DAQ-2024-007317

DAQC-284-24
Site ID 10405 (B1)
MEMORANDUMTO:FILE – INTERMOUNTAIN HEALTH CARE (IHC) – The Orthopedic SpecialtyHospital(TOSH)
THROUGH:Chad Gilgen, Minor Source Compliance Section Manager
FROM:Irene Tucker, Environmental Scientist
DATE:January 29, 2024
SUBJECT:FULL COMPLIANCE EVALUATION, Minor, Salt Lake County
INSPECTION DATE:January 24, 2024
SOURCE LOCATION:5848 South 300 East (Fashion Boulevard), Murray, UT – Central utilities plant is located on the west side of the parking lot.
SOURCE CONTACT:Jim Blankenau, P.G., Environmental EngineerOffice: 801.442.3896, Mobile: [e-mail]
OPERATING STATUS:Operating
PROCESS DESCRIPTION:IHC owns and operates TOSH in Murray. TOSH provides a variety of medical services. TOSH operates one dual-fuel
12 MMBtu Boiler, and two emergency diesel generators.The boiler provides steam and hot water, and emergency generators provide power during outages.
APPLICABLE REGULATIONS:AO dated September 24, 2019, DAQE-AN104050005-19
40 CFR Part 60, SubpartDc—Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units 40 CFR Part 60, Subpart IIII—Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
40 CFR Part 63, Subpart ZZZZ: National Emissions Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
SOURCE EVALUATION:
Name of Permittee:
Intermountain Healthcare
36 South State Street
Salt Lake City, UT 84111
Permitted Location:
The Orthopedic Specialty Hospital (TOSH)
5848 South Fashion Boulevard
Murray, UT 84107
UTM coordinates:425,300 m Easting, 4,499,700 m Northing, UTM Zone 12UTM Datum: NAD83
SIC code:8069 (Specialty Hospitals, Except Psychiatric)
Status: In compliance. The information above is correct and current. 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
1.8.
Status:
The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]
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]
In Compliance. IHC TOSH confirmed the installation and operation of the 1,220 HP Emergency Generator in a letter to the DAQ Director dated November 19, 2019. IHC TOSH did not exceed
any of the limits set forth in this AO. There were no modifications to the equipment or processes approved by this AO. IHC TOSH maintains records for a minimum of two years.IHC TOSH
maintains records of maintenance activities performed on authorized equipment of this AO. There were no breakdowns that resulted in an emissions event. The 2020 Emissions Inventory Report

indicated compliance with the PTEs of this AO.SECTION II: PERMITTED EQUIPMENTII.ATHE APPROVED EQUIPMENT
II.A.1
The Orthopedic Specialty Hospital (TOSH)
II.A.2
One (1) Dual-fuel Boiler
Max Rating: 12 MMBtu/hr Boiler
Fuel: Natural Gas/Fuel Oil
NSPS/MACT Applicability: 40 CFR 60 Subpart Dc
11.A.3
II.A.4
II.A.5
Emergency Generator Engine
Max Engine Rating: 1,220 hp (750 kW)
Manufacture Date: 07/13/15
Fuel: Diesel Fuel
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Emergency Generator Engine
Max Engine Rating: 1,220 hp (750 kW)
Model Year: 2018
Fuel: Diesel Fuel
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
Various boilers rated less than 5 MMBtu/hr each
Fuel: Natural gasStatus:In Compliance. There were no new or unapproved equipment observed onsite during this inspection. SECTION II: SPECIAL PROVISIONSII.BREQUIREMENTS 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
C.All other points - 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. [R307-305-3]
Status: In Compliance. There were no visible emissions observed from the boiler exhaust stacks, the diesel engine exhaust stacks, and all other points during this inspection. See the
attachment for additional information. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9.
II.B.2
Boiler Requirements
II.B.2.a
The owner/operator shall use natural gas as the primary fuel and #2 fuel oil as a backup fuel in the duel-fired boiler. [R307-401-8]
Status: In Compliance. IHC TOSH uses natural gas as the primary fuel and #2 fuel oil as a backup fuel in the 12 MMBTU duel-fuel boiler. On a rolling 12-month from January – December,
2023, the 12 MMBTU boiler ran on diesel fuel for a total of 6.8 hours. See the attachment for additional information.
II.B.2.b
II.B.2.b.1
The owner/operator shall not burn fuel oil in the dual-fuel boiler for more than 48 hours, 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 boiler during periods of natural gas curtailment, gas supply interruption, or startups. [40 CPR 63 Subpart JJJJJJ, R307-401-8]
Status: In Compliance. On a rolling 12-month from January – December, 2023, the
12 MMBTU boiler ran on diesel fuel for a total of 6.8 hours. See the attachment for additional information.
To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new12-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:
The date diesel fuel was burned
The duration of operation on diesel fuel, in hours
The reason for diesel fuel usage
Status: In Compliance. IHC TOSH records fuel oil usage of the 12 MMBTU dual-fuel boiler in a log, to include the date, the duration, and reason for fuel usage as required by this AO
Condition.
II.B.3
Emergency Generator Engine Requirements
II.B.3.a
II.B.3.a.1
II.B.3.b
II.B.3.c
I.B.3.d

II.B.3.d.1
II.B.4
II.B.4.a
II.B.4.a. l
The owner/operator shall not operate each emergency generator 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 engine during emergencies.
[ 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ, R307-401-8]
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:
The date the emergency engine was used
The duration of operation in hours
The reason for the emergency engine usage
[R307-401-8]
To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter on each emergency generator engine on site. [R307-401-8]
Status: In Compliance. The two diesel-fueled Emergency Generator Engines at IHC TOSH are only used for emergency purposes. The 2015, 1,220 HP Cummins Emergency Generator indicated 31
hours on a rolling 12-month, from January – December, 2023. The 2018, 1,220 HP Cummins Emergency Generator indicated 26 hours on a rolling
12-month, from January – December, 2023. IHC TOSH maintained records documenting the operation of each emergency engine in logs, to include the dates, duration, and reason for usage,
as required by this AO Condition. Both Emergency Generators are equipped with a non-resettable hour meters.
The stack for each emergency engine shall vent vertically unrestricted with no obstruction.
beyond the opening of the stack. Stack height shall be no less than 26 feet as measured from
ground level. [R307-401-8]
Status: In Compliance. The stack for each emergency engine vent was vertically unrestricted with no obstruction beyond the opening of the stack and confirmed by IHC TOSH to be greater
than 26 feet from the ground.
The owner/operator shall perform maintenance and testing of the emergency generator enginesduring non-emergency situations in accordance with the following:
A.No more than one (1) engine shall be operated at any one (1) time duringmaintenance and testing operations; and
B.Maintenance and testing operations shall not occur more than one (1) time permonth, per engine.
C.Maintenance and testing operations shall not occur before 6:00 am or after 6:00pm each day.
[R307-401-8]
Status: In Compliance. IHC TOSH performs maintenance and testing of the emergency generator engines during non-emergency situations in accordance with the requirements of this AO Condition.IHC
TOSH does not operate more than one engine at a time, and not more than once a month. Maintenance and testing operations are not conducted before 6:00 am or after 6:00 pm each day.

To determine compliance with the maintenance and testing requirements, the owner/operator
shall document the date and the hours of the day that the maintenance and testing was performed and the generator engine that was maintained and tested. [R307-401-8]
Status: In Compliance. IHC TOSH documented the dates and the hours of the day that the maintenance and testing were performed to include the generator engine that was maintained and
tested. See the attachment for additional information.
Fuel Requirements
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]
To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintainrecords of diesel fuel purchase invoices or obtain certification of sulfur content from the
dieselfuel supplier; The diesel fuel purchase invoices shall indicate the diesel fuel meets the ULSDrequirements. [R307-401-8]
In compliance. The Fuel Certification from RelaDyne characterizes the diesel as Ultra Low Sulfur Diesel Fuel with a sulfur content of 15 ppm. See the attachment for additional information.
APPLICABLE FEDERAL REQUIREMENTS
40 CFR Part 60, Subpart Dc—Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units
Status: In Compliance. IHC TOSH uses natural gas as the primary fuel and #2 fuel oil as a backup fuel in the 12 MMBTU duel-fuel boiler. In a rolling 12-month from January – December,
2023, the 12 MMBTU boiler ran on diesel fuel for a total of 6.8 hours.The Fuel Certification from RelaDyne characterized the diesel fuel as Ultra Low Sulfur Diesel Fuel with a sulfur
content of 15 ppm. See the attachment for additional information, the record of boiler maintenance, and the 40 CFR Part 60, Subpart Dc Reports; A semi-annual report from January to June
2023, and from July to December 2023.
40 CFR Part 60, Subpart IIII—Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
Status: In Compliance. The two diesel-fueled Emergency Generator Engines at IHC TOSH are only used for emergency purposes. The 2015, 1,220 HP Cummins Emergency Generator indicated 31.0
hours on a rolling 12-month, from January – December, 2023. The 2018, 1,220 HP Cummins Emergency Generator indicated 26.0 hours on a rolling 12-month, from January – December, 2023.
The two Emergency Generator Engines are certified EPA Tier 2. See the Compliance Statement in the attachment. The Fuel Certification from RelaDyne characterized the diesel as Ultra
Low Sulfur Diesel Fuel with a sulfur content of 15 ppm. Annual Preventive Maintenance was conducted on both Emergency Generators on March 30, 2023. See the attachment for additional
information.
40 CFR Part 63, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
Status: In Compliance. The Emergency Generators are each equipped with a non-resettable hour meter. According to an invoice from RelaDyne, the sulfur content of the diesel is characterized
as Ultra Low Sulfur Diesel.
AREA SOURCE RULES
R307-203 Emission Standards: Sulfur Content of Fuels
Status: In Compliance. The Fuel Certification from RelaDyne characterized the diesel as Ultra Low Sulfur Diesel Fuel with a sulfur content of 15 ppm. See the attachment for additional

information.R307-210 - Standards of Performance for New Stationary SourcesStatus: In Compliance. This area source rule is applicable to 40 CFR Part 60, Subpart Dc and Subpart IIII.
See Section III for compliance with this requirement.R307-214 -National Emission Standards for Hazardous Air PollutantsStatus: In Compliance. This area source rule is applicable to
40 CFR Part 63, Subpart ZZZZ. See Section III for compliance with this requirement.EMISSION INVENTORY:Status: In Compliance. The 2020 Emissions Inventory Report indicated compliance
with the PTEs of this AO.The 2020 Emissions Inventory, in tons/year:PM10:0.125SOx:0.018NOx:0.433CO:1.390VOC:0.092PREVIOUS ENFORCEMENT ACTIONS:No enforcement actions within the past fiveyears.
COMPLIANCE STATUS &RECOMMENDATIONS:IHC TOSH is in compliance with the conditions of AO DAQE-AN104050005-19, dated September 24, 2019. IHC TOSH maintained good housekeeping practices.
RECOMMENDATION FORNEXT INSPECTION:Inspect as usual.Required PPE includes steel-toe boots and safety glasses.
RECOMMENDATION FORNSR:None at this time.ATTACHMENTS:Visible Emissions Observation Form, Emergency Generator Preventative Maintenance, Boiler Preventative Maintenance, Fuel Certification,
EPA Tier 2 Compliance Statement, Subpart Dc Semi-Annual Reports; from January to June 2023, and from July to December 2023.