DAQ-2024-004982

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-120-24
Site ID 10892 (B5)

Brian Dial, Energy Services Director
City of St. George
175 East 200 North
St. George City, UT 84770

Dear Mr. Dial:

Re: City of St. George (St. George City Power) - Pretest Protocol for Carbon Monoxide (CO),
Volumetric Flow, Nitrogen Oxides (NOx), and Oxygen (O2) Relative Accuracy Test -
Washington) County

The Utah Division of Air Quality (DAQ) reviewed St. George City Power’s pretest protocol dated
January 18, 2024. The proposed test shall be performed under the following conditions:
St. George City Power’s monitoring system to be certified:

Source Channel Manufacturer Model # Monitor
SN
Low
Span
High
Span
Installation
Date
MC-2
CO Teledyne M300 2156 10 1000 03/28/2019
NOx Teledyne M200EM 456 8 150 03/28/2019
O2 Teledyne M300 2156 25 03/28/2019

TRC Environmental will conduct a relative accuracy/performance specification test on St. George
City Power’s continuous monitoring system.

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour.

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DAQC-120-24
Page 2

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
April 18, 2024 MC-2
CO Methods 3A, 10, and 19
NOx Methods 3A, 7E, and 19
O2 Methods 3A
• Reference Method 3A - Determination of Oxygen and Carbon Dioxide
Concentrations in Emissions from Stationary Point Sources – (Instrumental
Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.
• Reference Method 7E - Determination of Nitrogen Oxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.
• Reference Method 10 - Determination of Carbon Monoxide Emissions from
Stationary Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR
60 Appendix A.
• Reference Method 19 - Determination of Sulfur Dioxide Removal Efficiency and
Particulate Matter, Sulfur Dioxide, and Nitrogen Oxides Emission Rates as
outlined in 40 CFR 60 Appendix A.
• Deviations - The Director or the representative of the Director must be notified of
and approve deviations of the Reference Method test. Any deviation from these
conditions without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing
contractor from strict adherence to all applicable EPA methods, DAQ policies,
Utah Air Quality Rules (UAQR), and methods approved by the Director. Any
deviation from EPA methods, DAQ policies, UAQR, and methods approved by the
Director must be addressed separately and express written consent given prior to
commencement of testing.
• Field data (Point Source emission data and test data) shall be turned over to the
DAQ in a timely manner for review.
• The Director will determine the relative accuracy of each monitoring system based
on Point Source continuous emission monitoring data and test data acquired by the
staff member of the DAQ during the test.
• All test reports must be submitted to the Director not later than 60 days after
completion of the test.
• The test report shall include all raw calibration data, raw emission data with date,
time stamps.

DAQC-120-24
Page 3

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and
maintained process conditions representative of normal operations, and operated
under such other relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements and
information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

HB:RL:jl

cc: Southwest Utah Public Health Department
TRC Environmental

* $ . # ( ) - — G v A ? A C @ F w @ F ˜
Rob Leishman Jr