DEPARTMENT OF ENVIRONMENTAL QUALITY 

DIVISION OF AIR QUALITY ,..-. 

Michael 0, Luvin 

GoYemor 150 North 1950 West Reply to: State of Utah 

Dianne R, Nielson. Ph.D. Salt Lake City, Utah 84114 Division of Air Quality 

Execul.ive Du-or (801) 536-4000 P.O, Box 144820 

F, Burnell Cordner (80 I) 536-4099 Fax 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: 

4.2.4-594 
James 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 18 1992 

yAir Quality 

DEPARTMENT OF TIlE AIR FORCE 

HEADQUAR1ERS OGDEN AIR LOGISTICS CEN1ER (AFMC) 

Iill..L AIR FORCE BASE, UTAH 84056 

Mr Tim Blanchard 1 7 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 = 12.46x 1.45x 1.3x80/520 = 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 ';,., 

/ 

4.2.4-597 
NO. 088 

! 

I 

I 

tran'''''MI Mmo 

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 

For iJP-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 i emission8 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 DEPARTMENT OF THE AIR FORCE '\i,~,d) CT0 9 1992 HEADQUARTERS OGDEN AIR LOGISTICS CENTER (AFMCl 

v '. HILL AIR 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:;

i1 

- 

j

r

> 

( 

4.2.4-600 J 

5 
DEPARTMENT 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 

Dear Mr 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 

/""\ SfP 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 

A,t.H -1 
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.~ -
ORS Environmental Equipment 

Catalytic Scavenger® 

Vapor Abatement System 

When Clean Air Matters 

Most site remediation prOlects 

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Cost Effective And Efficient 

The ORS Cataiytlc Scavenger system is highly cost effective be- . 

couse of its unique deSign. AI the 

heart of the system is a durabie 

platlnum-coated catalytic element. 

This unit operates at temperatures 

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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 

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system 01 every ie'lei. Jigital outpur diso:ays orovlae cUlck, easy-toread reiere:1ces ror sil·~ personnel. 

From Its exolosion,proof deSign to 

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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 

costs of carbon 

and catalytic 

conversi.on. In 

this example. 

the Scavenger 

system saved 

the client 

$30.000 over 

3 manths. 

Carbon was 

regenerated 

off-site. 

Above: 

Interior view 

of control module showing 

electrical 

circuitry. 

4.2.4-604 
Reliable 

ORS Environmental Equipment 

has been aesigning, manufacturing and installing innovative systems for site remediation and contaminant recovery since 1975. 

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This experience is built into every 

Catalytic Scavenger system and is 

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...enefits 

• On-site contaminant destruction 

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When enviranmental regula' 

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put the Catalytic Scavenger 

system to work for you. 

&I EI.ad, -Con~ - - - Supply 

Contaminated I + Temperature 

Vapor Influent 

Sensor 

Clean Vapor 

Effluent 

Waste Heat 

Discharge 

Above: 

Process flow 

At a service 

station on the 

West Coast. 

the ORS 

Catalytic 

Scavenger" 

system was 

used for on site 

destruction of 

contaminatea 

vapors emitted 

from a Soli 

Vent System. 

The unit 

achieved a 

99% destruction rate for 

benzene, 

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California Air 

Pollution Control District 

requirements. 

Operating 

casts were less 

than 5300 per 

month. 

diagram showIng path af gas 

from remediatlan system to 

discharge. 

Contaminated 

vapors are 

preheated in 

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exchanger by 

hot exhaust 

released from 

the catalyst. 

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heater to the 

catalyst where 

combustion 

takes place. 

The clean 

vapor effluent 

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after being 

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the heat 

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systom was 

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Scavenger 

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approximately 

6000 Ibs. of 

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contaminants, 

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of thousands 

readout of of dollars in 

Influent air 

temperature 

operating 

costs. at the catalyst 

through glass 

viewing port. 

ri",_ 

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

4.2.4-605 
ORS Environmental Equipment 

Cota lytic Scavenger® 

Features and Specifications 

Features 

Applications: Can be used with 

Air Strippers, Soil Vent Systems, 

or other vapor streams. 

Portable: lightweight, skid 

mounted unit is easily transported. 

Durable: Precious metal catalyst 

is designed for long life with 

proper maintenance. 

EH'cient Operation: Up to 

70% heat recovery by heat ex· 

changer. 

Explosion proof Design: Control system and heater meet NFPA 

standards for use in Class 1, 

Division 1, Group D hazardous 

environments. 

. Sensor Redundancy: System 

features two LEL sensors wired in 

series. 

Control Mechanism: Allows in· 

terruption of other site operations 

during alarm conditions. 

Manual Slast Gate 

Dampers: Allow the processing 

of higher contamination levels 

produced by Soil Vent Systems. 

Manual Temperature 

Monitoring: Thermocouples and 

hand held thermometers provide 

additional monitoring 

capabilities. 

Manual Reset: After an alarm 

condition or shutdown, system will 

not restart without operator inter· 

vention. This feature prevents restarting before the couse of the 

shutdown has been investigated. 

High and Low Temperature 

Shutoffs: Prevent overheating 

and release of untreated vapors. 

Continuous Gas Monitoring: 

LEL sensors and controller shut 

Model 

Information 

'/ 

#1282001 #1282002 

20kw 35kw 

Air Flow Rate 100-200· SCFM 200-500 SCFM 

Power Requirements·· 230V(l or 3 Ph.) or 230VI460V (3Ph.) 

460V(3 Ph.) 

Dimensions 8S"h x 85"1 x 42"w 62"h x 132"\ x62-w 

Weight -1300Ib. -2000Ib. 

Operating Temp. Range 400o_900Fo 400°-900°F 

.. 300 SCFM IS ad'Hevaoie wIth SoeCiQl duplex unit. 

... Up to 125 amp M1r"Vice dependIng on voltoge end phose. Consult factory for weclfic ntqulremenl's. 

down system if flammable gas concentrations rise beyond adjustable 

limit5. 

Gas Sensor Failure Alarm: 

Shuts system down and triggers 

audible/visible alarm with 

audible shut-off. 

Automatic Dampers: Divert explosion proof vapors away from 

catalyst during alarm conditions. 

Min'mal Temperature Drift: 

System eledronics provide tight 

temperature control of gas enter- Components of ing the catalyst. Catalytic Scavenger unit 

Specifications clockwise from 

lower left: 

Catalyst: Platinum coated. heater, control 

module, heat Enclosure: 15 gauge sheet exchanger, aluminum. catalyst.

Gas EJ(po~edComponents: 

304 stainless steel. 

rnlet Pipe: 4/1 female: PVC 

flange. 

Outlet Pipe: 6" 0.0. 5toinless 

steel discharge port. 

Insulation: 3/1 ceramic blanket. 

Patent: Pending. 

Partial List of 

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 

Other gases: 

Acetylene 

Carbon 

monoxlOS' 

Alkanes: 

Butone 

Heplanes 

Hexane, 

P~ntanc$

Octane 

•••and ethel' 

organic 

compounds 

4 Mill Street, Greenville, N H 03048 

Fax: (603) 878-3866 Telex: 75-2858

~Q!!§ For more information or to place an order, please call 

·~EQUIPMENT (603) 878-2500. Sales and service facilities are located tnrough-

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

4.2.4-606 
DEPARTMENT OF THE 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 

4.2.4-609 
DEPART\lEi\T OF 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"' :.:' 

,. -,., ,,,. S0 11 535·6' 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 

4.2.4-614 
DEPARTMENT 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;re ly. .,/ 

.' / / .... 

;/' ,! . .r:: I/~:Mc~/~~

rJATHAN o. CURRIER 1 Atch 

Director Comments 

Env Mgt Directorate 

/\ 

I ) 

OE C 1.1 i~,_'; '\JV" 

f AIR QUALITY Ii 

4.2.4-615 
COMMENTS 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 

4.2.4-616 
variOUS 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. 

4.2.4-617 
DEPART\: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(~~{~~

4.2.4-621 
2 

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 

co x 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 

4.2.4-622 
3 

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 400-900oP. 

A partial list of destructible compounds includes benzene and toluene. 

It is recommended 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 

4.2.4-623 
4 

which impact 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 new major 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 

4.2.4-624 
5 

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 

4.2.4-625 
6 

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(~ .,. tt ,:1.1:·24 TON/Y F:

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: ·_·~-!.LOC·-ME-THANE , .. ,-"., , e ., • ., "., ,. .. .. • • .. 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',;; YER I AL-- BALANCE- CALCULA T-1 ON 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- ,. 

'.' ••:> TDr~ / '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 • 3CF~

COMPANY NAME: HILL AIR FORCE BASE 

~QCArION: DAVIS COUNTY 

ANNUAL EMISSIONS ESTIMATE IN TONS;YR = 

(EMISSION FACTOR)(FUEL OIL CONSUMPTION)(ITON/2000LBS) 

-TSF'· .. " .. '!' " t .. 0.04 TONS;'Yf:

~. ~11 '::+.. .. .. .. .. .. .. .. .. • .. .. .. t .. .. .. .. .. .. or .. , ; .. , .. • • • .. .. " f .. ., .. .. .. .. .. • .. .. .. , .. () • G:: TON S/':' ~:

SC!>~	 , - t .. 0.00 TONS/YF: 

NO;.;: 'l' " .. " - .. t , y " .. o.11 TONS':';'~:

CO .. I .. t '!' + + t ( t I t .. o. 0 1 TON S/ YF: 

\.10 C rl CI r,- MET H.. ; t '!' .. t ;. t j .. t .,. t (0.00 TONS/YF:

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

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(; = (;:.: <= 10iJu, )4T.sF') ••••••·•••• •• ':". 11.-392 Lf: /1 0 3 G~L

i; <= 10IJ r.: (F ROM TABLE 1 .. 3- 5) t t t t t .. .. 62 .. 0 ~/~ PASS

sox= (1~4)(%S CONTENT OF FUEL)(l00-% CONTROL)/(100) 0.27 LB:'10~3GAL

SULFER CONTENT OF FUEL: UACR 4.2 LIMIT •••..••• _ -- L 7.0 ;~ . In. 

;;, CC' ~)T ~: C' L FF: ']MBA CT D:: TEF:r : :; ATI 0 f~ • • • • • • • • • • • • • • • • 99 .. S:' .". 

~,~ .:' ~< "" •.. .. .. .. .. .. p .. .. .. .. t .. .. .. .. .. .. • .. .. .. • • • .. .. .. .. ,. .. .. .. .. .. .. .. t .. .. .. .. .. .. ~5.0 LB/10'"'3G;'d... 

.5_ 0- L B/.1 r.l~~ 3 SAL 

NON METHANE VOC " . 1. 13 LB/10~3GAL

Mf~THHNE •••• f •••••••••••••• ~t •••• t ...... t ••••••• t .... 0.475 LB/l0'"'3GAL 

~UEL OIL CONSUMPTION IN 1000 GALLONS! YR FROM: 

( MMBTU;' HR; 0: I-l F:./ YR) / ( n u; GAL \ .......•.•••........... 4 .. 0 11~~~GAL../Y~:

MMBTU/HF:: (HP)-(.('MMBiU/HR)/H~'\.> (BOILEF: EFF)/lCoO)) .. 0.1::6 MME:TU/HF~

HP: Nor INFO. +,. ,..,. . _ HF' 

BOILER Z EFF. : NOI INFO .. , ......•••. , ...•••.. 

H;:;/YR: NOI INFO •••••• - •••••• , - •••••••••••••••• 

	 SULFU~ ~y WT. ALLOWED: UACR 4.:= 

(LB!MMBTU ~LLOWED)(OIL HEAT ~AL~E BTU/GAL)! 

(FUEL OIL. DENSITY)(100)!(1000000) _ 1 .. -: 0 :~ {S) 

LB/MMBTU= ALLOWED SULFER BY U;ICF: 4.2 •••••••••.• 0.85 Lt:/MMf:TU 

OIL HEAT VALUE FROM: AP~2 ~G. A-3 .••••••.•...•. 130000.0 BTU/G~L

FUEL. DIL DENSITY .. . 6.50 L=:/GAL .-.. 

4.2.4-629 
..... 

;'-. .'- _.-.-

~."":"":",. DEPART~ENTOF HEALTH 

DIVISION OF ENVTRONME!\T'fAL HEALTH BAQE~065-91

Bureau or All O~alliv Norman H. Bangerter i 950 West Nor;~ TefT'.Dle Goyernor 

POBox 16690 Suzanne Danaoy, M.D.. ~.P.H.

Executlye Dtrector Salt Lake Citv. Ulan 84116·0690 

Kenneth L. Alkema (801) 536·4000 

DIrector (801) 536·4099 FAX 

January 31, 1991 

A_ "." (,:' -L-- /'~
 .r ,I /' 'd / -<... ,,' "~":~i~V<--f 7\ /"~'-;~ -~ "':.'-~ >; __cv,_~J-'<' , ,'- .... r--..' - - I . t.1. ' '/ ' .. /'. f ,.... A 

_' . ~a-d-, -CoJ.-oRe-:l-, :.; Sr.F 

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 '. 

.. .. . .... .. DEPARTMENT OF HEALTH 

DIVISION OF ENVIRONMENTAL HEALTH 

Bureau oi Air Ouall1y :"orman H. Bangerter 1950 Wes; NOflh Terno:e Governor POBox 16690 Suumne Dandoy, ~1.D., M.P.H. 

Executive DIrector Salt Lake C'IV Ulah 84,16·0690 

Kenneth L. Alkema (801) 536-4000

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 

4.2.4-633 
DEPARTMENT OF THE AIR FORCE 

HEADQUARTERS OGDEN AIR LOGISTICS CENTER (AFLC) 

HILL AIR FORCE BASE. UTAH 84056-5990 RECEiV~:

DE C1 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 oAFIiC- COMBAT STRENGTH THROUGH LOGISTICS 
2. 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 
,... - - '. -.• r- I.'..... '......... 1'"""'1 Ilv 

,. 

...... 

MOD'= L 450 

Cr~nJ\,,·r~. r()\\'~r uiilh J:l~~ l\~~J~'~ .. :::.:~~ l:i~..:h~:L':

Illl)dt... 1 hJnJk°":; J-.' 1.,:I::: .,'.• ::: :"y;.~. ~·.;-li~ ....1; ",:,,',:,:, 

- '" .. - ... _.- ... 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

pedesta I and 5wi"cl ada pter. Suspended u'.1ngement J Is.:, 

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 of maintt"nance. 

REPRESE1\TED BY 

.0;" _

R 0 r,.1\., MIS r® Division' 

110 fRENCH ROAD. GARDENVILLE I~OUSTRIAl PARI 

TECHNOLOGY. INC. BUFFAlO, HEW YCRl unl ., .-...:.... .- lAC 1\~) PHONE &S8,511~ '." ~-.. 

Printed in l1.~A, Form A 15 

~------------~~---~
-- -

, - ... . , .... ",; 

( -, 210 Fre. Jl ;.\o.:;d "" - K:,,/.) ;"-i:, ~/ - Gardenville Industri<}1 P<},:< 

TECHNOLOGY, Buffalo. New York 14227 INC 

(716) 668-5222 

Th<: p.:rman<:nt (oii<:.:tor elem<:nt is ,d;"J:~l::"';:, ~::~ .,~

b<: easily cleaned with a jet spray of sol\'<:nl Whli~ o;:><:rJt:r.g. 

C,"-. ·.:parat<:d from Ihc.: air stream ~IHj ";~roSIIS In 'h.: 

le drain p:Jn. from whi..:h it return, ,0 the rr\Jchir.~

L .1S<:. Drain pan rc:mo\'able hy or~:ll:1l.: 'r:lr.j:·:'::(~~"

Jaorr:ls (;)mpl<:l<: a.:cess to insiJ~ ot unit. i{c'1I10VJi 0: ,::.::t 

UJI:.'f .~:,.;",; (ullc.:(tor dcment tu ,lip uC;' ;0: ~;~':::lng 0:': 

:hc' :::1"" ..1~ wIth ",ater soluble dc:tc:r;:~1l! c',·. :~J. Cor.,;):· 

".11:" . ,··::;~;'\t cag<: and c<:ntrifug:aJ ::- ".: ... ,. \Ch~::1 '.'.:;:, 

d'.: ·~~.·!::1t:d hlJdt:s lS rt\."~tc:d :.JnJ ','-\·;tl::J ..::;",: p~r:-:-:;;­

"':':11:, h"I~::("J. ~!Jndlcs rr,w,J"d on lc';' u: ',::':, ,r:~:i.

T - .. 

... ! 2 I i 

10 

I 

~, 6 .

---.,, t 4 .,. I I 

I ~6 i 1-

1 

~------------------'

I 1'::-

A' ., ,: 

650 

67SCFM 

SPECIFICATIO:--';S 

:.10:0:. s:ngk or .3 ph.!,<:. s,J:1dJrG ·"ui'ages. 

5: n~:e ;Jhase m od~ls su pplied \vi I h mn \1:': o\'aloJd 

c:::J:; \;Jr[.:r Jnd pliot !If?ht r.1ot.::1t<:d on ;he!I, w:tl' 6 fL 

,C:;\.;(= Lc.d and riug. 

,':-::::<cc: CJif:: :Jno [.J:' '.c-:lh t'Jd:\\'crJ Inc:lin"d bIJJ_'s 

:". :-::::~ ;Jerfor:1n.!:1C:': J: !o-.\ no"~ :''''~1. cornrkto: J'-

~;':;7;O·. J~!:..: > 

£-1:;.'1;.- ;"(i:: i~:-H () 75 SC F.\l ;'l: ,.. , 0: :1)J ;J(:': 

6 R~",o',able crain ran aS5er:,bly JccJcn::J with spr;n~

I"tches provide5 Lompkt:: acc<:~~ to Hltaior of u:llL 

5c:cty d:~charge grill:: and liflir1g hJndles. 

s. Or:IOrlJ! Fir~ DJI1~;t'~r W!lh <:!~':[rlC:J! Interlocr. 10 shut 

(~o"':n I.:nikl.:ln:- I! rl.:~n~t.:r:ltL:;C ::-.:/;ccc.; 1hUo. \~)y :lIsa 

.. I \~ I 1 ".'. : • 

. ," ,~>.\ ,~,; I " 

A7CH - i 4.2.4-637 
'~'

. ,~. T~ 2~ t,:: :~-..::: 

. 1g~~~~~~~~~:;~-HEALTH
 ':.. 

.;. Bureau of A" QualilY

Norman H. Bangerter 1950 West Nonr> Temple Governor ~; P.O. Box 16690 Suzanne Dandoy, M.D., M.P.H. 

Executive Director Salt Lake City. Utar> 84116-0690 

Kenneth L. Alkema . (801) 536·4000 

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: Hi 11 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
~.\::rJ

:-ionnan H. Bangerter

Governor

Suzanne Dandoy. M.D., M,P,H.

Execuuve Director

Kenneth L. Alkema

Director

DEPARTMENT OF HEALTH

DIVISION OF ENVIRONMENTAL HEALTH

Bureau 0: Air Quality

1950 West 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 OF ENvIRONMENTAL HEALTH

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,

4.2.4-642
Thavne Judd

January 15, 1991

Page 2

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 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~~xecutiveSecretary

Utah Air Conservation Committee

FBC:LCB:jiw

cc: EPA Region VIII, Mike Owens

Davis County Health Department

4.2.4-643