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Home My WebLink AboutDAQ-2025-0026201 DAQC-CI160490001-25 Site ID 16049 (B1) MEMORANDUM TO: FILE – INTERMOUNTAIN HEALTHCARE – Riverton Hospital THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: April 23, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: February 26, 2025 SOURCE LOCATION: 3741 West 12600 South Riverton, UT 84065 SOURCE CONTACTS: Jim Blankenau, Environmental Engineer 801-484-6114; James.Blankenau@imail.org OPERATING STATUS: Operating normally. PROCESS DESCRIPTION: Intermountain Healthcare Riverton Hospital operates a full-service hospital and a medical office building. Emissions are primarily associated with two 33.6 MMBtu/hr Cleaver Brooks steam boilers which run on natural gas, and two 2007 Cummins, diesel-fueled, 1,750 kW emergency generator engines (Generator #1 and Generator #2). There is also an underground diesel fuel storage tank. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN160490001-21, dated October 27, 2021 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, NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. MACT (Part 63) JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources, * ) ) * - $ % * 2 . & $ 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Intermountain Healthcare- Riverton Hospital 383 West Vine Street 3741 West 12600 South Murray, UT 84123 Riverton, UT 84065 SIC Code: 8062: (General Medical & Surgical Hospitals) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] 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] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. A construction notification letter was submitted April 10, 2023, according to Condition I.8, and is included in a previous inspection memo (DAQC-778-23). The 2023 Emission Inventory was submitted by the required date. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Intermountain Healthcare Riverton Hospital II.A.2 Two (2) Steam Boilers Rating: 33.6 MMBtu/hr each Primary Fuel: Natural Gas Emergency Fuel: Ultra-low Sulfur Diesel (ULSD) II.A.3 Two (2) Emergency Generator Engines Rating: 1,750 kW each (2,560 hp each) Fuel: ULSD Manufacturer Year: 2007 II.A.4 One (1) Underground Diesel Storage Tank Capacity: 30,000 gallons Content: ULSD Listed for informational purposes only. Status: In Compliance. No unapproved equipment was observed. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the specified values at the exhaust stack: A. All boilers when fired on natural gas - 10% opacity B. Emergency generator engines and boilers when fired on diesel - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from any stationary source on site shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions from any stationary source were observed during the inspection. One boiler was operating with no visible emissions. II.B.2 Boiler Requirements II.B.2.a The owner/operator shall not burn fuel oil in the dual-fuel boilers for more than 48 hours each, per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the dual-fuel boilers during periods of natural gas curtailment, gas supply interruption, or startups. [40 CFR 63 Subpart JJJJJJ, R307-401-8] 4 II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting fuel oil usage in each dual-fuel boiler shall be kept in a log and shall include the following: A. The date diesel fuel was burned B. The duration of operation on diesel fuel, in hours C. The reason for diesel fuel usage. [R307-401-8] Status: In Compliance. Each boiler typically burns diesel one hour per month for testing purposes. Operation logs viewed during the inspection indicate proper records are kept including the date, duration, and reason for diesel usage. The source also submits a semi-annual report with the total diesel fuel operation hours per calendar year. Refer to this report in the attachments. II.B.3 Emergency Engine Requirements II.B.3.a The owner/operator shall install emergency generator engines with a manufacturer's specification rate of 5.3 g/hp-hr or less for NOx. [R307-401-8] II.B.3.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's specification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] Status: In Compliance. Records viewed on site indicate the emergency engines meet manufacturer's specification rate of 5.3 g/hp-hr or less for NOx. The source is aware of the requirement to maintain emission rate records for the life of the equipment. II.B.3.b 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.3.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 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 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The source operated each engine less than 100 hours for non-emergency purposes for the rolling 12-month period. Operation logs are kept which include the date, duration, and reason for usage. These records were reviewed on site. Emergency engine #1 operated for 19 hours and engine #2 operated for 15 hours. II.B.3.b.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] Status: In Compliance. Non-resettable hour meters are installed and were viewed during the inspection. 5 II.B.3.c The owner/operator shall perform maintenance and testing of the emergency generator engines in accordance with the following: A. The owner/operator shall not operate the emergency generator engines for maintenance and testing operation before 10:00 AM or after 7:00 PM each day; B. The owner/operator shall not operate more than one (1) emergency generator engine at any one time during maintenance and testing operations; C. The owner/operator shall not test each emergency generator engine more than once per month. [R307-410] II.B.3.c.1 The owner/operator shall: A. Record the date and the time of the day that the maintenance and testing was performed; B. Record the emergency generator engine that was maintained and tested; C. Maintain records of the maintenance and testing on a daily basis. [R307-401-8] Status: In Compliance. Record reviewed onsite indicate the engines are tested according to these conditions. Only one engine operates at a time within the set time frame and no more than once per month for testing purposes. II.B.3.d The exhaust stack for each emergency generator engine shall vent vertically unrestricted with no obstruction beyond the opening of the stack. Stack height shall be no less than 24 feet as measured from the base of the stack. [R307-401-8] Status: In Compliance. The exhaust stacks vent vertically with no obstruction and the heights were observed to be at least 24 feet from the ground. II.B.3.e The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8] II.B.3.e.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.3.e.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. The source utilizes ULSD for the emergency engines. This was determined by a fuel purchase invoice provided by the fuel supplier. Refer to this in the attachments. 6 Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. The source has two 33.6 MMBtu/hr Cleaver Brooks steam boilers which run primarily on natural gas and diesel fuel for emergencies. Boiler ratings were provided and can be viewed in the attachments. A semi-annual NSPS Subpart Dc report was submitted January 30, 2025. Refer to this report in the attachments. Refer to Condition II.B.2.a for additional information. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The two 1,750 kW emergency engines were manufactured in 2007 and are equipped with non-resettable hour meters. Each engine operated less than 100 hours for non-emergency purposes. Refer to Condition II.B.3 for more details. NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. Status: In Compliance. The emergency engines are each equipped with a non-resettable hour meter. Fuel was verified to be ULSD. The source performs routine monthly and annual maintenance on each engine. Maintenance records are kept in a physical logbook which was viewed during the inspection. MACT (Part 63) JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources Status: In Compliance. Refer to Condition II.B.2.a for additional information. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Refer to Condition II.B.3.e for more details. Stationary Sources [R307-210] Status: In Compliance. This rule is satisfied through compliance with NSPS Part 60 Subpart IIII and Dc. Refer to these in the Federal Requirements section. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This rule is satisfied through compliance with MACT Part 63 Subpart ZZZZ and JJJJJJ. Refer to these in the Federal Requirements section. 7 EMISSION INVENTORY: Listed below are the 2023 Actual Emissions Inventory provided from Intermountain Healthcare - Riverton Hospital. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN160490001-21, dated October 27, 2021, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 35214.61 N/A Carbon Monoxide 21.90 2.264 Nitrogen Oxides 13.96 0.9584 Particulate Matter - PM10 2.26 0.200 Particulate Matter - PM2.5 2.26 0.0518 Sulfur Dioxide 1.30 0.0312 Volatile Organic Compounds 1.66 0.147 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Generic HAPs (CAS #GHAPS) 60 N/A Hexane (CAS #110543) 1040 92.62 PREVIOUS ENFORCEMENT ACTIONS: None. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN160490001-21, dated October 27, 2021, the overall status is: In Compliance. The source appears to be well maintained and operated. All records were current and made available during the inspection or via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the regular interval. NSR RECOMMENDATIONS: None. ATTACHMENTS: Semi-annual Subpart Dc Report, Fuel Purchase Invoice, Boiler #1 and #2 Ratings January 30, 2025 Minor Source Compliance Section Utah Division of Air Quality Attn: Chad Gilgen P.O. Box 144820 Salt Lake City Utah 84114-4820 Dear Mr. Gilgen, The New Source Performance Standards for Small Industrial-Commercial- Institutional Steam Generating Units (NSPS Boilers) 40 CFR 60 Subpart Dc requires reporting the quantity of fuel other than natural gas combusted during the reporting period for Riverton Hospital – Utah DAQ Site ID 160490. - Dates cover in this letter include July 1 through December 31, 2024 - Boiler operation hours on diesel fuel for the reporting period are as follows: o Boiler #1 – 7.5 hours o Boiler #2 – 7 hours - Fuel was delivered to the facility on 8/9/24. A copy of the low-sulfur certification is attached. In accordance with Utah Administrative Code R307-415-5d and based on information and belief formed after reasonable inquiry, I certify that the statements and information in this document are true, accurate, and complete. Sincerely, Jim Blankenau Intermountain Health, Canyons Region 383 W. Vine Street (4th floor), Murray, UT 84124 801-484-6114 James.Blankenau@imail.org Attachments: Riverton Hospital Oil Certification