the realm of economic feasibility to install a boiler with a Low-NOx burner. Unfortunately when the boiler was installed
can't be considered relevant to the permitting process as from our perspective it shouldn't have been installed
without approval in the first place. During our Zoom call, you indicated it is likely SLCC does not have the capital on hand
to purchase a new boiler outright. However, this does not account for the possibility of purchasing the equipment via a
loan. The cost estimate provided shows that to pay off the boiler over a 10-year lifespan of the equipment, it is still
economically feasible even at a 7% interest rate. I know the circumstances of this situation are not ideal and there isn't a
lot of control you had on your end, but that is the final determination I have to make. I can run the final cost calculation by
my manager to be sure, but otherwise I don't see a scenario where we can accept the 8.1 MMBtu/hr boiler operates with
no controls. This change needs to be made soon, or during May 2024 new rules will become applicable that require all
boilers install a much more stringent control of 9ppm, compared to the estimate SLCC provided for a 30 ppm boiler.
Please let me know if there is anything I can do to answer any questions you have or discuss this on call or online.
Dylan
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…7/10
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Chris McCarty <[e-mail]>Fri, Aug 25, 2023 at 9:47 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>
Hi Dylan,

Thank you for the response. Is there an appeals process that SLCC can go through or is this the final statement? I have
a meeting set-up with our HVAC director next week and I should be able to get you a response on what our plans are
moving forward.
[Quoted text hidden]
Chris McCarty <[e-mail]>Wed, Aug 30, 2023 at 11:41 AM
To: Dylan Frederick <[e-mail]>
Cc: Kam Howell <[e-mail]>, Josh Sylvester <[e-mail]>
Hi Dylan,

I spoke with our HVAC director, Kam Howell cc’d, and we have turned off the boiler for the last few months. We will no
longer use that boiler unless an appeal process can work in our favor. We will need to adjust the SLCC Redwood NOI to
state that we no longer use that boiler. We will follow all new applicable rules regarding future purchases.

Please let me know if there is any other information I can help provide and let us know next steps.

Thanks,

Chris McCarty
Project Manager
Salt Lake Community College
(O) [phone]

[Quoted text hidden]
Dylan Frederick <[e-mail]>Wed, Aug 30, 2023 at 3:01 PM
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…8/10
To: Chris McCarty <[e-mail]>
Chris,
I believe my manager gets back next week, I can try to go over this with him at that time.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Chris McCarty <[e-mail]>Fri, Sep 22, 2023 at 11:03 AM
To: Dylan Frederick <[e-mail]>, Sherie Thornton <[e-mail]>, Kam Howell
<[e-mail]>
Hi Dylan,

I’m looping in Sherie Thornton who will be taking over for me regarding the SLCC Redwood NOI. Please let us know
what the findings are between you and your manager.

Thanks again,
[Quoted text hidden]
Dylan Frederick <[e-mail]>Fri, Sep 22, 2023 at 1:52 PM
To: Chris McCarty <[e-mail]>
Cc: Sherie Thornton <[e-mail]>, Kam Howell <[e-mail]>
Hey all, my apologies for taking a bit to get back to you.
My manager said that we can take the boiler off the NOI, but it has to be disconnected from service at the facility. If it is
simply turned off it would still be installed at the facility which would then require the upgrade that we discussed in
previous emails. Let me know how you would like to proceed, thank you.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
10 attachments
1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:1728565720827874…9/10
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1/24/24, 12:31 PM State of Utah Mail - SLCC Redwood Heat Plant Boiler Burner Replacement
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1728565720827874132&simpl=msg-f:172856572082787…10/10
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Dylan Frederick <[e-mail]>Wed, Nov 22, 2023 at 6:42 AM
To: Chris McCarty <[e-mail]>
Cc: Sherie Thornton <[e-mail]>, Kam Howell <[e-mail]>
Hey all, I just wanted to give an update on this project. I should have a draft done this week that will be sent for peer
review internally. After some other reviews you can expect to see the permit yourself to ensure everything looks correct. I'll
aim to either have the permit to you after the new year or provide an update on where we are at by then. Please reach
out if you have any questions, thank you.
[Quoted text hidden]
Dylan Frederick <[e-mail]>
105050005 Compliance Review
6 messages
Dylan Frederick <[e-mail]>Wed, Jan 24, 2024 at 2:17 PM
To: Chad Gilgen <[e-mail]>
Chad,
Please see the attached ER and project folder. Please let me know if you have any questions or comments, thank you.
Salt Lake Community College Redwood Campus - 10...
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
RN105050005-24.rtf
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Chad Gilgen <[e-mail]>Tue, Jan 30, 2024 at 1:09 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan,
I have completed the compliance review for this one. See attached for my comments/questions.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
RN105050005-24_cg.rtf
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8/6/24, 5:13 PM State of Utah Mail - 105050005 Compliance Review
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r6858440404129269062&simpl=msg-a:r-650949376502527…1/3
Dylan Frederick <[e-mail]>Wed, Jul 3, 2024 at 8:40 AM
To: Chad Gilgen <[e-mail]>
Chad,
I'm sorry for any confusion, I'm sending this to you for a second review as modeling had to be done on this source and
some small changes were made. Please let me know if you have any questions or changes I should make.
[Quoted text hidden]
RN105050005-24.rtf
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Chad Gilgen <[e-mail]>Tue, Jul 16, 2024 at 1:50 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan,
Thanks for sending this over. I do not have any comments related to the modeling or conditions included as a result of
that. However, it doesn't look like any of my comments from my review in January were addressed so I have carried
those forward into this ER. See attached.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
RN105050005-24_cg.rtf
1546K
Dylan Frederick <[e-mail]>Sat, Jul 27, 2024 at 9:46 PM
To: Chad Gilgen <[e-mail]>
Chad,
I believe I've addressed all your comments. Let me know if there's anything else or I missed something.
[Quoted text hidden]
RN105050005-24.rtf
1549K
Chad Gilgen <[e-mail]>Tue, Aug 6, 2024 at 4:37 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan,
Thanks for sending this over. The changes look good and I have no additional comments.
Thanks,
Chad
8/6/24, 5:13 PM State of Utah Mail - 105050005 Compliance Review
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r6858440404129269062&simpl=msg-a:r-650949376502527…2/3
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
8/6/24, 5:13 PM State of Utah Mail - 105050005 Compliance Review
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r6858440404129269062&simpl=msg-a:r-650949376502527…3/3
Best Available Control Technology (BACT) Analysis
for Salt Lake Community College (SLCC) Equipment
March 2021

Paint Booth – Paint spraying in the paint booth occurs very infrequently as the majority
of the painting at SLCC occurs on site and not in the paint booth. This on-site painting
is done with water based latex paint. The filter system in the paint booth is serviced
once a year by a professional painting booth servicing company. The paint booth has
filters that are replaced on an as needed basis to ensure proper filtration of any over
spray. Due to the infrequent use of the paint booth the calculated emissions are very
low. Given this fact, there is very little room for improvement to the process to reduce
emissions. Upgrading or replacing the paint booth to today’s best available technology
is economically infeasible.

Baghouse – The baghouse is for the Cabinetry Shop at SLCC. While the Dust Hog
baghouse may not be new, it still functions quite well. Whenever a saw or sanding
machine is turned on in the Cabinetry Shop, employees also turn on the vacuum system
of the Dust Hog. No visible dust or emissions can be seen looking at the baghouse
when it is in operation. The total amount of emissions from the Cabinetry Shop is quite
low as the equipment is only used a small portion of the workday (estimated at less than
30% of a workday). Given this fact, there is very little room for improvement to the
process to reduce emissions. Upgrading or replacing the baghouse to today’s best
available technology is economically infeasible.

Emergency Generator or Engine – The new emergency generator that was installed in
2017 replaced two older generators thereby reducing air emissions. The new generator
was manufactured on January 3, 2017 and has a certified Tier 3 emissions rated
engine. At the time of the installation of this Generac generator it was brand new.
Adding on controls and/or upgrading to a Tier 4 engine now would not be cost effective
or economically feasible given the low emissions predicted for the very infrequent use of
this generator

Generac Power Systems, Inc. | P.O. Box 8 | Waukesha, WI 53187
P: [phone] © 2016 Generac Power Systems, Inc. All rights reserved. All specifications are subject to change without notice.
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Doc No. 10000000872
Rev. A 02/05/16
STATEMENT OF EXHAUST EMISSIONS
2016 FPT DIESEL FUELED GENERATOR
The measured emissions values provided here are proprietary to Generac and it’s authorized dealers. This information may only be disseminated
upon request, to regulatory governmental bodies for emissions permitting purposes or to specifying organizations as submittal data when expressly
required by project specifications, and shall remain confidential and not open to public viewing. This information is not intended for compilation or
sales purposes and may not be used as such, nor may it be reproduced without the expressed written permission of Generac Power Systems, Inc.
The data provided shall not be meant to include information made public by Generac.
Generator Model:SD350 EPA Certificate Number:GFPXL12.9IGR-007
kWe Rating:350 CARB Certificate Number:Not Applicable
Engine Family:GFPXL12.9IGR SCAQMD CEP Number:511711
Engine Model:F3BE9685A-E Emission Standard Category:Tier 3
Rated Engine Power (BHP)*: 530 Certification Type:Stationary Emergency CI
Fuel Consumption (gal/hr)*:27.02 (40 CFR Part 60 Subpart IIII)
Aspiration:Turbo/Aftercooled
Rated RPM:1800
*Engine Power and Fuel Consumption are declared by the Engine Manufacturer of Record and the U.S. EPA.
Emissions based on engine power of specific Engine Model.
(These values are actual composite weighted exhaust emissions results over the EPA 5-mode test cycle.)
CO NOx + NMHC PM
0.80 3.80 0.17 Grams/kW-hr
0.60 2.80 0.13 Grams/bhp-hr
• The stated values are actual exhaust emission test measurements obtained from an engine representative of the type described above.
• Values based on 5mode testing are official data of record as submitted to regulatory agencies for certification purposes. Testing was
conducted in accordance with prevailing EPA protocol, which is typically accepted by SCAQMD and other regional authorities.
• No emissions values provided above are to be construed as guarantees of emission levels for any given Generac generator unit.
• Generac Power Systems, Inc. reserves the right to revise this information without prior notice.
• Consult state and local regulatory agencies for specific permitting requirements.
• The emission performance data supplied by the equipment manufacturer is only one element required toward completion of the permitting
and installation process. State and local regulations may vary on a case-by-case basis and local agencies must be consulted by the permit
application/equipment owner prior to equipment purchase or installation. The data supplied herein by Generac Power Systems cannot be
construed as a guarantee of installability of the generating set.
Cy
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C SERIES
C SERIES
CYCLONE DUST
COLLECTORS
The Most
Effective Way To
Remove Large
Size Contaminants
from your factory.
HIGH-EFFICIENCY CYCLONE SEPARATOR
Industrial processes generate contaminants in a variety of sizes. Some
particles are visible to the human eye, while others are not. Large or
small, many of these pollutants are harmful to your employees and
need to be removed from the air to ensure a safe breathing environment.
That’s why United Air Specialists (UAS) created the C Series Cyclone
dust collector.
The C Series Cyclone is designed to effectively remove large to
moderate-size particles (chips, metal grindings, sawdust) from the air
stream. Used alone or in conjunction with another dust collector, the
Cyclone separates coarse contaminants from fine, non-visible particles,
and exhausts clean air.
UAS’ Cyclone dust collector offers airflow capacities ranging from
800 to 13,000 CFM. Its high-efficiency performance is accomplished
by means of the unit’s long tapered cone,
high-velocity inlet and welded helix. Dirty air
enters the unit at a high speed and is then
spun around in a spiral motion, throwing
particles against its cone wall. Centrifugal
force pushes the larger or heavy dust particles
down through the narrow part of the cone
and into a collection drum or hopper. Cleaned
air runs back up through the center of the unit
and is discharged back to the atmosphere or
into a UAS after-filter for further processing.
APPLICATIONS
• Buffing • Polishing
• Fiberglass/Plastic • Sawing
• Grinding • Woodworking
• Machining
www.dust-hog.net
ENERGY EFFICIENT
C Series Cyclone fans are self-cleaning, material handling
radial blades designed to deliver peak airow with low
horsepower to conserve energy. All models can be
installed indoors or outdoors, and clean air can be
returned inside your factory if the Cyclone is equipped
with a UAS after-lter.
One 30- or 55-Gallon Drum
(30 gal. shown)
Two 30- or 55-Gallon Drum (55 gal. shown)60ft3 or 110ft 3 Hopper
(C110H shown)
DISCHARGE OPTIONS
CUSTOMIZED SYSTEM
The C Series Cyclone oers a variety of congurations
to help meet your company’s industrial air cleaning
needs. With the assistance of a UAS Representative, you
can actually “design” a Cyclone unit and after-lter to
match your specic application. Select the direction of
the inlet and discharge areas, exhaust clean air back into
your plant or outdoors, or choose to use the Cyclone
alone or with a UAS after-lter.
Dierent ind ustrial applications generate varying amounts
of dust and debris, so UAS oers a v ariety of discharge
options. For small quantities, you have the choice of
30- and 55-gallon drums that can be congu r ed under
the Cyclone unit as a single-or two-drum conguration .
For larger loads, you may opt to use the Model C60H
hopper, which has a storage capacity of 60 ft3 or Model
C110H, which can hold 110 ft 3. Additionally, you can
add rotary airlocks to your system to constantly
discharge dust from a throw-out bin into an external
dust storage container.
FEATURES AND BENEFITS
Powder-Coated Finish
Components have electrostatically
applied paint that helps prevent fading
and chalking.
Come-Apart-
Construction
Allows for easy removal of
cone section without
replacing entire unit.
Internal Helix
Forces contaminants out of
the air and down into the
cone section.
Insert Section
Supports steep taper of
cone to maximize efficiency.
Complete Unitized
Assembly
Unit ships assembled for
immediate use.
True Storage Capacity
Discharge Drum
Cone sits flush with discharge area
to maximize storage capacity.
Blower Housing
Taperlock bushing allows for easy
replacement of fan wheel and motor.
Durable Motor
Able to withstand indoor and
outdoor temperatures.
Cone Section
www.dust-hog.net
OPTIONS AND ACCESSORIES
UAS pr ovides a comprehensive selection of options and
accessories to enhance the performance of your
C Series Cyclone dust collector. Some of these include:
•Pressure Relief Panel —Minimizes damage and
provides a degree of personal protection in the
unlikely event of an explosion that may result when
collecting explosive dusts.
•Silencer Package —Duct-type and acoustical
foam-lined silencers reduce unit noise levels.
•Fully Welded Construction —Provides a complete,
airtight seal to meet unique specications.
• After-Filter Magnehelic ®Gage Kit —Monitors pressure
drop to indicate when lters need to be changed.
•Access doors
•Aluminum fan wheel
•Drum lid latch kit/slide gate
•Explosion-proof motor
•Explosion venting
•Increased hopper clearance
•Leg extensions
•Lined plenum
•208/3/60 motor option
•Scroll outlet
•Sprinkler heads
•Throw out bin
*Heights include motor/blower where applicable.
**C-44 Series unit heights include throw-out bins.
***Weight does not include drum or hopper options.
C SERIES CYCLONE CONFIGURATIONS
Overall Height (inches)*After-lter Options
Motor 1D 2D 60H 110H Weight
Model CFM (Hp)Cyclone (One Drum) (Two Drums)(60ft3 Hopper)(110ft3 Hopper)(lbs)Interior Exterior
‘C-190 800-1,200 – 49 1/8" 92 7/8" 114 3/4"193 1/2"209 1/2"235 ––
C-192 800-1,200 2 64 3/4" 108 1/4"130 3/8" 209 1/8" 225 1/8" 320 AF192 –
C-200 1,250-2,250 –62 3/16"108 3/16"121 3/16"204 15/16"220 15/16" 320 ––
C-203 1,250-2,000 3 79 3/16" 125 3/16"137 3/16"222"238 5/8"430
C-205 1,500-2,250 5 80 9/16"126 9/16"138 9/16" 223 3/8" 240" 450
C-240 2,000-3,500 – 73"119 1/8"131 1/8"210"226"435 ––
C-247 2,000-3,500
C9-E, C18-E C18-W
C-3000 3,000-5,500 –92 1/2"138 1/8"150 1/8" 228 13/16"245 3/32"621 ––
C-3010 3,000-4,500 10 113 15/16"159 9/16" 171 9/16" 250 7/16"266 1/2"870
C-3015 4,000-5,500 15 119 1/2"165 1/8" 177 1/8"256"272 1/16"883
C-3600 4,500-8,000 – 112 1/16"154 3/4" 161 3/4"241 3/8"257 9/16"995 ––
C-3620 4,500-7,000 20 151 3/16" 194" 201" 284 7/8"301 1/4" 1,763 AF12, C18-E C18-W
C-3625 4,500-7,500 25 152 3/16" 195" 202"286"302 1/4" 1,857
C-3630 5,000-8,00 30 154 3/16" 197" 204" 287 1/2”303 3/4” 1,934
C-4400 **8,000-13,000 – 155"202 3/16" 211 3/16" 260 7/16"276 5/8"1,147 ––
C-4440 **8,000-11,500 40 175 9/32" 249"257 13/16" 307"323 1/4" 1,594 AF18, Two
Two C18-Es C18-Ws
C-4450 **8,000-13,000 50 175 9/32"249"257 13/16" 307"323 1/4"1,745 AF24, Two
Two C27-Es C27-Ws
AF4, C9-E C9-W
AF8, C18-E C18-W
AF12, C27-E C27-W
7 1/2 95 3/8” 141 5/8”232 1/2”248 1/2”605153 5/8”AF4, AF8,C9-W,
AF- VERSUS C-SERIES
For indoor Cyclone installations, UAS offers AF-Series
after-filters. These after-filters bolt directly to the
Cyclone blower outlet or are remotely mounted using
interconnecting ducting. AF-Series after-filters consist
of up to 24 10-oz. polyester felt zippered filter tubes.
Another option is the C-Series after-filter, which can be
installed inside or outside your facility. These units
remotely connect to the Cyclone with ducting and
empty into 55-gallon drums. Standard filter media
are 9-oz. polyester felt bags. Outdoor C-Series units
are designated with a “W” for weather enclosure,
and are constructed using epoxy-coated cold rolled
steel for the harshest environmental conditions.
A UAS Representative can help you determine which
after-filter is the best fit for your specific application.
CHOOSING AN AFTER-FILTER
Depending on your application, building specifications
and other factors, it may be necessary to use an
after-filter in conjunction with the C Series Cyclone.
In this case, the Cyclone dust collector captures the
heavier contaminants while the after-filter removes the
fine particles that may not be seen, but are harmful to
breathe. After-filters can be used indoors and outdoors,
and can be directly mounted to the C Series Cyclone
or remotely located using ducting.
W
AF4 Top
C9-E Front C18-W Front C27-W Front
C9-E Top C18-W Top C27-W Top
W W W
D D D
D
AF4 Front
70"
or
100"
24"
20 9/16"20 9/16"20 9/16"
www.dust-hog.net
AF-SERIES AFTER-FILTERS
Model W D Height Filter No. of Unit RecommendedInterior Area Filters Weight Cyclone(ft2)(lbs)
AF192 30"8" 72"25 1 20 C-192
AF4 51"27" 89" 72-104 4 91-95 C-203, C-205, C-247
AF8 78"27" 119" 208 8 182 C-247, C-3010, C-3015
AF12 78"40" 119" 312 12 244 C-3620, C3625, C-3630
AF18 105" 40" 119" 468 18 366 C-4440
AF24 132" 40" 119" 624 24 488 C-4450
STORAGE HOPPERS
C-SERIES AFTER-FILTERS
170 1/4"
146 1/4"
67"
63 1/4"
73 1/2"
91 3/4"
154 1/4"
130 1/4"
67"
92 1/2"
24"24"
52"
68"
Model C60H Side Model C60H Fr ont Model C110H Side Model C110H Fr ont
E indicates indoor applications only.
W indicates weather enclosure suitable for outdoor installation.
Model W D Height Filter No. of Unit Recommended
Interior Area Filters Weight Cyclone
(ft2)(lbs)
C9-E/C9-W 34" 34" 156" 119 9 600/645 C-203, C-205, C-247
C18-E/C18-W 68"34" 156" 238 18 1,175/1,225 C-247, C-3010, C-3015
C-3620, C-4440
C27-E/C27-W 102" 34" 156" 357 27 1,750/1,805 C-3625, C-3630, C-4450
44"81"57"81"
UAS, Inc. reserves the right to change design or without notice. IND-PSH-04-REV0208-PRO
WHY CHOOSE UNITED AIR SPECIALISTS?
A world-renowned reputation. For more than 40 years, we’ve been
the industry leader in air quality technology — a proven track record that
speaks for itself.
Commitment to quality products. Measuring our quality against
documented expectations, we practice continuous improvement methods
to anticipate challenges and implement successful solutions.
Unparalleled customer support. As a customer-driven solutions provider,
we earn credibility and establish successful relationships by exceeding
expectations for professional service and attitude.
Innovative technical leadership. Always, we keep technology at the
forefront — ensuring continuous product advancements through ongoing
investments in design and manufacturing.
Air Cleaning Specialists, Inc.
826 Horan Drive
Fenton, MO 63026
Ph: [phone]
E-mail: [e-mail]
www.dust-hog.net
Vendor Product Average use Notes
Upper End of the
Volume of the
Chemical
Projected to be
Used
Rust-Oleum Corporation Bin QT 6 PK Primer 2 - 16 ounce cans per month 4 -16 ounce cans
per month
Crown Crown Acetone 1 gallon per month 2 gallons/month
Crown Crown Denatured
Alcohol 1 gallon per month 2 gallons/month
M.L. Campbell Fast Dry Wood Paste
Filler 1 - small can per year 2 - small cans
Old Masters Gel Stain Dark
Walnut I quart per year 2 quarts per
month
Krylon
Krylon Color Master
Aerosol Primer Gloss
White
1 - 16 ounce spray can per
month
6 -16 ounce spray
cans per month
M.L. Campbell
Magnalac
Precatalyzed
Lacquer Stain 35
1 gallon per month 2 gallons per
month
Valspar Man O War Spar
Varnish 2 quarts per year 4 quarts per year
Sunnyside Corporation Paint Thinner 1 gallon per month 2 gallons/month
Fabulon Products
Professional
Polyurethane Super
Stain
I quart per year 1 gallon per year
Pratt and Lambert Paints
Red Seal Interior Oil
Eggshell Finish, Base
1
1 quart per year 1 gallon per year
Salt Lake Community College Paint Booth Oil Based Paints and Cleaning Solvent Usage
Vendor Product Average use Notes
Upper End of the
Volume of the
Chemical
Projected to be
Used
Salt Lake Community College Paint Booth Oil Based Paints and Cleaning Solvent Usage
Pratt and Lambert Paints
StainShield Solid
100% Acrylic Latex
Siding Stain
1 gallon per month 2 gallons per
month
Messmers Inc. UV Plus MC Series
Natural Clear 1 quart per year 1 gallon per year
Sunnyside Corporation VOC Complaint
Lacquer Thinner 1 gallon per month 2 gallons per
month
M.L. Campbell WoodSong II Stain
Base and PreStain 1 quart per year 2 quarts per year
Vendor Product Average use Notes
Upper End of the
Volume of the
Chemical
Projected to be
Used
Salt Lake Community College Paint Booth Oil Based Paints and Cleaning Solvent Usage