DAQ-2024-008171

1
DAQC-514-24
Site ID 12512 (B1)

MEMORANDUM

TO: FILE – KERN RIVER GAS TRANSMISION COMPANY – Veyo Natural Gas
Compressor Station

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: May 24, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Washington County,
FRS #UT0000004905300050

INSPECTION DATE: May 15, 2024

SOURCE LOCATION: Take I-15 to the St. George Bluff Street exit. Then take Highway 18 north to
Veyo. Take Center Street in Veyo west for about 5.5 miles to the Eagle Mt.
Ranch and turn north on well-maintained dirt road heading northwest for
about 4 miles to the facility.

MAILING ADDRESS: 2755 East Cottonwood Parkway, Suite 300
Salt Lake City, UT 84121

SOURCE CONTACT(S): Denise Kohtala, Environmental Specialist: [phone]
Grant Parkenson, Operator: [phone]

OPERATING STATUS: C1 and C2 operating; C1 on standby. 1846 MMSCFD

PROCESS DESCRIPTION: Natural gas compressor station consisting of three natural gas turbine
compressors, emergency backup generator, and a boiler (heater). Kern River
Gas has installed three compressor engines to increase the pressure and thus
the flow rate of the natural gas in the pipeline that runs from Utah to Nevada
to California. The additional turbines will increase the amount of gas that can
be moved by an additional 135,000 Mcf/day. The Veyo compressor station
compresses natural gas for injection into the Kern River natural gas
transportation system. The facility includes three SoLoNOx turbine driven
centrifugal compressors, an emergency backup power generator, and a gas
fired hot water heater. The Veyo compressor station is a major source of NOx
and CO and is subject to NSPS Subpart GG.

APPLICABLE
REGULATIONS: Title V Operating Permit 5300050003 dated December 19, 2019

0 ( 8
2
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: Not evaluated. This is a statement of fact.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. The permittee appeared to be operating in compliance with this permit. See
status of each condition below for details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: In compliance. It appears that all conditions have been complied with.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))
3
I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In compliance. This permit has not expired. Application for renewal is due by June 19, 2024.
The company submitted the application April 24, 2024, and the completeness letter was dated
May 2, 2024.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: In compliance. This permit has not expired. Application for renewal is due by June 19, 2024.
The company submitted the application April 24, 2024, and the completeness letter was dated
May 2, 2024.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: Not evaluated. This is a statement of fact.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. No outstanding emission fees noted.

4
I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: Not evaluated. This is a statement of fact.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: Not evaluated. This is a statement of fact.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance. Entry into the site and access to records was allowed for this inspection.

5
I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All applications forms, reports, or compliance certifications submitted
pursuant to this permit have contained certification as to their truth, accuracy, and
completeness, by a responsible official as defined in R307-415-3.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

6
I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance. The most recent annual certification was received August 14, 2023 (due August
15, 2023), and was reviewed under a separate memo (DAQC-939-23).

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: No permit shields have been granted.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))
7
I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency.

This notice must contain a description of the emergency, any steps taken to mitigate
emissions, and corrective actions taken. This notice fulfills the requirement of
Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: No emergency events were recorded or reported during the 12-month period preceding this
inspection.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: Not evaluated. This is a statement of fact.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: Not evaluated. This is a statement of fact.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: Not evaluated. This is a statement of fact.

8
I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: Not evaluated. This is a statement of fact.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit. (R307-415-
6a(3)(c)(i)

9
I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail
code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records have been maintained as required. Monitoring reports have been
submitted.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

10
I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions. (R307-415-
7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: Not evaluated. This is a statement of fact.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance. Emission inventories have been submitted as required.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: Not evaluated. This is a statement of fact.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

11
II.A.2 C1: Natural Gas Turbine Compressor Engine
Only pipeline quality natural gas-fired turbine with SoLoNOx burners rated at approximately 15,000 hp.
Mechanical diversion dampers installed allow exhaust gases to be diverted to a waste heat recovery
system in some operating scenarios.

II.A.3 C2 and C3: Natural Gas Turbine Compressor Engines
Two only pipeline quality natural gas-fired turbines with SoLoNOx burners rated at approximately 15,000
hp each. Mechanical diversion dampers installed allow exhaust gases to be diverted to a waste heat
recovery system in some operating scenarios.

II.A.4 Emergency Backup generator
Approximately 1072 hp only pipeline quality natural gas-fired RICE generator for emergency power.

II.A.5 Boiler
3.815MMBTU/hr only pipeline quality natural gas-fired hot water heater.

II.A.6 Mechanical Diversion Dampers for C1, C2, C3
Non-emitting equipment included for informational purposes only. The mechanical diversion dampers are
used to divert exhaust gases through a waste heat recovery system.

Status: In compliance. No unapproved equipment was observed onsite.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on Permitted Source (Source-Wide).

II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the
extent practicable, maintain and operate any permitted equipment, including associated air pollution
control equipment, in a manner consistent with good air pollution control practice for minimizing
emissions. Determination of whether acceptable operating and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to, monitoring
results, infrared camera images*, opacity observations, review of operating and maintenance procedures,
and inspection of the source. All maintenance performed on permitted equipment shall be recorded.

*The "infrared camera images" provision occurs in R307-501-4(1)(c), but not in R307-401-8(2) or,
DAQE-AN125120008-15.

[Origin: DAQE-AN125120008-15; R307-501-4(1)(c); and 40 CFR Part 60.11(d). Authority R307-401-
4(1); R307-401-8(2); R307-401-8; R307-501-4(1)(c); and 40 CFR Part 60, Subpart A]

All air pollution control equipment shall be operated and maintained pursuant to the manufacturing
specifications or equivalent to the extent practicable and consistent with technological limitations and
good engineering and maintenance practices.

[Origin: R307-501-4(2)(a); Authority: R307-501-4(2)(a)]

12
In addition, all such air pollution control equipment shall be adequately designed and sized to achieve the
control efficiency rates established in rules or in approval orders issued under R307-401 and to handle
reasonably foreseeable fluctuations in emissions of VOCs during normal operations. Fluctuations in
emissions that occur when the separator dumps into the tank are reasonably foreseeable.

[Origin: R307-501-4(2)(c); Authority: R307-501-4(2)(c)].

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Kern River appeared to be maintained in a manner consistent with good air
pollution control practices for minimizing emissions. A preventative maintenance program called
C.A.R.S. issues tasks, and the maintenance is documented in paper form.

II.B.1.b Condition:

Visible emissions shall be no greater than 10 percent opacity from compressors, heater and emergency
backup generator. [Origin: DAQE-AN125120008-15; Authority R307-401-8].

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

In lieu of monitoring via visible emission observations, the permittee shall keep one of the
following sets of records for each affected emission unit, as applicable:

(1) Documentation that the emission unit can only burn pipeline quality natural gas;

(2) Documentation that the fuels other than pipeline quality natural gas cannot be supplied to the
emission unit without modification of the fuel supply system; or

(3) Fuel bills or fuel meter reading that demonstrate only pipeline quality natural gas is
combusted in the emission unit.

13
The permittee shall keep a log which includes the location and description of each affected
emission unit. For each affected emission unit, the log shall include the type of records that will
be used in lieu of monitoring via visible emission observations, the permittee shall review fuel
bills or fuel meter reading once per quarter and record in the log the types of fuel combusted. The
records and log required by this condition shall be maintained in accordance with Provision I.S.1
of this permit.

II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. This equipment operates on pipeline quality natural gas. The equipment is not able
to operate on alternate fuels. No other fuel connections were noted.

II.B.1.c Condition:

Sulfur content of any natural gas burned shall be no greater than 0.068% by weight. [Origin: 40 CFR 60,
Subpart GG; Authority 40 CFR 60.331(u)].

II.B.1.c.1 Monitoring:

The Federal Energy Regulatory Commission (FERC) gas tariff serves as the monitoring. (40 CFR
60.334(h)(3)(i)).

II.B.1.c.2 Recordkeeping:

The total sulfur limit in the FERC gas tariff shall be recorded and converted to percent sulfur by
weight to determine the sulfur content. Records shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Pipeline quality natural gas is drawn out of the pipeline of the gas that is being
compressed and is part of the sales line covered by the tariff.

II.B.2 Conditions on Natural Gas Turbine Compressor (C1).

II.B.2.a Condition:

Emissions of CO shall be no greater than 10.12 lb/hr. [Origin: DAQE-AN125120008-15, Authority:
R307-401-8].

14
II.B.2.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Test every five years, based on the date of the most recent stack test, using 40 CFR
60, Appendix A, Method 10 or every two years with a portable testing monitor. If a portable
monitor is to be used, a correlation must be established during the initial test between the portable
testing monitor and Method 10. Subsequently, the portable testing monitor results shall be
correlated with the results of the periodic reference method test at least once every five years. The
Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director. Testing protocol shall be approved by the
Director.

(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety
and Health Administration (OSHA) approved access shall be provided to the test location.

(d) Methods to be used:

(1) To determine stack volumetric flow rate: 40 CFR 60, Appendix A, Method 2, or
other EPA-approved testing method, as acceptable to the Director.

(2) To test for CO emissions: 40 CFR 60, Appendix A, Method 10, or other EPA-
approved testing method, as acceptable to the Director. A portable testing monitor may
be used in lieu of the reference test method provided the requirements of (a) are met. If
the requirements of (a) are not met, the reference test method must be used for
subsequent tests.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and
any necessary conversion factors determined by the Director, to give the results in the specified
units of the emission limitation.

(f) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.

(g) Stack testing shall be performed with the mechanical diversion damper positioned so that the
turbine exhaust gases are not diverted to waste heat recovery.

II.B.2.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

15
II.B.2.a.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance. Stack testing was last conducted on Unit 1 on November 30, 2022. Test results were
submitted to DAQ and audited in DAQC-112-23. DAQ calculated results were as follows:

Emission Unit Test Date Pollutant Limit Results
Unit C1 November 30, 2022 CO 10.12 lb/hr 0.41 lb/hr*

*Units wase tested at four loads. The highest result is listed.
Next test is due in 2027.

II.B.2.b Condition:

Emissions of NOx shall be no greater than 8.35 lb/hr. [Origin: DAQE-AN125120008-15; Authority:
R307-401-8].

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Test every five years, based on the date of the most recent stack test, using 40 CFR
60, Appendix A, Method 20 or every two years with a portable testing monitor. If a portable
testing monitor is to be used, a correlation must be established during the initial test between the
portable testing monitor and Method 20. Subsequently, the portable testing monitor results shall
be correlated with the results of the periodic reference method test at least once every five years.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director. Testing protocol shall be approved by the
Director.

(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 in accordance with 40 CFR 60.335(a)(4) and (5). An Occupational Safety
and Health Administrations (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.

(d) Methods to be used:

(1) To determine stack volumetric flow rate: 40 CFR 60, Appendix A, Method 2, or
other EPA-approved testing method, as acceptable to the Director.

16
(2) To test for NOx emissions: CFR 60. Appendix A, Method 20, or other EPA-
approved testing method, as acceptable to the Director. A portable testing monitor may
be used in lieu of the reference test method provided the requirements of (a) are met. If
the requirements of (a) are not met, the reference test method must be used for
subsequent tests.

(e) Calculations. The nitrogen oxides emission rate (NOx) shall be computed using 40 CFR
60.335 (b).

(f) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.

(g) Stack testing shall be performed with the mechanical diversion damper positioned so that the
turbine exhaust gases are not diverted to the waste heat recovery.

II.B.2.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance. Stack testing was last conducted on Unit 1 on November 30, 2022. Test results were
submitted to DAQ and audited in DAQC-112-23. DAQ calculated results were as follows:

Emission Unit Test Date Pollutant Limit Results
Unit C1 November 30, 2022 NOx 8.35 lb/hr 5.98 lb/hr*

*Units wase tested at four loads. The highest result is listed.
Next test is due in 2027.

II.B.2.c Condition:

Emissions of NOx shall not be greater than the concentration calculated by the equation

STD = 0.0150 (14.4/Y) + F where

STD is the allowable NOx emission in percent by volume, dry, at 15 percent oxygen;
0.0150 is the base emission standard, in percent by volume;

Y is the ratio of fuel consumption (in kJ/hr) over output power (in watts), with Y not to exceed 14.4
(dimensionless); and

17
F is an allowance for the fuel bound nitrogen as determined by the following table:

Fuel bound nitrogen, N, wt% F, NOx percent by volume
N<0.015 0
0.015<N<=0.1 0.04N
0.1<N<=0.25 0.004 + 0.0067(N-0.1)
N>0.25 0.005.

[Origin: 40 CFR 60 Subpart GG; Authority 40 CFR 60.332].

II.B.2.c.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. The source shall be tested every five years, based on the date of the most recent
stack test, using 40 CFR 60, Appendix A, Method 20or every two years with a portable testing
monitor. If a portable testing monitor is to be used, a correlation must be established during the
initial test between the portable testing monitor and Method 20. Subsequently, the portable testing
monitor results shall be correlated with the results of the periodic reference method test at least
once every five years. The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director. Testing protocol shall be approved by the
Director.

(c) Sample Point: The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 in accordance with 40 CFR 60.335(a)(4) and (5). In addition,
Occupational Safety and Health Administration (OSHA) approved access shall be provided to the
test location.

(d) Methods

(1) 40 CFR 60, Appendix A, Method 20, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the nitrogen oxides and oxygen
concentrations. The span values shall be 300 ppm of nitrogen oxide and 21 percent
oxygen;

(2) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine stack gas velocity and volumetric
flow rate;

(3) Fuel-bound nitrogen content (F) shall be assumed to be 0 wt%, in accordance with 40
CFR 60.332(a)(3);

(e) Calculations. The nitrogen oxides emission rate (NOx) shall be computed using 40 CFR
60.335(b)

(f) Production Rate during Testing. The operational rate during all compliance testing shall be no
less than 90% of the maximum rate achieved in the previous three (3) years.

18
(g) Stack testing shall be performed with the mechanical diversion damper positioned so that hte
turbine exhaust gases are not diverted to waste heat recovery. [40 CFR 60]

II.B.2.c.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision S.1 in Section I of this
permit. [40 CFR 60]

II.B.2.c.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance. Stack testing was last conducted on Unit 1 on November 30, 2022. Test results were
submitted to DAQ and audited in DAQC-112-23. DAQ calculated results were as follows:

Emission Unit Test Date Pollutant Limit Results
Unit C1 November 30, 2022 NOx 150 ppmdv 15.08 ppmdv*

*Units wase tested at four loads. The highest result is listed.
Next test is due in 2027.

II.B.3 Conditions on Natural Gas Turbine Compressors (C2 and C3).

II.B.3.a Condition:

Emissions of CO shall be no greater than 11.34 lb/hr for each turbine. [Origin: DAQE-AN125120008-15;
Authority: R307-401-8].

II.B.3.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Test every five years, based on the date of the most recent stack test, using 40 CFR
60, Appendix A, Method 10 or every two years with a portable testing monitor. If a portable
testing monitor is to be used, a correlation must be established during the initial test between the
portable testing monitor and Method 10. Subsequently, the portable testing monitor results shall
be correlated with the results of the periodic reference method test at least once every five years.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director. Testing protocol shall be approved by the
Director.

(c) The emission sample point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other methods as approved by the Director. An Occupational Safety and Health
Administration (OSHA) approved access shall be provided to the test location.

19
(d) Methods to be used:

(1) To determine stack volumetric flow rate: 40 CFR 60, Appendix A, Method 2, or
other EPA-approved testing method, as acceptable to the Director.

(2) To test for CO emissions: 40 CFR 60, Appendix A, Method10, or other EPA-
approved testing method, as acceptable to the Director. A portable testing monitor may
be used in lieu of the reference test method provided the requirements of (a) are met. If
the requirements of (a) are not met, the reference test method must be used for
subsequent tests.

(e) Calculations. To determine mass emission rates (lb/he, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and
any necessary conversion factors determined by the Director, to give the results in the specified
units of the emission limitation.

(f) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.

(g) Stack testing shall be performed with the mechanical diversion damper positioned so that the
turbine exhaust gases are not diverted to the waste heat recovery.

II.B.3.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation. [R307-405-8]

Status: In compliance. Stack testing was last conducted on Unit 2 on May 19, 2021. Test results were
submitted to DAQ and audited in DAQC-1265-21. Stack testing was last conducted on Unit 3 on
June 13, 2023. Test results were submitted to DAQ and audited in DAQC-944-23. DAQ calculated
results were as follows:

Emission Unit Test Date Pollutant Limit Results
Unit C2 May 19, 2021 CO 11.34 lb/hr 0.29 lb/hr*
Unit C3 June 13, 2023 CO 11.34 lb/hr 0.40 lb/hr*

*Both units were tested at four loads. The highest result is listed.
Next test due C2- 2026 and C3 – 2028.

II.B.3.b Condition:

Emissions of NOx shall be no greater than 9.31 lb/hr. for each turbine. [Origin: DAQE-AN125120008-15;
Authority: R307-403-8].

20
II.B.3.b.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Test every five years, based on the date of the most recent stack test, using 40 CFR
60, Appendix A, Method 20 or every two years with a portable testing monitor. If a portable
testing monitor is to be used, a correlation must be established during the initial test between the
portable testing monitor and Method 20. Subsequently, the portable testing monitor results shall
be correlated with the results of the periodic reference method test at least once every five years.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date.
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director. Testing protocol shall be approved by the
Director.

(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 in accordance with 40 CFR 60.335(a)(4) and (5). An Occupational Safety
and Health Administration (OSHA) approved access shall be provided to the test location.

(d) Methods to be used:

(1) To determine stack volumetric flow rate: 40 CFR 60, Appendix A, Method 2, or
other EPA-approved testing method, as acceptable to the Director.

(2) To test for NOx: 40 CFR 60, Appendix A Method 20, or other EPA-approved testing
method, as acceptable to the Director. A portable testing monitor may be used in lieu of
the reference test method provided the requirements of (a) are met. If the requirements of
(a) are not met, the reference test method must be used for subsequent tests.

(e) Calculations. The nitrogen oxides emission rate (NOx) shall be computed for each run using
40 CFR 60.335(b)

(f) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.

(g) Stack testing shall be performed with the mechanical diversion damper positioned so that the
turbine exhaust gases are not diverted to waste heat recovery.

II.B.3.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

21
II.B.3.b.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance. Stack testing was last conducted on Unit 2 on May 19, 2021. Test results were
submitted to DAQ and audited in DAQC-1265-21. Stack testing was last conducted on Unit 3 on
June 13, 2023. Test results were submitted to DAQ and audited in DAQC-944-23. DAQ calculated
results were as follows:

Emission Unit Test Date Pollutant Limit Results
Unit C2 May 19, 2021 NOx 9.31 lb/hr 6.61 lb/hr*
Unit C3 June 13, 2023 NOx 9.31 lb/hr 6.28 lb/hr*

*Both units were tested at four loads. The highest result is listed.
Next test due C2 - 2026 and C3 - 2028.

II.B.3.c Condition:

Emissions of NOx shall not be greater than the concentration calculated by the equation

STD = 0.0150 (14.4/Y) + F where

STD is the allowable NOx emission in percent by volume, dry, at 15 percent oxygen;
0.0150 is the base emission standard, in percent by volume;
Y is the ratio of fuel consumption (in kJ/hr) over output power (in watts), with Y not to exceed 14.4
(dimensionless); and

F is an allowance for the fuel bound nitrogen as determined by the following table:

Fuel bound nitrogen, N, wt% F, NOx percent by volume
N<0.015 0
0.015<N<=0.1 0.04N
0.1<N<=0.25 0.004 + 0.0067(N-0.1)
N>0.25 0.005.

[Origin: 40 CFR 60 Subpart GG; Authority 40 CFR 60.332].

II.B.3.c.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Test every five years, based on the date of the most recent stack test, using 40 CFR
60, Appendix A, Method 20 or every two years with a portable testing monitor. If a portable
testing monitor is to be used, a correlation must be established during the initial test between the
portable testing monitor and Method 20. Subsequently, the portable testing monitor results shall be
correlated with the results of the periodic reference method test at least once every five years. The
Directory may require testing at any time.
22
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director. Testing protocol shall be approved by the
Director.

(c) Sample Point: The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 in accordance with 40 CFR 60.335(a)(4) and (5). In addition, Occupational
Safety and Health Administration (OSHA) approved access shall be provided to the test location.

(d) Methods

(1) 40 CFR 60, Appendix A, Method 20, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the nitrogen oxides and oxygen
concentrations. The span values shall be 300 ppm of nitrogen oxide and 21 percent oxygen;

(2) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method as acceptable to
the Director, shall be used to determine stack gas velocity and volumetric flow rate;

(3) Fuel-bound nitrogen content (F) shall be assumed to be 0 wt%, in accordance with 40
CFR 60.332(a)(3);

(e) Calculations. The nitrogen oxides emission rate (NOx) shall be computed for each run using 40
CFR 60.335(b)

(f) Production Rate during Testing. The operational rate during all compliance testing shall be no
less than 90% of the maximum rate achieved in the previous three (3) years.

(g) Stack testing shall be performed with the mechanical diversion damper positioned so that the
turbine exhaust gases are not diverted to waste heat recovery. [40 CFR 60]

II.B.3.c.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. [40
CFR 60]

23
II.B.3.c.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation. [40 CFR 60]

Status: In compliance. Stack testing was last conducted on Unit 2 on May 19, 2021. Test results were
submitted to DAQ and audited in DAQC-1265-21. Stack testing was last conducted on Unit 3 on
June 13, 2023. Test results were submitted to DAQ and audited in DAQC-944-23. DAQ calculated
results were as follows:

Emission Unit Test Date Pollutant Limit Results____________
Unit C2 May 19, 2021 NOx ≤ 256 ppm @15% O2 23 ppm @15% O2*
Unit C3 June 13, 2023 NOx ≤ 150 ppm @15% O2 16.96 ppm @15% O2*

*Both units were tested at four loads. The highest result is listed.
Next test due C2 - 2026 and C3 - 2028.

II.B.4 Conditions on Emergency Backup Generator.

II.B.4.a Condition:

The permittee shall comply with the following operation limitations and other requirements at all times:

(1) The permittee shall operate the emergency generator according to the requirements in paragraphs
(1)(a) through (1)(c). To be considered an emergency stationary RICE, any operation other than
emergency operation, maintenance and testing, and operation in non-emergency situations for 50 hours
per year, as described in (1)(a) through (1)(c), is prohibited. If the engine is not operated in accordance
with paragraphs (1)(a) through (1)(c), it will not be considered an emergency engine and shall meet all
requirements for non-emergency engines.

(a) There is no time limit on the use of the emergency generator in emergency situations.
[40 CFR 63.6640(f)(1)]

(b) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state, or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine for a maximum of
100 hours per calendar year. The owner or operator may petition the Administrator for approval
of additional hours to be used for maintenance checks and readiness testing, but a petition is not
required if the owner or operator maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency RICE beyond 100 hour per calendar
year.

(c) The permittee may operate the affected emission unit up to 50 hours per year in non-
emergency situations, but those 50 hours are counted towards the 100 hour per year provided for
maintenance and testing and shall meet the requirements in 40 CFR 63.6640(f)(4).

(2) The permittee shall comply with the following operational requirements for the emergency generator
at all times, except during periods of startup:
24

(a) Change oil and filter every 500 hours of operation or annually, whichever comes
first.

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes
first, and replace as necessary.

(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever
comes first, and replace as necessary.

(d) The Permittee has the option of utilizing an oil analysis program in order to extend
the specified oil change requirement in accordance with 40 CFR 63.6625(j).

(3) During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed
30 minutes, after which time the non-startup emission limits apply.

(4) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.

[Origin: 40 CFR 63, Subpart ZZZZ; Authority: 40 CFR 63.6603, 40 CFR 63.6605, 40 CFR 63.6625(h),
40 CFR 63.6640(f), 40 CFR 636665, 40 CFR 63 Subpart ZZZZ, 40 CFR 63 Subpart ZZZZ].

II.B.4.a.1 Monitoring:

The permittee shall demonstrate continuous compliance by operating and maintaining the
emergency generator and after-treatment control device (if any) according to the
manufacturer's emission-related written operations and maintenance instructions or develop and
follow their own maintenance plan which must provide to the extent practicable for the
maintenance and operation of the engine in a manner consistent with good air pollution control
practice for minimizing emissions. [40 CFR 63.6625(e)]

The permittee shall install a non-resettable hour meter if one is not already installed. [40
CFR 63.6625(f)]

If the emergency generator is operating during an emergency and it is not possible to shut down
the engine in order to perform the management practice requirements on the schedule required in
Condition II.B.4.a(2), or if performing the management practice on the required schedule would
otherwise pose an unacceptable risk under federal, state or local law, the management practice
can be delayed until the emergency is over or the unacceptable risk under federal, state or local
law has abated. The management practice shall be performed as soon as practicable after the
emergency has ended or the unacceptable risk under federal, state or local law has abated.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.4.a.2 Recordkeeping:

The permittee shall keep the records described below for the emergency generator. [40
CFR 63.6655(a)]

25
A copy of each notification and report submitted to comply with 40 CFR 63, Subpart ZZZZ,
according to the requirement in 40 CFR 63.10(b)(2)(xiv). [40 CFR 63.6655(a)(1)]

Records of the occurrence and duration of each malfunction of operation (i.e., process equipment)
or the air pollution control and monitoring equipment. [40 CFR 63.6655(a)(2)]

Records of all required maintenance performed on the air pollution control and monitoring
equipment. [40 CFR 63.6655(a)(4)]

The permittee shall keep records of the hours of operation of the engine that is recorded through
the non-resettable hour meter. The permittee shall document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours
are spent for non-emergency operation. If the engine is used for the purposes specified in §
63.6640(f)(2)(ii) or (iii) or § 63.6640(f)(4)(ii), the owner or operator must keep records of the
notification of the emergency situation, and the date, start time, and end time of engine operation
for these purposes. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)(2)(i)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation (including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan). [40 CFR 63.6655(d)]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the emergency generator and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Section I.S.1 of this permit.

II.B.4.a.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the Federal, State or local law under which the risk was deemed unacceptable. [40
CFR 63, Subpart ZZZZ Table 2d Footnote 2]

The permittee shall also report each instance in which it did not meet the applicable requirements
in Table 8. [40 CFR 63.6640(e)]

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. Kern River appeared to have operated the emergency generator according to these
requirements. A non-resettable hour meter is installed. Records show 49.6 for 12-month period
ending April 30, 2024. 30-minute weekly maintenance runs are done by the operator.

26
II.B.4.b Condition:

At all times, the permittee shall operate and maintain the emergency generator, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by 40 CFR 63,
Subpart ZZZZ have been achieved. Determination of whether such operation and maintenance procedures
are being used will be based on information available to the Director which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63, Subpart ZZZZ; Authority:
40 CFR 63.6605(b)].

II.B.4.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.b.2 Recordkeeping:

Records of actions taken during periods of malfunction to minimize emissions in accordance with
40 CFR63.6605(b), including corrective actions to restore malfunctioning process and air
pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR
63.6655(a)(5)]

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Section I
of this permit.

II.B.4.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The permittee appeared to be operated and maintained in accordance with
good air pollution control practices. Subpart ZZZZ maintenance requirements have been
incorporated into the maintenance program. Maintenance is completed annually. The last
maintenance was done May 7, 2024, with oil changed and all other requirements met.

EMISSION INVENTORY: Taken from DAQ’s 2020 emissions inventory: (2023 inventory was submitted
April 11, 2024, and is listed as under review)

Pollutant Tons/yr
PM10 .................... 6.75
PM2.5 .................... 6.75
SO2 ...................... 0.24
NOx.................... 79.16
CO ..................... 10.47
VOC .................... 3.46

27
PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Kern River Gas Transmission Company should be found in compliance with
the conditions of the Title V permit at the time of this inspection. No further
action is recommended.

HPV STATUS: Not applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspector should contact the source prior to inspection as personnel are not
continually available at the site.

ATTACHMENT: VEO Form.