### DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISIONOF AIR QUALITY 

## ,..-.
Michael 0, Luvin GoYemor 150 North 1950West Reply to: State ofUtah Dianne R, Nielson. Ph.D. Salt Lake City, Utah 84114 DivisionofAir Quality Execul.ive Du-or (801) 536-4000 P.O, Box 144820 F, Burnell Cordner (80I) 536-4099Fax Salt Lake City, Utah 84114-4820 Du-or (801) 538-6621 T,D.D, DAQE-0103-93 February 11, 1993

James Van Orman Department of the Air Force HQ Ogden AFMC HAFB, Utah 84056-5990 Re: Modified Approval Order:for Aircraft Purge System Near Building 287 Davis County CDS A1 Dear Mr. Van Orman: This Modified Approval Order revises and replaces Modified Approval Order BAQE-021- 91 dated January 15, 1991, by replacing two catalytic incinerators, used to control hydrocarbon emissions from the Aircraft Purge Facility near Bldg 287, with a closed loop distillation unit. The Aircraft Purge Facility is a facility used to purge the fuel from aircraft fuel cells thus eliminating the danger of explosion during the repair of an aircraft fuel cell. This Air Quality Modified Approval Order authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order: 1. Hill Air Force Base shall install a 28,000 gallon purge oil reclamation unit, which shall operate in conjunction with the two existing 6,000 gallon units. The unit shall be located at area 15090 near Building 287. The purge oil unit shall be installed according to the information submitted in the notice of intent dated August 1, 1988, October 8, 1992, and additional information submitted December 3, 1992. 2. A copy of this Approval Order shall be posted on site and shall be available to the employees who operate ':he air emission producing equipment. All employees' who operate the air emission producing equipment shall receive**i:'l.st~~::'"::_·::-:'": ~.S**  -"::J**~-='** 

## ..:-**:':"-=s:J0n~ibilit.ies** ir-. oopr=7':i--**.-:-.-~.~. -~!:"':**  in

3. This Modified Approval Order shall replace Modified Approval**Orde~** SAQE-021- 91 dated January 15, 1992, and Variance DAQC-670-92 dated June 4, 1992. 4. The JP-4 and purge oil from all three purge oil units shall be processed by closed loop distillation unit that is operating under vacuum. The purge oil is stored and reused in the purge system. The JP-4 is separated by distillation and diverted to a portable 1,000 gallon tank where it is transported to a storage area. The JP-4 tank venting emissions are not controlled. 5. Visible emissions from the vent on the JP-4 portable tank shall not exceed 10% opacity. Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. 6. The following extraction limits for JP-4 shall not be exceeded without prior approval in accordance with R307-1-3.1, UACR:

4.2.4-594James Van Orman February 11, 1993 Page 2
A. 24,000 gallons per 12-month period Compliance with the annual limitations shall be determined on a rolling 12-month total. Based on the first day of each month a new 12-month total shall be calculated using the previous 12 months. Records of consumption/production shall be kept for all periods when the plant is in operation. Records of consumption/production shall be made available to the Executive Secretary or his representative upon request and shall include a period of two years ending with the date of the request. Production/Consumption shall be determined by a log of the JP-4 recovered in the portable tank. The log shall be kept in area 15090. The records shall be kept on a daily basis. 7. All installations and facilities authorized by this Approval Order shall be adequately and properly maintained. The owner/operator shall comply with R307-1-3.5 and 4.7, UACR. R307-1-3.5, UACR addresses emission inventory reporting requirements. R307-1-4.7, UACR addresses unavoidable breakdown reporting requirements which result in excess emissions. It specifies the reporting requirements where excess emissions result from the breakdown. The owner or operator shall take all reasonable measures to minimize emissions which may include curtailment of production. The owner/operator shall calculate/estimate the excess emissions whenever a breakdown occurs. The sum total of excess and normal emissions shall be reported to the Executive Secretary as directed for each calendar year. 8. The Executive Secretary shall be notified in writing upon start-up of the installation, as an initial compliance inspection is required. Any future mOdifications to the equipment approved by this order must also be approved in accordance with Section 3.1.1, UACR. This Approval Order in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including the Utah Conservation Regulations. Sincerely,

FBC:JTB:dn

cc: EPA Region VIII, Mike Owens Davis County Health Department



### 4.2.4-595

# AECc/Vt:D

. -..

.J./ 

### \ :!/ 

# DEC 181992y

# Air Quality

DEPARTMENTOFTIlEAIRFORCE HEADQUAR1ERSOGDENAIRLOGISTICS CEN1ER(AFMC) Iill..LAIR FORCE BASE, UTAH 84056
Mr Tim Blanchard 

# 17 DEC 

# 1992 Division of Air Quaiity 1950 W. North Temple POBox 144820 Salt Lake City, UT 84114-4820
Re: Distillation Units for the Aircraft Purge System
Reference your telecon 2 Dec. 92, we answer your questions as follows:
lP-4 distillate tank capacity is about 1,000 gallons. The tank is vented and there will be a small amount of hydrocarbon emissions. Based on our workload, we estimate distilling about 2,000 gallons of lP-4 per month.
Emission Factor: Use AP-42, 4th Edition, Eqn (l), 

### Page 4.4-5 L 

# = 12.46 x SPMff For lP-4 S, Saturation Factor, AP-42, Table 4.4-1, Assume splash loading, Dedicated normal service 

# = 1.45 P. True VaDor Pressure. AP-42 Table 4.3-2. Assume 60 deQ:ree F 

# = 1.3 PSIA M, Moiecular Weight, AP-42, Table 4.3-2 = 

### 80 Lb/Lb mole T,

..i.bsolute temperature, Assume average 460+60 = 

### 520 R L, Loading Loss 

# = 12.46x1.45x1.3x80/520 

# = 3.61 Use 4.0 Lb Loading Loss/1,OOO gallons Hydrocarbon Emissions: 4 Lb HC/1,000 gals x 2,000 gals/Mo x 12 Mo/Yr x Tonl2,OOO Lbs

= 

### 0.048 Ton/Yr These emissions are insignificant.
Please also note that we have specified " Factory Mutual Valves" ie dead ended valves with petroleum service gaskets, the best in the petroleum
4.2.4-596

### industry, to almost eliminate fugitive hydrocarbon emISSIOns. Therefore, fugitive emissions reported in our 8 Oct. 92 transmittal will be negligible.
We hope this answers your questions. If 

### there are any more questions, please feel free to 

### contact Jay Gupta at 777-0359. Sincerely

1 

# r .**J~** 

# R.**UC1NJ!)~** James R. Van Orman Director of Environmental Management

i ';,.,

/



### 4.2.4-597NO. 088 ! I I 

### tran'''''MIMmo 

### IfI"A

Faz t



### TO:!Div Air Quality (Attn: 

### Tim Blanchard)
Reference your telecon 

### 2 Dec 

### 92. we answer your questiona 

### as**foUo~s:** i 

### !**JP-~** 

### distillate tank capacity is about 1.000 

### gallons. The**~ank** 

### is**v~nted** 

### ad there will be a small amount of hydrocarbon emissions. 

### Based on'our workload. we estimate distilling about 

### 2.000 gallons of 

### jp-4 per month.
Emission Factor: Use: AP-42. 4th Edition. Eqn (l). 

### Page 4.4-5 

### L =i 

### 12.46 x 

### SPMrr ForiJP-4 ,.-. .. S.

## ~aturation Factor. AP-42 Table 4.4-1. as!iiume splash Joadinl. 

## 40ddcatecl nonttal service 

## = 1.45 

## I ' p. true Vapor Pressure. AP-42 Table 4.3-2. assume 60 d.gree F ::i 

### 1.3 

### PSIA M.

## ~olecular Weight. Ap-42 Table 4.3-2 =0 

### 80 LblLb

## m~e T. Absolute T. assume avg 

# =460+60 

# =520 R L. loading Loss 

# = 12.46x1.45x1.3x80/520 

# =3.61
I 

### Use 4.0 Lb Loading Loss/I.OOO gallons Hydrocarbons Emissions: '+ l"fJ OLll,VVV gal ;;.**~,\./VV 5~11**  j

....0 ;.. ! _ j·'Vi" ", .i. Uill

....**'<''oJ~** ......... 

# = Ol048 Ton/Yr I 

### These emissions are insignificant.
Please note that we have specified

.. Factory Mutual Valves

.. ie 'ead endod val'Jes with petroleum service gaskets. the best in petroleum**in~siry,** 

### to alrnbst eliminate fugitive emissions. Therefore, fugitive 

## iemission8 reported in our 8 

### Oct 92 Transmittal will be negligible.
Wo! 

### hope this answers your questions. If 

### there are any more 

## qUe.Btions, please feel to 

### call Jay 

### Gupta at 777-0359. 

# -,

4.2.4-598

# (JRECElVED '. 1 

### DEPARTMENTOFTHE AIR FORCE

### '\i,~,d) 

## CT0 9 1992 HEADQUARTERSOGDEN AIR LOGISTICSCENTER (AFMCl 

### v '. HILLAIR FORCE BASE, UTAH

# ~Ir 

# Quality
8 OCT 1992·

F.

### Burnell~o/aner, Executive Secretary Division of ir Quality 1950 W. No h Temple P.O.

### Bo~/'44820 Salt**L~** 

### City**UT.8~114-4820** 

### Re: 15 Jan 91 A.O. for Aircraft (BAQE-021-91); 4 Jun 92 Ltr, Variance for Aircraft Purge Purge System Near Bldg 287 Twelve Month Extension of System (DAQC-670-92) Dear Mr Cordner In Oct 90, a fire destroyed the c the pollution control equipment atalytic incinerators which on our JP-4 purge facility were near Bldg 287. On 31 Jan 91, the State granted us an 18 month variance for continued operation of the purge facility. On 4 Jun 92, a**tw~lve** 

### month extension of variance was granted. After the variance was granted, we began a project to install new air pollution control equipment. In lieu of catalytic incinerators, we propose to install distillation units operating under a vacuum. A schematic of distillation units is Attachment 1. Distillation units will separate and recycle the two product streams, namely, JP-4 and the purge oil. Since the distillation units will be closed loop, they will not be a source of air pollution and we feel a NOI is not required for these units. Fugitive emissions from piping valve flanges are negligible and estimated as follows: Number of Pipe Line Valves = 

### 23 Process Stream Category 

## = I Emission Factor, AP-42 Table 9.1-2 

## = 0.00056 lb/hr source 2,000 We request you modify our 15 Jan 91 Approval Order deleting any reference to catalytic incinerators and include distillation units in the same. If you have any questions, please feel free to contact Jay Gupta at 777-0359. Sincerely 

# JfuM.t.s R.

# JOJIA0~ JAMES R. VAN ORMAN 1 Atch Director of Environmental Management Distillation Units Schematic 

### 4.2.4-599!.'l. 

# !l

J:;

# i

# 1



# - j r >
( 

### 4.2.4-600 J 

### 5DEPARTMENT OF THE AIR FORCE HEAOQUARiERS OGDEN AIR LOGISTICS CENTER (AFLC) HIL.L AIR FORCE BASE. UTAH 84056



### SEP )**~9g3**



### Mr F. Burnell Cordner, Executive Secretary Utah Air Conservation Committee Bureau of Air Quality 288 North 1460 West PO Box 16690 Salt Lake City UT 

### 84116-0690
Re: Additional Information on Notice of Intent (NOI) to Construct New Aircraft Purge System Near Building 287
DearMr Cordner
In our NOI dated 1 Aug 88, we proposed using either an activated carbon adsorption or a refrigeration unit to control JP-4 emissions from the purge tanks. Subsequent evaluation reveals that activated carbon is not suitable for JP-4 vapors and a refrigeration unit is not cost-effective. As a result, we propose using two catalytic incineration units. Additional information on control devices and air emissions is provided as Atch 

### 1. Atch 2 is a descriptive brochure on catalytic incineration unit. If you have any questions, please feel free to contact Jay Gupta at 777-6742.



### . 

### - /**S~ncerely** 

## f /.

# /f~&Ljyl~**~~ATHAN** O. CURRIER 2 

### Atch Dep Chief 1. 

### Additional Info Environmental Mgt 

### Office 2. Brochure



### RECEIVED 

## /""\ Sf P

## 111988 ( j' AIR Ql1Al/1Y

# \~ I

4.2.4-601

### ADDITIONAL**INFO~~TION** 

### ON NOTICE OF INTENT (NOI) TO CONSTRUCT NEW AIRCRAFT PURGE SYSTEM NEAR BUILDING 287

1. Control Devices:

a. In our NOI dated 1 August 1988, we proposed activated carbon adsorption or a refrigeration heat transfer solvent recovery unit for controlling JP-4 emissions from the purge tanks. 

## we have determined that these control devices are not cost effective for the recovery of JP-4 vapors from the purge tanks. b. We are now proposlng to control these emissions by two catalytic incineration units. One 200 SCFX catalytic unit will be installed on two existing 6,OOo-gallon purge tanks, while a second unit will control emissions from the proposed 28,OOo-gallon tank. Descriptive brochure from the equipment manufacturer is attached. 2. Air Emissions: We estimate 95-98% destruction efficiency for the catalytic incineration units. Based on this, hydrocarbon emissions to the atmosphere will be reduced to 0.26 tons per year.



### 4.2.4-602

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### -1.**;~**



### -

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### 4.24-603



# -**.~**

# ORS Environmental Equipment Catalytic Scavenger® Vapor Abatement System

When Clean Air Matters
Most site remediation prOlects start off witn contaminated soi'l and grounawater. BUI they otten end up with a c::>ntamlnaled air stream from the very systems that are doing the cleanup! Now, ORS Environmental Equipment has combined proven catalytic conversion technology witn years of site remediation experience to creale the Catalytic Scavenger® system. This unique state of the orr system is specifically deslgneci to nandre the vapors emitted from air strippers ana sod vent systems during site cleanups. CostEffective And Efficient
The ORS Cataiytlc Scavenger system is highly cost effective be-

. couse of its unique deSign. AI the heartof the system is a durabie platlnum-coated catalytic element. This unit operates at temperatures which efficiently destroy organic contaminants. Speciol ceramiC i:1- sulation retains the heat, which is recovered dunng the process and recycled to pre-neat the inlet gases. Reusing this energy greatly reduces operating costs. Meets Environmental Standards
ContOr:1lnalea air streO:T1S that nove peen orocessea tr.rC'Ugh the CaTalytiC Scovenger syslem may be sa;elv 'eleased l:1tO tnc armospnere. ,'gn cieSlruc,cn rOles meet SICIe ona recieral VOC and air toxics emiSSions slanaarcis. Since the (olalytlc Scc>lenger system runs on convenient eiectriclty ana creOles no emlSSIOO1S or Its own. ,I ,S 001 extremeiy clean unit. Jnlike aCllvolec carpon wn,cn merelv Ircnsrers conta:T1lnants to an expensive meaium, :he CatalytiC Scavenger s'lstem destroys CO:1lcrT:motion on sile, ellmmallng c:-:oln-oi-eus:ody ana other Ilngerrng :IO::ldITy**,ss~es.** Safe Safety precautions nove been Suiir Into Ihe Cctalytlc Scavenger system 01 every ie'lei. Jigital outpur diso:ays orovlae cUlck, easy-toread reiere:1ces ror**sil·~** personnel. From Its exolosion,proof deSign to Its gas :T10illtonng, tem::leralure senSing, 0:10 automat,.: s'lul-off systems, the'CCloiY-IC SC'.:'1enger sys.- tem has been aeslgnej t::J prOVide complereiy safe operation Graph shows comparative costsofcarbon and catalytic conversi.on. In thisexample. theScavenger system saved theclient $30.000 over 3 manths. Carbonwas regenerated off-site. Above: Interior view of control module showing electrical circuitry.



### 4.2.4-604Reliable
ORS Environmental Equipment has been aesigning, manufacturing and installing innovative systems for site remediation and contaminant recovery since 1975. ORS systems have been fieldproven on thousands of projects worldwide. From the innovative Filter Scavenger® oil/water separator, to our ambient monitor· ing units, to our full·scale remediation systems, ORS equipment has operated reliably on virtually every kind of remediation project. This experience is built into every Catalytic Scavenger system and is -t ofwhat you can depend on**/~.** everyORS product.

...enefits

• On-site contaminantdestruction

• Nooff·site hauling or disposal

• No long-term liability

• Flexible design accommodates multipleapplications

• low operating costs When enviranmental regula' tionsrequirecleanemissions, put the Catalytic Scavenger systemtoworkforyou. 

# &I EI.ad,**-Con~** - - - Supply Contaminated I 

### + Temperature Vapor Influent Sensor

CleanVapor

Effluent Waste Heat Discharge

Above: Processflow At a service station onthe WestCoast. theORS Catalytic Scavenger" system was used foron site destruction of contaminatea vapors emitted from a Soli Vent System. The unit achieved a 99% destruction ratefor benzene, which met CaliforniaAir Pollution Control District requirements. Operating casts were less than 5300per month.
diagram showIng path afgas from remediatlan systemto discharge. Contaminated vaporsare preheated in the heat exchangerby hot exhaust released from the catalyst. Gaspasses through the heatertothe catalystwhere combustion takes place. Theclean vaporeffluent Is discharged afterbeing caoled in the heat TheCatalytic Scavenger" systom was used on siteto destroythe vapors from an underground fuel spillin Maryland.The unit wos installedto replace Q car· bonrank which costtheclient 51S.OOO injust three days. In five months, theCatolytlc Scavenger destroyed approximately 6000Ibs. of vaporphase contaminants, and savedthe Engineertak. Ing digital exchanger. clienthundreds ofthousands readoutof ofdollars in Influentair temperature operating costs. atthecatalyst through glass viewing port. ri",_

...";.': ;. :**.~** :



### 4.2.4-605

# ORS Environmental Equipment Cotalytic Scavenger® Features and Specifications

Features Applications:Can be used with AirStrippers, Soil Vent Systems, or othervapor streams. Portable: lightweight, skid mounted unit is easilytransported. Durable: Precious metal catalyst is designed for long life with proper maintenance. EH'cientOperation:Up to 70% heat recovery by heat ex· changer. Explosion proofDesign:Control system and heater meet NFPA standards for use in Class 1, Division 1, Group D hazardous environments.

.SensorRedundancy:System

features two LEL sensors wired in series. ControlMechanism: Allows in· terruption ofother site operations during alarm conditions. ManualSlastGate Dampers:Allow the processing ofhigher contamination levels produced by Soil Vent Systems. Manual Temperature Monitoring:Thermocouples and hand held thermometers provide additional monitoring capabilities. ManualReset:After an alarm condition or shutdown, system will not restart withoutoperator inter· vention. This feature prevents restarting before the couse ofthe shutdown has been investigated. Highand LowTemperature Shutoffs: Prevent overheating and release of untreated vapors. Continuous GasMonitoring: LEL sensors and controller shut Model Information 

# '/ #1282001 #1282002 20kw 35kw AirFlowRate 100-200·SCFM 200-500SCFM PowerRequirements·· 230V(l or3Ph.)or 230VI460V(3Ph.) 460V(3Ph.) Dimensions 8S"h x 85"1 x 42"w 62"hx 132"\ x62-w Weight -1300Ib. -2000Ib. OperatingTemp. Range 400o _900Fo 400°-900°F

.. 300SCFM IS ad'Hevaoie wIthSoeCiQl duplexunit.

... Up to 125 amp M1r"Vice dependIngon voltogeendphose.Consultfactory for weclficntqulremenl's.

down system ifflammable gas concentrations rise beyond adjustable limit5. Gas SensorFailureAlarm: Shuts system down and triggers audible/visible alarm with audible shut-off. AutomaticDampers: Divert explosion proofvapors away from catalyst during alarm conditions. Min'mal TemperatureDrift: System eledronics provide tight temperature control ofgas enter- Componentsof ing the catalyst. CatalyticScavengerunit Specifications clockwisefrom lowerleft: Catalyst: Platinum coated. heater,control module,heat Enclosure: 15 gauge sheet exchanger, aluminum. catalyst. Gas**EJ(po~ed** Components: 304 stainless steel. rnletPipe:4/1 female: PVC flange. OutletPipe: 6" 0.0. 5toinless steel discharge port. Insulation: 3/1 ceramic blanket. Patent: Pending. Partial Listof Destructible Compounds Aromatics: Benzene TOluene Xylenes Ethyl benzene Napnihaicilc Styrene ISObutyl

benzene Ketones: Melhyl etnvi

ketone \tl,eK: MClhyllSD:Jutyl**~etone** iM18K) Acetone Alcohols: Isopropanoi Methono: Bufano: Ethanol 2 methyl-1.

butanoi Esters: Ethyl acetate Propyl acelate Isobutylocclale Cyclohcxyl

acetate Alkenes: Propylene Ethylene Aldehydes: Formaldehloe Benzaldehycie Othergases: Acetylene Carbon

monoxlOS' Alkanes: Butone Heplanes Hexane,**P~ntanc$** Octane
•••and ethel' organic compounds

4Mill Street, Greenville, N H 03048 Fax: (603) 878-3866 Telex: 75-2858

# ~Q!!§ Formoreinformation orto placean order, pleasecall (603) 878-2500.Sales and servicefacilities are located tnrough-

# ·~EQUIPMENT

... 0 I YO' Co IOU'" D w
.. ' •• r t ( It H 0 l 0 C 1', INC outthe U.S., Canada, and overseas
. 

### 4.2.4-606DEPARTMENT OFTHE AIR FORCE HEADQUARTERS OGDEN AIR LOGISTICS CENTER (AFLC, HILLAIR FORCE BASE. UTAH 84056-5149 

### AUG 0 

### t 1988

Mr F. Burnell Cordner, Executive Secretary Utah Air Conservation Committee Bureau of Air Quality 

### 288 North 

### 1460 West 

### PO Box 

### 16690 Salt Lake City UI 

### 84116-0690 Re: Notice of Intent to Construct New Aircraft Purge System Near Bldg 

### 287

Dear Mr Cordner 'In compliance with Section 3.1 of the State Air Conservation Regulations, we submit the attached Notice of Intent to Construct. If this office can provide additional information, please reel free to contact Jay Gupta at 

### 777-6742. Sincerely

# ~~~ 1 

### Atch 

### THAYNE 

### H. JUDO, Col, USAF**~otice** 

### of Intent to Construct 

### ChlCf, 

### Envlronmelltal Mgt Office

RECaVi::D

# r\

AUG 

# 319BBV

AIR QUALITY ./ 'J



### 4.2.4-607

### NOTICE OF INTENT TO CONSTRUCT NEW AIRCRAFT PURGE & 

### RECOVERY SYSTE:.1 HILL AIR FORCE BASE, UTAH

1. PROJECT DESCRIPTION: Hill AFB presently operates two 6,000 gallon purge fluid recycling units. Approval orders for these units were granted on 19 Oct 77 and 11 Jan 83 respectively. These units are operating with Rotamist 650 oil mist collection device. Due to increased workload and larger aircraft programmed for depot maintenance at HAFB, a new purge system at area 15090 adjacent to building 287 will be built. The system includes a 28,000 gallon tank purge oil reclamation unit and will function in conjunction with the existing 12,000 gallon purge system. Aircraft is defueled and bucket drained in area 15090. Aircraft fuel tanks are then connected to the purge oil lines and are pumped full of purging oil. The oil is left in the aircraft for ten minutes and then is pumped out and back into the purge tank. The flash point of purge oil and JP-4 mixture in purge tank must be maintained above l20oF. This requirement is fulfilled by aerating the mixture and by maintaining the tank temperature between 100-120oF.

. 2. AIR EMISSIONS: Based on projected workload (FY92), total JP-4 defueled and estimated emissions from purging are as follows: Total JP-4 defueled 546,000 gals/yr
Assuming 1% retention, fuel extracted by purge fluid 5,460 gallons Upon aeration, assuming 70-75% JP-4 "bubbled off" JP-4 emissions to the atmosphere 4,040 gals/yr Assuming carbon adsorption/condenser efficiency 90% Net HC emissions 404 gals/yr 404 gals x 6.5 lbs x ton 1.3 ton VOC/yr yr gal 2,000 lbs 3. 

### AIR CLEANING DEVICES: Hydrocarbon emissions from purging operations will be 

### controlled through the use of either an activated carbon adsorption equipment or a refrigeration heat transfer solvent recovery equipment. We are currently evaluating these control devices.

4.2.4-608

### 4. EMISSION POINTS:
A 20" diameter duct will discharge approximately 1,000 standard cubic feet per minute, 10' above ground level. 

### 5. SAMPLE POINTS: No sampling points are provided 

### 6. OPERATING SCHEDULE: The proposed facility will normally be operated two eight-hour shifts per day, five days a week and 52 weeks per year.



### 076lA 

### 4.2.4-609DEPART\lEi\TOF HEALTH 

# \;ZI DIvlSIO\" OF E\"\lRON\lE:\T.-\L HEALTH "\orman d Han2err("r ;"\t'rn"f 288 Non- :.:6C 'toes'
;:I 0 Bo;l,**16c~O** Sail LaKe C '. ,-,:2"' :.:'

,.-,., ,,,. S011 535·6'CS 

### BAQE-653-88 January 13, 1989 Thayne Judd, Colonel, USAF Department of the Air Force HQ Ogden Air Logistics**Cente~** 

### (AFLC) HAFB, Utah 84056-5149 Dear Colonel Judd: Re: Approval Order for Aircraft Purge System Near Building 287 Davis County, CDS Al The above-referenced project has been evaluated and found to be consistent with the requirements of the Utah Air Conservation Regulations (UACR) and the Utah Air Conservation Act. A 30-day public comment period was held and all comments received were evaluated. The conditions of this approval order reflect any**~hanges** 

### to the proposed conditions which resulted from the evaluation of the comments received. This air quality approval order authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order: 1. Hill Air Force Base shall install the new 28,000 gallon purge oil reclamation unit, which will operate in conjunction with the two existing 6000 gallon units. The new unit shall be located at area 15090 near Building 287. The purge oil unit shall be installed according to the information submitted in the notice of intent dated August I, 1988. 2. Emissions from all three purge oil units shall be controlled by catalytic incinerators. One incinerator shall be used on the 28,000 gallon unit, and one incinerator shall be used on the two existing 6000 gallon units. Both incinerators shall be an ORS Environmental Equipment model 1282001 or equivalent. Equivalency shall·be determined by the Executive Secretary. The incinerator shall operate whenever the corresponding purge unit is operating. 3. Either one or both of the catalytic incinerators shall be stack tested if directed by the Executive Secretary. The emission rate/concentration shall not exceed any of the following values: A. 19.18 LB/1000 gallons burned for particulate B. 11.89 LB!1000 gallons burned forPM10 

### The test method used shall be 40 CPR 60, Appendix A, Method 5. A pretest conference shall be held if 

### directed by the Executive Secretary. It shall be held at least 30 days prior to the test between the owner/operator, the tester, and the Executive Secretary. The exhaust stacks need not be designed to accommodate testing. However, if the Executive Secretary determines a stack test is necessary, whatever modifications needed to meet the requirements of 40 CPR 60, Appendix A, Method 5 and the requirements of , Occupational Safety and Health Administration (OSHA) for providing approvable access to the test site shall be made.



### 4.2.4-610

### Thavne Judd F4265089M0003 Page 2

4. Visible emissions from either incinerator shall not exceed 10%**opaci~y. Opaci~y** **observa~ions** 

### of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A,**Me~hod** 9. 

### S. Opacity**observa~ions** 

### or**~ntermittent** 

### sources shall use procedures similar to Method 9, but**~he** 

### reauirement for observations to be made**a~** 

### IS-second**in~ervals** 

### over a**6~minute** 

### period shall**no~** 

### apply. The averaging time shall be**~he** 

### actual**~ime in~erval**  

### over which visible emissions are observed

..**~y** 

### time interval with no visible emissions shall not be included. 6. The volume of purge fluid which is replenished to the storage tanks shall be measured every**~onth.** 

### This volume is assumed to**b~** 

### the volume of JP-4 which has been**sen~** 

### to the catalytic**incinera~ors.** 

### The volume shall be recorded in an operations log. The log shall be kept in area 15090 and shall be made available to the Executive**Secre~ary** 

### upon request. 7. The**sulf~r** 

### content of anv JP-4 burned shall not exceed 0.85 pounds of sulfur per million 

## Biu**hea~** 

### input as detennined by ASTM Method D-4239-83. The sulfur :ontent shall be tested if directed by the Executive Secretary. 8. This approval order shall replace the approval orders dated October 19, 1977 and January 11. 1983. 9. All installations and facilities authorized by this approval order shall be adequately and properly maintained. 10. The Executive Secretarv shall be notified in writing upon start-up of the installation. as'an initial compliance inspection is required. Any future**modifica~ions ~o**  

### the equipment approved by this order must also be approved in accordance with Section 3.1.1. UACR. This approval order in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including the Utah Air Conservation Regulations. The fee for issuing this approval order is $411.04. The amount is payable to the Bureau of Air Quality, sent to the Executive Secretary, Utah Air Conservation Committee. 288 North 1460 West, P.O. Box 16690, Salt Lake City, Utah 84116-0690 and is due within 30 days after receipt of this approval order. Sincerely,

) 

## =

## ~d)v.:c.1/~"kl':'~!l F.

### ~urnell**Co~ner** Executive Secretary Utah Air Conservation Committee FBC/MK/cc

cc: 

### EPA Region 

### VIII, John Dale Davis**Coun~y Heal~h**  

### Department



### 4.2.4-611

# -------------- Thayne Judd F4265089M0003 Page 3

UTAH BUREAU OF AIR qUALITY APPROVAL ORDER FEE

Department of the Air Force Aircraft Purge System Near Building 287 Filing Fee
Review Engineer

- total hours 13


### Modeler

- total hours Computer time

- total hours
Notice To Paper

_
Travel

- total miles

Total 

# s 411.04

Please send payment to: Utah Bureau of 

### Air Quality P.O. Box 16690 Salt Lake City, Utah 84116-0690 (801) 538-6108



### 4.2.4-612

### Memorandum To: Montie Keller Through: Dave KO'Dta From: Don

# ROb~nson 

# M
Subject: Response To Comments from HAFB on Aircraft Purge System near Building 287; NOI Dated August 1, 1988 Date: December 19, 1988 HAFB submitted a notice of intent dated August 1, 1988 to install an additional aircraft purge system at area 15090 adjacent to Building 287. The intent to approve letter is dated November 1, 1988. The comment period began on November 15, 1988. HAFB submitted comments on December 13, 1988. Following are the affected conditions, the comments, and our suggested responses: Condition #6 The total amount of JP-4 to be defueled from aircraft shall not exceed 546,000 gallons per 12 month period without prior approval in accordance with Section 3.1, UACR. Compliance with the limitation shall be determined on a rolling monthly total. On the first day of each month a new 12-month total shall be calculated using the previous 12 months. Records of defueling shall be kept for all periods when the plant is in operation. Records of defueling shall be made available to the Executive Secretary upon request, and shall include a period of two years ending with the date of the request. The total amount of JP-4 to be defueled from aircraft shall be determined by the use of flow meters on the purge lines. An 

### operations log shall be kept in which shall be recorded daily the volume of JP-4 which is defueled. The log shall be kept in area 15090 and shall be made available to the Executive Secretary upon request. Comment on Condition #6 HAFB has submitted 

### six separate comments on condition #6. I will summarize them here. For additional details consult their letter dated December 13, 1988. HAFB has a defueling process and a purging process. The defueling process is as follows: A. An 

### aircraft is brought into the purging area. B. A fuel truck pumps as much fuel as possible from the aircraft into the fuel truck for later use. C. Leftover fuel is bottom drained to fuel bowsers. The purging operation 

### is as follows: A. The only fuel left in the aircraft is residue that must be removed to avoid any flanunability problems while the aircraft 

### is in the repair hangar. This is done by running purge fluid through the fuel system. 

### 4.2.4-613

### B. Purge fluid is 

### stored in tanks that can be attached to the aircraft. C. The purge fluid is 

### pumped into the fuel system and mixes with the lP-4 residue. The fuel purge fluid mixture is 

### pumped back to the purge fluid tank. D. The fuel purge fluid mixture is 

### continually heated and aerated to drive off the residual fuel which the purge fluid has picked up. E. The fuel being driven off will be controlled by the catalytic incinerator units. HAFB recommends that this condition be changed because the defueling and purging processes are independent. Regulating the volume of fuel reclaimed will not control VOC emissions from the purging operation. Since submitting the NOI, HAFB has concluded that this condition is 

### not a sound method of determining VOC emissions. There are simply too many variables with this method. For example, there are too many different configurations in the various aircraft serviced. Some aircraft have fuel foam and some do not. In looking at more reliable methods we concluded that using replenishment figures for the purge oil would be much more reliable. The best method of measuring 

## voe emissions is to record the amount of purge fluid replenished in the storage tanks annually. The purge oil lost annually is 

### attributed to it 

### being retained in the aircraft after the purging operation. The purge oil/1P-4 mixture is 

### returned to the storage tanks where the lP-4 is is 

### evaporated and incinerated. New purge oil is pumped into the storage tanks to retain the same level, hence replacing the volume of JP-4 evaporated. This intent would be served by the following conditions: A. Use of catalytic incineration of JP-4 vapors B. Accurate recording of purge oil replenishment figures Response The reasoning of HAFB seems to be logical, considering the fact that the defueling and purging operations are separate. The oBAQ realizes that the actual process has many variables in it. 

### Condition 

### 16 will be rewritten to read as follows: "The volume of purge fluid which is 

### replenished to the storage tanks shall be measured every month. This volume is 

### assumed to be the volume of lP4 which has been sent to the catalytic incinerators. The volume shall be recorded in an operations log. The log shall be kept in area 15090 and shall be made available to the Executive Secretary upon request."

2 

### 4.2.4-614DEPARTMENT OF THE AIR FORCE HEAOQUARiEP.S OGOEN AIR LOGISTICS CENTER (AFLC) HILL AIR FORCE BASE. UTAH 84056

1 -



### Mr F. 

### Burnell Cordner, Executive Secretary Utah Air Conservation Committee Bureau of Air Quality 288 North 1460 West PO Box 16690 Salt Lake City UT 84116-0690
Re: Public Comments on Notice of Intent to Approve Aircraft Purge System Near Bldg 287 for HAFB

Dear Mr Cordner
In reference to the above Intent to Approve Notice dated 1 Nov 88, we submit our comments as an attachment. If you have any questions, please feel free to contact Jay Gupta at 777-6742.
S

### inc;rely. .,/
.' 

## / /

.... ;/' ,!

.

# .r::**I/~:Mc~/~~** rJATHAN 

## o. CURRIER 1 Atch Director Comments Env Mgt Directorate

/\

I ) 

# OEC1.1**i~,_';** 

## '\JV" 

# f AIR QUALITY Ii



### 4.2.4-615COMMENTS ON INTENT**~C** APPROVE FOR PURGE FACILITY
1.**Condlt:o~** 6 indlcates we cld not adequa-cely explaln the difference between the defuel:'ng process and the pu:,glng operatlon. The detailed process we use to defuel and purge an aircraft are as follows:

a.**~he** cefueling process: (1) An aircraft is brought into the purging area. (2) A fuel truck pumps as much fuel as possible from the aircraft into the fuel truck for later reuse. (])**~eftover** fuel is bottom-drained to fuel bowsers.
b. The purging operation: (1) The only fuel left ln the airc:'aft lS resldue that must be removed to avoid any flammability problems while the**al~craft** :s ln the repair hangar. This is done by running purge flu1d through the fuel system. (2) Purge fluid is stored in tanks that can be attached to the au'craft. (]) The purge fluid is pumped into the fuel system and mixes with the JP-4 residue, the fuel-purge fluid m1xture is pumped back to the purge fluid tank. (4 ) The fuel-purge fluid mixture 1S continually heated and aerated to drive off the residual fuel the purge fluid has picked up. (5) The fuel being drlven off will be controlled by the catalytic incinerator units.
2. Recommend condition six in the proposed approval order be changed because defueling and purging processes are independent. Regulating the volume of fuel reclaimed during the defueling process will not control hydrocarbon emissions into the air as a result of the purging operation and may well affect the Air Force m1ssion. The submitted Notice of Intent included a linkage between the two processes only for the purpose of estimating air emissions. These figures vary annually and are by no means a maximum.
3. Since submitting the Notice of Intent, we have concluded that this is not a sound method of predicting or measuring emissions. There are simply too many variables with this method. For example. there are too many different configurations in the



### 4.2.4-616variOUS aircraft we serVice and some**al~c~aft** have fuel foam**a~~** some do not. Furthermore. arbitrarily limiting the**quant:~y** 

## 0: fuel may have**di~ec~** :mpacc on**~he milita~y**  operations**a~ ~ill**  AFB. In looking**a~** more reliable methods of estimating. we concluded that using**~eplenishment** figures for the purge 011 would be much more reliable.
4. The best method of measuring hydrocarbon emissions in**t~e** air lS to**reco~d** the**a~ount** of**~u~ge** :luid replenished in the**sto~agc** tanks annually. The purge oil 10sL annually is attributed to it being retained in the aircraft after the purging operation. The purge 011/JP-4 mixture :s returned to the storage tanks where**~he** JP-4 is evaporated and inclnerated into carbon dioxide and water vapors. New purge oil is pumped**in~o** the storage tanks to**re~a:n** the same level, hence replacing the volume of JP-4 evaporated.
5. It would be**prema~ure** to require or limit the quantity of JP-4 fuel defueled. Such a reqUirement could result :n disastrous effects upon the Air**~orce** mlSSion. The intent of the Bureau should be that we**cor.~rol** actual emissions to**~he** maXlmum practical extent possible.
6. This intent would be served by the following conditlons:

a. Use of catalytic inClneration of JP-4 vapors. b. Accurate recording of purge-oil replenishment figures.



### 4.2.4-617DEPART\:E):T 

### 'Jf HEALTH 

### DI\1SIO\' OF E\TIRO:\MEi\T.-\L HEALT:-f

',1':'; '\ .,: " \! f'l; 

### BAQE-629-88

November 2, 1988

Newspaper Agency Salt Lake Tribune Legal Advertising Department 157 Regent Street Salt Lake City, Utah 84111
Gentlemen: This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and Deseret News on Tuesday, November 15, 1988. Please mail the invoice and affidavit of publication to the Utah State Department -., of Health, Division of Environmental Health, Bureau of Air Quality, P.O. Box 16690, Salt Lake City, Utah 84116-0690. Sincerely, ._ 

# . y**-~/_-** 

# t-/Ci/z-P)/;1:2-**~'F/CCL** David Kopta, Manager Engineering Unit Bureau of Air Quality Enclosure DK/cc

-',",



### 4.2.4-618

### NOTICE The following not.ices of int.ent to const.ruct. submitted in accordance with Section 3.1. Ut.ah Air Conservat.ion Regulat.ions. iave been**~eceived** 

### for considerat.ion by the Execut.ive Secret.ary, Utah Air Conservation Committee: 1. Tooele A=my Depot. Four Air Stripping**~owers.** 

### Tooele County 2. Overlook Gold Mining, Surface Mining Cperat.ion. uintah County 3. Tooele Army Depot. Spray Booth in Building Sll. Tooele County 4. The Pillsbury Company, Gas Fired Boiler, Weber County 5. Hill Air Force Base, Paint Spray Booth 

### &Oil/Water Separat.or. Weber County. 6. Nucor Steel.**I~crease** 

### Zinc Oxy-Sulfate Plant.. Box**~lder** 

### County 7. Hercules Aerospace Company, Exhaust Syst.ems for**~.azzk** 

### Flexible Machining Cent.er. G 

### &L Machining Center, and Niles Lathe Machining Center; Clearfield Plant. Davis County 8. James M. Lekas Mineral Explorat.ion. Gilsonite Mine, Uintah County 9. Hercules Aerospace Company, Flexseal Boiler Syst.em at. Clearfield Plant, Davis Count.y 10. 

### Department of the Army. Two Bead Blast Booths in Building 271, 

### Davis County 11. Depart.ment of the Air Force, Aircraft Purge System Near Building 287, 

### Davis County The engineering evaluations and air quality impact analyses have been completed· and no adverse air quality impact.s are expected. No Prevention of Signi:icant. Deterioration (PSD) increment will be consumed by these proposals. It is the intent to the Executive Secretary to approve the const=uction projects. The construction proposals and estimates of the effect on local air quality are available for public inspection and comment. at the Bureau of Air Quality, Utah State Department of Health. 288 

### North 1460 

### West, Salt Lake City. Utah 84116- 0690. 

### Written comments received by the Bureau. 288 

### North 1460 

### West, P.O. Box 16690, 

### Salt Lake City, Utah 84116-0690. 

### on or before Thursday. December 15, 1988 

### will be considered in making the final decision on the approval or disapproval of the proposed construction.


### 4.2.4-619

### If anyone so requests within 15 days of publication of notice, a hearing will be held in the area of the proposed construction. installation. modification. relocation. or establishment. Date of Notice: November 15. 1988



### 4.2.4-620

### UTAH BUREAU OF AIR QUALITY NEW'

### 'MODIFIED SOURCE PLAN REVIEW Thayne Judd, Colonel, USAF Department of the Air Force HQ Ogden Air Logistics Center (AFLC) HAFB, Utah 84056-5149 Re: Aircraft Purge System Near Building 287

i 

### Davis County, CDS Al DATE: October 7, 1988 NOTICE OF INTENT DATED: August 1, 1988 PLANT CONTACT: Jay Gupta PHONE NUMBER: 

### (801) 777-6742 PLANT LOCATION: Hill Air Force Base Filing Fee $ 

### 100.00
Review Engineer


## - total hours 13 $22.08/hr ) 

### = $ 

### 287.04
Modeler

- total hours ( 

### $18.07/hr ) 

### = $ 

### Computer time

- total hours $


### Notice To Paper $ 

### 24.00
Travel



## - total miles ( 

### $ 0.23/mile ) $



### Total $ 

### 411.04 Approved by Engineering Unit Manager 

### DI( jO//2 

### Iff" 

### Approved by Technical Evaluation Section Manager

__

## (O.~**(o(~~{~~**

4.2.4-6212



### I. DESCRIPTION OF PROPOSAL 

### Hill Air 

### Force Base has filed a notice of intent dated August 1, 1988 

### in which they are proposing to install an additional aircraft purge system at area 15090 

### adjacent to building 287.

. HAFB presently operates two 6000 

### gallon purge fluid recycling units. These units are operating with Rotamist 650 

### oil mist collection devices. When aircraft are to receive certain repairs, they must be completely defueled. The fuel is 

### first drained from the aircraft, and then a purging oil is 

### pumped through the craft's fuel system to remove the remaining estimated 1% 

### of the JP-4 

### fuel. Air is then blown through the purge oil to remove the JP-4, 

### and the purge oil is recycled back to the fuel purge unit. For safety purposes, the flash point must be kept below 120°F. 

### Due to increased workload and larger aircraft programmed for depot maintenance. the new purge system is needed. The system includes a 28.000 

### gallon tank purge oil reclamation unit which will function in conjunction with the existing 12,000 

### gallon system. Aircraft fuel tanks are defueled and bucket drained in area 15090. 

### The tanks are then connected to the purge oil lines and are pumped full of purging oil. The oil is left in the aircraft for 10 

### minutes and is then pumped out and back into the purge tank. The flash point requirement is fulfilled by aerating the mixture and by maintaining the tank temperature between 100-120oF. 

### The total amount of JP-4 

### to be defueled is projected to reach 546.000 

### gallons per year. An 

### estimated II 

### of the fuel is picked up by the purge system. HAFB is proposing to pass them through two catalytic incineration units. One unit will handle the two existing 6000 

### gallon purge units, and the other unit will handle the new 28,000 

### gallon purge unit. Installation will begin as soon as approval is granted. II. EMISSION SUMMARY The emissions from the JP-4 

### being bubbled off and from the incineration units will be as follows: JP-4 

### VOC 0.66 

### tons/yr Incineration Particulate 0.04 

### tons/yr PM10 0.02 

### tons/yr SOz 0.00 

### tons/yr NO 0.11 

### tons/yr 

## cox 0.01 

### tons/yr VOC 0.00 

### tons/yr Methane 0.00 

### tons/yr These emissions represent a net emission increase. III. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS The proposed new purge unit was to have either a carbon adsorption unit or a**~.** 

### refrigeration unit as a control device for VOC emissions. The refrigeration unit 

### would have recovered JP-4 

### from all three purge units. The cost of the



### 4.2.4-6223 

### refrigeration unit was considered to be too high. The vendors for the carbon adsorption unit claimed that some of the polarized components in JP-4 would become so attached to**th~** 

### carbon bed that tb:e beds w<;,uld not last very long. This would make the operatJ.D.g cost of the UIllt too hJ.gh. Both control systems are rated at a capture efficiency of 90%. The vapor stream from the purge oil recycling**~t** 

### will be**suitab~e** 

### for**c:a~aly~ic** 

### incineration. The proposed incinerators (two) 

### W111 have destructJ.on effJ.cJ.enc:-es of 95-99%. BACT for the incinerators has been determined to be the follOW1ng limitations: Particulate 19.18 LB/1000 gallons burned PM10 

### 11.892 S02 

### 0.27 NOx 

### 55.0 CO 5.0 VOC 1.13 Methane 0.475 Opacity 10.0 % The inclusion of the catalytic incinerator for the existing units will result in a decrease in VOC emissions. However. the combustion units will produce other emissions. The low temperatures of the units will result in a lowered emission rate of NOx• 

### The proposed units are identical. The units will be ORS Environmental Equipment model #1282001 incinerators. The catalyst is a platinum-coated element. The unit operates at temperatures which efficiently destroy organic contaminants. The unit has ceramic insulation which will reduce operating costs. The exhaust flow rate is at most 200 scfm. The operating temperature range is 400-900o

### P. A partial list of destructible compounds includes benzene and toluene. It isrecommended that the two catalytic incinerators be approved as BACT. IV. APPLICABLE UTAH AIR CONSERVATION REGULATIONS (UACR) This notice of intent is for a modification to an existing major source. It is not a new major source or a major modification. The following federal and state regulations have been examined to determine their applicability to this notice of intent: 1. Section 3.1.1, UACR

- Notice of intent required for a modified source. This regulation applies. 2. Section 3.1.8, UACR Application of best available control technology (BACT) required at all emission points. This regulation applies. 3. Section 3.1.9, UACR

- Rules for relocation of temporary sources. This source is a permanent source. Therefore, this regulation does not apply. 4. Section 3.2, UACR

- Particulate emission limitations for existing sources which are located in a nonattainment area. HAFB is listed in this regulation.· The existing boilers are limited to 20% opacity. However, these new emission points are not listed. Therefore. this regulation does not apply to this notice of intent. 5. Section 3.3.2, UACR

- Review requirements for new major sources or major modifications which are located in a nonattainment area or


### 4.2.4-6234 whichimpact a nonattainment area. This notice of intent does not represent a new major source or a major modification. Therefore, this regulation does not apply. 6. Section 3.5, UACR

- Emission inventory reporting requirements. This regulation requires any source which emits 25 tons or more per year of any pollutant to submit an emission inventory to the Bureau of Air Quality every year. HAFB must submit an inventory every year, and this new emission point must be included in that inventory. 7. Section 3.6.5 (b), UACR

- Prevention of significant deterioration (PSD) review requirements for new major sources or major modifications. This notice of intent does not represent a new major source or a major modification under PSD rules. Therefore, this regulation does not apply. 8. Section 3.8, UACR

- Stack height rule. This regulation limits the creditable height of stacks to that height determined to be good engineering practice. The formulas used to determine good engineering practice are found in 40 CFR 51.1. A deminimus height of 65 meters (213.2 feet) is allowed. HAFB has no stacks which exceed 65 meters in height. It is in compliance with this regulation. 9. Section 3.11, UACR

- Visibility screening analysis requirements. This regulation requires all newmajor sources or major modifications to undergo a visibility screening analysis to determine visibility impact on any mandatory Class I area. This notice of intent does not represent a new major source or a major modification under UACR rules. Therefore, this regulation does not apply. 10. Section 4.1.2, UACR

- 20% opacity limitation at all emission points unless a more stringent limitation is required by New Source Performance Standards (NSPS) or BACT or National Emission Standards for Hazardous Air Pollutants (NESBAPS). In this case, BACT has been determined to be a 10% opacity limitation. 11. Section 4.1.9, UACR

- EPA Method 9 to be used for visible emission observations. This regulation applies. 12. Section 4.2.1, UACR

- Sulfur content limitations in oil and coal used for combustion. This new emission point (the catalytic incinerators) burns JP-4. The limitation is 0.85 LB of sulfur per 106 BTU heat input. 13. Section 4.7, UACR

- Unavoidable breakdown reporting requirements. This regulation applies. 14. Section 4.9, UACR

- Review requirements for volatile organic compound (VaC) sources located in a nonattainment area for ozone. This process (catalytic incineration) is not covered in this regulation. 15. Section 5, UACR

- Emergency episode requirements. This regulation applies. 16. New Source Performance Standards (NSPS)

- There is no NSPS for this industrial process. 17. National Emission Standards for Hazardous Air Pollutants (NESBAPS)\- There is no NESBAPS for this industrial process. 18. National Ambient Air Quality Standards (NAAQS)

- This source is



### 4.2.4-6245 located in Davis County which is a nonattainment area for ozone. The Bureau of Air Quality guidelines do not call for this new emission point to be modeled for any pollutant. The bureau has found through experience that, because of the conservative predictions made by modeling, a source or emission point of this small size will not cause a new violation of the NAAQS.


## v. RECOMMENDED APPROVAL ORDER CONDITIONS 1. Hill Air Force Base shall install the new 28.000 gallon purge oil reclamation unit, which will operate in conjunction with the two existing 6000 gallon units. The new unit shall be located at area 15090 near Building 287. The purge oil unit shall be installed according to the information submitted in the notice of intent dated August 1. 1988. 2. Emissions from all three purge oil units shall be controlled by catalytic incinerators. One incinerator shall be used on the 28,000 gallon unit, and one incinerator shall be used on the two existing 6000 gallon units. Both incinerators shall be an ORS Environmental Equipment model 1282001 or equivalent. Equivalency shall be determined by the Executive Secretary. The incinerator shall operate whenever the corresponding purge unit is operating. 3. Either one or both of the catalytic incinerators shall be stack tested if directed by the Executive Secretary. The emission rate/concentration shall not exceed any of the following values: A. 19.18 LB/I000 gallons burned for particulate B. 11.89 LB/I000 gallons burned for PM10 The test method used shall be 40 CPR 60, Appendix A, Method 5. A pretest conference shall be held if directed by the Executive Secretary. It shall be held at least 30 days prior to the test between the owner/operator, the tester. and the Executive Secretary. The exhaust stacks need not be designed to accommodate testing. However, if the Executive Secretary determines a stack test is necessary, whatever modifications needed to meet the requirements of 40 CPR 60, Appendix A, Method 5 and the requirements of Occupational Safety and Health Administration (OSHA) for providing. approvable access to the test site shall be made. 4. Visible emissions from either incinerator shall not exceed 10% opacity. Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CPR 60, Appendix A. Method 9. 5. Opacity observations of intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at IS-second intervals over a 6-minute period shall not apply. The averaging time shall be the actual time interval over which visible emissions are observed. Any time interval with no visible emissions shall not be included. 6. The total amount of JP-4 to be defueled from aircraft shall not exceed 546,000 gallons per 12 month period without prior approval in accordance with Section 3.1, UACR. Compliance with the limitation shall be determined on a rolling monthly total. On the first day of each month a new 12-month total shall be calculated using the previous 12 months. Records of defueling shall be kept for all periods when the plant is in operation. Records of defueling shall be made available to the Executive Secretary upon request, and shall


### 4.2.4-6256 include a period of two years ending with the date of the request. The total amount of JP-4 to be defueled from aircraft shall be determined by the use of flow meters on the purge lines. An operations log shall be kept in which shall be recorded daily the volume of JP-4 which is defueled. The log shall be kept in area 15090 and shall be made available to the Executive Secretary upon request. 7. The sulfur content of any JP-4 burned shall not exceed 0.85 pounds of sulfur per million BTU heat input as determined by ASTM Method D-4Z39-83. The sulfur content shall be tested if directed by the Executive Secretary. 8. This approval order shall replace the approval orders dated October 19, 1977 and January 11. 1983. 9. All installations and facilities authorized by this**a~proval** order shall be adequately and properly maintained. 10. The Executive Secretary shall be notified in writing upon start-up of the installation, as an initial compliance inspection is required. Any future modifications to the equipment approved by this order must also be approved in accordance with Section 3.1.1, UACR. This approval order in no way releases the owner or operator from any liability for compliance with all other applicable federal, state. and local regulations including the Utah Air Conservation Regulations. DER/sh HAFPURG



### 4.2.4-626**CONTROLLEr~** 

### ANNUAL EM!SSION**~~TE ~ST!M~TE** **FOR~ ~RCE:**  

### CATALYTIC INCINERATOR VENT, BLDG. 287**FIL~:** HAFB::S7
COMP-ANY 

### ·NAME: HILL HIF.:FOF:CE E:HSE 

### LOCATION: DAVIS COUNTY DATE: 15-SEP-19SS TOTAL ANNUAL 

### EMISSIONS ESTIMATE IN TONS/YR =

--T·SP---.-,-. & •••••••**~-,** " " • " •••••• " , io •• ;.
...... " io '-f" f"l ,,-• •--•• • " 0" 03'7'**TOi~/YF F"M-l(~**  .,. ,:1.1:·24 TON/YF: tt 

### sox ,. t •• io**~ ~ ~ ~ ~**  ..**~ ~** ..**~ ~** • ,. • • • ., • • • (:. CI(iC'S TON/Y**~' -i~OX**  -, to -, -, • , , ,., , , ,-tot , , , , f " to t to •• -, • ,,- ••• , •••• , 0.1·1 

### TOrun: CO " ••• ,. ••.••••• " •••• t •• ••**~~~~ ~.~**  ••••••**~.io** •••• (j

..**01·~** 

### TON/YF:

, .. VDC 

### non METHANE •••••••••••.••••••••••••••••••••••• 'J.

### Qe· 

### TON

.."YF:

e ., • ., "., ,. .. .. • • ..**·_·~-!.LOC·-ME-THANE** ,.. ,-"., , 0.0010 

### TON,' YF: 

### SOURCES INCLUDED:


### vac MATERIAL BALANCE OIL 

### COMBUSTION EMISSIONS

4.2.4-627**:J~!T~Q~LEIi** 

### ANNUAL EMISSION**R~TE ~ST!M~TE**  'JF:CE; :JOC 

### MATEF:IAL BALANCE**(OMPA~Y** 

### NAME: HILL AIR FORCE BASE**LGCATIJ~;** 

### DAVIS COUNTY ';:'MTI t: :"'1, •• , _ .....



### ANNUAL EMISSIONS 

### ESTIMATE IN TONS/YR 7

..'C:: non- METH <I •••• " , , , , , • • , •• , • '.'

. .:·c TONS/YF:

1',;;YERIAL--BALANCE- CALCULAT-1ON

### c· JP-4 

### BUBBLED OFF: 

### NOI INFO .•....••................•.. 

## i:**H-4-!Nrd:NEF:-A~TD;-B':iCT** ESTIMATE .......•..•.....•• · 

### 0QC EXAUSTED TO THE**AT~OS?~ERE:** 

### .'

. 'jOC EMESIDNS 

### EST.: (GALlYP)'i..B/G';l.'/::"'JGiJ 

### LBiTON) ..•• JP-4 DENSITY .•..••...•..............•..••...•• 4,040 GAL/YF: 95- ,.

'.' ••:> TD**r~**

### /'r

### r:

.:·.5 LB/GAL



### 4.2.4-628**CQNTROLL~D** 

### ANNUAL EMISSION RATE**E5T!~ATE '!~:CE:**  

### OIL COMF::USTION EMISSIONS FI LE:**~~** F'1 • 3C**F~** 

### COMPANY NAME: HILL AIR FORCE BASE**~QCArION:** 

### DAVIS COUNTY

ANNUAL EMISSIONS ESTIMATE IN TONS;YR 

## = (EMISSION FACTOR)(FUEL OIL CONSUMPTION)(ITON/2000LBS) -T

SF'·

.. "

.. '!'
.. 0.04 

### TONS;'Yf: " t**~. ~11**  '::+..

.. .. .. .. .. .. .. .. •
.. .. .. .. .. .. or .. , ; .. , .. •
.. .. " f

.. ., .. .. .. .. .. •
.. .. .. , .. () •G:: 

### TONS/':'**~:** t

.. .. .. • •**SC!>~** , - t

.. 

### 0.00 TONS/YF: NO;.;: 'l' "

.. "

- .. t , y "

.. 

## o.11**TONS':';'~:** CO

.. I

.. t '!' + + t ( t I t

.. 

## o.0 1 TONS/ YF: \.10C rlCI

## r,-METH

.. ; t '!'

.. t ;. t j t .,. (0.00 

### TONS/YF:

.. t MET**HAf~E** t "" O.**O(J-TONS:'l~:** f'

..



### AP-42 

### FOURTH EDITION SEPT. 1985 

### VOLUME 1 

### SECTION ! 

### EXTERNAL COMBUETION SOURCES 1.3 

### FUEL OIL 

### COMCUSTION**rc<PL~** 1.3-: ::-/.!El. :=IIL COMBUSTICtt;**CQM~E~C!~L 3Q!L~R**  

### \0.5 MMBTU;HR 

### fa :0**~MBTU/HR)** 

### USING RE3IDUAL OIL

h 

### CONTROL FROM BACT**DETERMIN~T!aN** 

### .....•.......•.. ',! • 'J !. F'Ml(; 

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.. 3- 5) t t

.. .. 62

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## sox=**(1~4)(%S** 

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_ -- L 7.0**;~** .

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..

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### BOILER 

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# .-

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### 4.2.4-629

# ..... ;'-.

# .'- _.-.-

# ~."":"":",.**DEPART~ENT** 

### OF HEALTH**BAQE~065-91** 

### DIVISIONOFENVTRONME!\T'fAL HEALTH
Bureauor All**O~alliv** Norman H. Bangerter i950 West**Nor;~** T efT'.Dle Goyernor POBox 16690 Suzanne Danaoy, M.D

..**~.P.H.** ExecutlyeDtrector Salt Lake Citv. Ulan 84116·0690 KennethL. Alkema (801) 536·4000 DIrector (801) 536·4099 FAX 

### January 31, 1991

A_ "." (,:' -L--**/'~** 

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### Department of the Air Force HQ Ogden Air Logistics Center (AFLC) Hill Air Force Base, Utah 84056-5149

Re: Eighteen Month Variance for Aircraft Purge System near Building 287 to use Rota-Mist while**Repa~~s** 

### are Accomplished Davis County CDS Al

Dear Colonel Judd: The above-referenced request was presented to the Utah air Conservation Committee (UACC) on January 17. 1991. Under authority of Title 26, Chapter 13-15, Utah Code Annotated. as amended, the UACC approved the request to temporarily use alternate. less efficient, Rota-Mist emissions control equipment on the aircraft fuel purge system (approval order BAQE-653-90), It is understood, you will proceed with redesign and installation of the burnedout incinerators or equivalent technology as quickly as possible. The following conditions shall be applicable during the time of the variance: 1. Hill Air Force Base shall install the Rota-Mist emissions control equipment on the 28,000 gallon purge oil reclamation unit. The purge unit shall be located at area 15090 near Building**~287.** 

### 2. The reclamation unit shall operate with the Rota-Mist emissions control equipment**n~** 

### longer than June 30, 1992. Effort needs to be extended to minimize the actual time the Rota-Mist emissions control equipment will be used before the incinerators or equivalent technology will be put into service. 3. The purge oil reclamation unit shall not be operated without the Rota-Mist emissions control equipment in place and operational. 4. The applicable conditions of the approval order BAQE-040-91, numbers 4. 5. 6 and 9. shall apply while the Rota-Mist emissions control equipment**~s** 

### in use.



### 4.2.4-630

### Thayne Judd



# -- January 31. 1991 Page 2

5. Emissions from the reclamation unit shall not exceed 2.6 ton per 12 month period and shall be included in the emissions inventory. Emissions shall be calculated using the data obtained f=om compliance with conditions in approval order BAQE-040-91 and an efficiency factor recommended by the manufacturer or as determined by testing if directed by the Executive Secretary.
6. A notice of intent shall be submitted for the new incinerators or alternate technology for the reclamation unit emissions in accordance with Section 3.1. Utah Air Conservation Regulations.
Sincerely.

# }~~&dur c. Burnell Cordner.**~xecutive** 

### Secretary Utah Air Conservation Commit:ee FBC:LCB:jiw

cc: 

### EPA Region VIII. Mike Owens Davis County Health Department



### 4.2.4-631

# @ "- -"

-


# _.. '-." 

# .... o '.

.. ..
. .... 

### .. 

### DEPARTMENTOFHEALTH DIVISION OFENVIRONMENTALHEALTH
Bureau oi Air Ouall1y :"ormanH. Bangerter 1950Wes; NOflh Terno:e Governor POBox 16690 SuumneDandoy,**~1.D.,** M.P.H. Executive DIrector Salt Lake C'IV Ulah 84,16·0690 (801) 536-4000 Kenneth L. Alkema Director (801) 536-4099 FAX MEMORANDUM TO: 

### F. Burnell Cordner, Executive Secretary 

### TIffiOUGH: Montie Keller, Branch Manager

# @
TIffiOUGH: Donald E. Robinson,

. P. E. , 

### Manager, Engineering Section 

### FROM: Carl Broadhead, Environmental Health Engineer Subject: Hill Air l\orce Base Fuel Purge System Intermediate Control Variance Date: January 14, 1991
Background The fuel must be removed from an aircraft before moving it into a hangar for repairs due to safety and fire concerns. After draining the tanks, the mechanics pump a purge fluid through the fuel system and then regenerate the purge fluid. This is done by heating the used purge fluid and blowing air through it. The JP-4 is driven off and either condensed or incinerated. The old system approved in 1983 (AO dated January 11, 1983) used a ROTAMIST emissions control unit and is located near Building 236. The ROTAMIST collectors are about 70% effective. On January 13, 1989 HAFB was issued an approval order for a second purge system to be located near Building 287 which had two incinerators for emissions control which are both 98% effective. The new unit became the unit of primary use. In October 1990 the incinerators became overheated and caught fire, rendering both incinerators nonfunctional. \ HAFB has determined that there was condensation of JP-4 fuel vapors into droplets plus carryover droplets in the vapors from the purge fluid regenerator that were going to the incinerators. The incinerators were designed for only vapors. The higher BTU value of the droplets drove the temperature beyond the maximum allowable temperature of the catalyst and destroyed the units. Problem The purge system emissions control system will have to be redesigned and replaced. It is estimated that the time required to have a new high efficiency emissions control system on line will be



### 4.2.4-632

### 18 months. Meanwhile, the fuel purge system is still required to be used because of fire and safety concerns, and the purge fluid needs to be regenerated. HAFB ,has available ROTAMIST oil mist collectors for inunediate installation and use. The estimated difference in emissions between the incinerators and the mist collectors is approximately 2.6 ton per year of VOC. Applicant Request HAFB requests the Air Conservation Committee to grant a variance allowing the use of the less efficient ROTAMIST collectors only until the new high efficient incinerators can be replaced. The requested time period is not to exceed 18 months or no later than June 30, 1992. Reconunendation I reconunend that the request be granted, based on the following: A. The ROTAMIST collectors are the best control option which is available on short notice. No uncontrolled emissions will be released. B. The 18 month request is reasonable and a relatively short time to accomplish the,work. C. The 2.6 tpy increase in VOC emissions is a small amount for that time period. D. The emissions will be controlled at the same level as the older unit near Building 236. CARL HAFB-VAR.REQ

4.2.4-633DEPARTMENT OFTHE AIR FORCE HEADQUARTERS OGDEN AIR LOGISTICS CENTER (AFLC)**RECEiV~:** HILLAIR FORCE BASE. UTAH 84056-5990 

## DEC1 

## 7 

## 1990

AIR QUAL j:Y 

### 1**.~ ~?90**  Mr Mike Beheshti Bureau of Air Quality 1950 West North Temple PO Box 16690 Salt Lake City, UT 84116-0690
Ref: Request for Modification of 13 Jan 89 Approval Order for Aircraft Purge System Near Bldg 287 (BAQE-653-88)
Dear Mr Beheshti:
Per 10 Dec 90 telephone conversation between Jay Gupta and you, we submit this request for modification of the referenced approval order.
On 10 Oct 90, we reported that one of the JP-4 purge incinerators caught fire rendering both incinerators nonfunctional. Since then, we have not operated our purge facility near Bldg 287. We wish to operate this facility using Rotamist oil mist collectors, until we can put the incinerators back in operation. We anticipate 15-18 months for the redesign and installation of new incinerators. Actual performance data on Rotamist collectors is not available. Estimating, at best, 70% collection efficiency, additional JP-4 vapors emissions to the atmosphere will be 5,250 pounds per year. Manufacturer's brochure on Rotamist collector is attached.
We would also like to operate our purge facility in Bldg 236 under an Approval Order, issued 11 Jan 83. However, condition 8 of the referenced approval order states, "This approval ordet shall replace the Approval Orders, dated 19 Oct 77 and 11 Jan 83". 11 Jan 83 approval order was for the purge facility in Bldg 236. We did not intend that this approval order be replaced when we filed 

### Nor for the purge facility near Bldg 287.
We request two modifications to the referenced approval order as follows:
1. Change condition 8 to read, "This approval order shall replace the approval order dated October 19, 1977."



### 4.2.4-634 

# oAFIi

# C- COMBAT STRENGTH THROUGH LOGISTICS2. Change condition 2 or add a new condition to read. "For a period not to exceed 

### 18 months from the date of this modified approval order. emissions from all three purge oil units near Bldg 

### 287. shall be controlled using Rotamist oil mist collectors. At the end of this period, emissions shall be controlled by catalytic incinerators."
If you have any questions or need additional information, please feel free to contact Jay Gupta at 

### 777-6917.

1 Atch Manufacturer's Brochure 

### J,' cc: JAM 1"\ .•• TrW l.,'"



### 4.2.4-635,... - - '.

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...hLr·;IL.C MODEL 650

HOODS AND ADAPTEF.:; 

# ..-..,

ROTA\llST offe.; JI1 extens:\,e lint" of**~d~:** ,", ;.",:**fl~[ings** to simplify**in~tJll.[lil)n** of**mis~~i_c;,~:~~2.!i~** sere\': maChineL:lncLolu<:r**m·!I'b.jtlt._t29~_,~fh)ods** Jnt cur'a!n.**ar~** ava:lablc for genaJi**purpo~e u~c**  with ma.:hines not**~qu:pped** suspended**~~** :-; 30 hood, Filtration elcment mJ}' be**c!~::!ncd** in place from hdow.**entin~** unit is readily remo\"3ble, :.toad and unit**Jss<:rnbl~'** m.lY also be floor suppo.tee with**s!an(.\~:c** pedestaI and 5wi"cl adapter. Suspended u'.1ngement JIs.:, applicable to '.10dd 750, I

Two models**:l\'ailabl~** 10r DJvcnport "\lIlonlJri,'"**-l~0** :!:ld 5000. f0r:.-!-\);" mnuo'I')'; on tht' l1l.lchine, Reie. to CJtJlog for details on this iinc of high ,.;fici<:ncy J:lJ compa.:t ':li;;t**<:ollcctor~** that hJ' won al'claim 'for rcIiJbllit:-' J:1d low cost ofmaintt"nance.
REPRESE1\TED BY .0;"

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110 fRENCH ROAD. GARDENVILLE**I~OUSTRIAl** PARI TECHNOLOGY. INC. BUFFAlO, HEW YCRl unl

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### TECHNOLOGY, INC (716) 668-5222

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# g~~~~~~~~~:;~-HEALTH ':.

.

.;. Bureau of A" QualilY Norman H. Bangerter 1950West Nonr> Temple Governor**~;** P.O. Box 16690 SuzanneDandoy,M.D., M.P.H. Executive Director Salt Lake City. Utar> 84116-0690

. (801) 536·4000 KennethL. Alkema Dlrector (801) 536·4099 FAX
MEMORANDUM TO: 

### F. Burnell Cordner, Executive Secretary**'\~** 

### THROUGH: 

### Montie Keller, Branch Manager**~i** 

### THROUGH: 

### Donald E. Robinson, P. E. , 

### Manager, Engineering Section FROM: Carl Broadhead, Environmental Health Engineer Subject: Hi11 Air' Force Base-.:..: Fuel Purge System Intermediate Control Variance Date: January 14( 1991
Background The fuel must be removed from an aircraft before moving it into a hangar for repairs due to safety and fire concerns. After draining the tanks, the mechanics pump a purge fluid through the fuel system and then regenerate the purge fluid. This is done by heating the used purge fluid and blowing air through it. The JP-4 is driven off and either condensed or incinerated. The old system approved in 1983 (AO dated January 11, 1983) used a ROTAMIST emissions control unit and is located near Building 236. The ROTAMIST collectors are about 70% effective. On January 13, 1989 HAFB was issued an approval order for a .second purge system to be located near Building 287 which had two incinerators for emissions control which are both 98% effective. The new unit became the unit of primary use. In October 1990 the incinerators became overheated and caught fire, rendering both incinerators nonfunctional. HAFB has determined that there was condensation of JP-4 fuel vapors into droplets plus carryover droplets in the vapors from the purge fluid regenerator that were going to the incinerators. The incinerators were designed for only vapors. The higher BTU value of the droplets drove the temperature beyond the maximum allowable temperature of the catalyst and destroyed the units. Problem The purge system emissions control system will have to be redesigned and replaced. It is estimated that the time required to have a new high efficiency emissions control system on line will be
4.2.4-638

### 18 months. Meanwhile, the fuel purge system is still required to be used because of fire and safety concerns, and the purge fluid needs to be regenerated. HAFB has available ROTAMIST oil mist collectors for immediate installation and use. The estimated difference in emissions between the incinerators and the mist collectors is approximately 2.6 

### ton per year of VOC. Applicant Reauest HAFB requests the Air Conservation Committee to grant a variance allowing the use of the less efficient ROTAMIST collectors only until the new high efficient incinerators can be replaced. The requested time period is not to exceed 18 months or no later than June 30, 1992. Recommendation I recommend that the request be granted, based on the following: A. The ROTAMIST collectors are the best control option which is available on short notice. No uncontrolled emissions will be released. B. The 18 month request is reasonable and a relatively short time to accomplish the work. C. The 2.6 

### tpy increase in VOC emissions is a small amount for that time period. D. The emissions will be controlled at the same level as the older unit near Building 236. 

### CARL HAFB-VAR.REQ



### 4.2.4-639

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### 4.2.4-640

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:-ionnan H. Bangerter Governor Suzanne Dandoy. M.D., M,P,H. Execuuve Director Kenneth L. Alkema Director 

### DEPARTMENT OFHEALTH DIVISION OF ENVIRONMENTALHEALTH
Bureau 0: Air Quality 1950West North Temole PO 80x 16690 Salt Lake City Utah 84 1 5·0690 (801 ) 536·4000 (801) 536·4099 FAX
MEMORANDUM 

### BAQE-020-1991

MEMORANDUM TO
FROM: 

### SUBJECT: DATE: Donald E. Robinson, Manager, Engineering Section, Carl Broadhead, Environmental Health Engineer Hill Air Force Base, Aircraft Fuel Purge System January 10, 1991

============================================================;=================== 

### The fuel must be removed from an aircraft before moving it into a hanger for repairs for safety and fire concerns. After 'draining the tanks. they pump a purge fluid through the fuel system and then recover the purge fluid. This is done by heating the used fluid and blowing air through it. The JP-4 is driven off and either condensed or incinerated. The old system approved in 1983 (AD 

### dated January II, 1983) used a RDTAMIST emissions control unit and was located near Building 236. On January 13, 1989 Hill Air 

### force Base was issued an AO for a new purge system located near Building 287 which had incinerator controls. The new unit became the unit of primary use. The wording in the second notice of intent appeared to indicate it to be a replacement of the first unit so the old AO was rescinded in Condition 

### 18 of the AO # 

### BAQE-653-88. With the new unit at Building 287 on line the purge system a Building 236 has not been used extensively. During the public comment period and until recently. the deletion of the AO was not detected. In a letter dated December 13, 1990, Hill AFB has requested that the approval order for the purge unit at Building 236 be reinstated as they still need to use it on occasion.
It is recommended that the request be granted and a modified AO is attached.



### 4.2.4-641

# ~.~.".~"'.'~"".

Nonnan H. Bangerter Governor Suunne Dandoy. M.D

.. M.P.H. Execuuve O,rector Kenneth L. Alkema Director 

### - 

## -'

-..... 

### DEPARTMENT OF HEALTH DIVISION OFENvIRONMENTALHEALTH
Bureau oi Air Ouallty

,950 West Non/) Temole PO. Box 16690 Salt Lake City. Uta/) 8.: 116·0690 (801) 536-4000 (801) 536-4099 FAX BAQE-02l-91

January 15, 1991

Thayne Judd, Colonel, USAF Department of the Air Force HQ Ogden Air Logistics Center (AFLC) HAFB, Utah 84056-5149

Re: Modified Approval Order for Aircraft Purge System Near Building 287 Davis County CDS Al

Dear Colonel Judd: The above-referenced project has been reevaluated as per your request in the letter dated December 13, 1990. It has been determined that the approval order for the purge system near Building #236 had been rescinded due to a misinterpretation of the submitted information for the new purge system that was approved to be located near Building #287 in approval order #BAQE-653-88. THe conditions of this approval order reflect any changes to the previous conditions which resulted from the evaluation. This air quality approval order and authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order: 1. Hill Air Force Base shall install the new 28,000 gallon purge oil reclamation unit, which shall operate in conjunction with the two existing 6,000 gallon units. The new unit shall be located at area 15090 near Building 287. The purge oil unit shall be installed according to the information submitted in the notice of intent dated August 1, 1988. 2. Emissions from all three purge oil units shall be controlled by**ca~al¥tic** incinerators. One incinerator shall be used on the two eXl.stl.ng 6,000 gallon units. Both incinerators shall be an DRS environmental equipment model 1282001 or equivalent. Equivalency shall be determined by the Executive Secretary. The incinerator shall operate whenever the corresponding purge unit is operating. 3. Either one or both of the catalytic incinerators shall be stacked tested if directed by the Executive Secretary. The emission rate/concentration shall not exceed any of the following values: A. 19.18 lb per 1,000 gallons of purge oil burned for particulate B. 11.89 lb per 1,000 gallons of purge oil burned for PM10 The test method used shall be 40 CFR 60, Appendix A, Method 5. A pretest conference shall be held if directed by the Executive Secretary. It shall be held at least 30 days prior to the test between the owner/operator, the tester, and the Executive Secretary. The exhaust stacks need not be designed to accommodate testing. However, if the Executive Secretary determines a stack test is necessary, whatever modifications needed to meet the requirements of 40 CFR 60,


### 4.2.4-642Thavne Judd January 15, 1991 Page 2Appendix A, Method 5 and the requirements of Occupational Safety and Health Administration (OSHA) for providing approvable access to the test site shall be made. 4. Visible emissions from either incinerator shall not exceed 10% opacity. Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. Opacity observations of intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at lS-second intervals over a 60-minute period shall not apply. The averaging time shall be the actual time interval over which visible emissions are observed. Any time interval with no visible emissions shall not be included. 5. The volume of purge fluid which is replenished to the storage tanks shall be measured every month. This volume is assumed to be volume of JP-4 which has been sent to the catalytic incinerators. The volume shall be recorded in an operations log. The log shall be kept in area 15090 and shall be made available to the Executive Secretary or his representative upon request. 6. The sulfur content of any JP-4 burned shall not exceed 0.85 pounds of sulfur per million BTU heat input as determined by ASTM Method 0-4239- 83. The sulfur content shall be tested if directed by the Executive Secretary. 7. This approval order shall replace the approval orders dated October 19, 1977 and January 13, 1989. 8. All installations and facilities authorized by this approval order shall be adequately and properly maintained. 9. The Executive Secretary shall be notified in writing upon start-up of the installation, as an initial compliance inspection is required. Any future modifications to the equipment approved by this order must also be approved in accordance with Section 3.1.1, UACR. This approval ·order in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including the Utah Conservation Regulations. Sincerely,

# t~o~~xecutive Secretary Utah Air Conservation Committee FBC:LCB:jiw

cc: EPA Region VIII, Mike Owens Davis County Health Department



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