DAQ-2024-008058

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-467-24
Site ID 13031 (B5)

Tom Wiscomb, Senior Environmental Analyst
PacifiCorp
1407 West North Temple, Suite 310
Salt Lake City, Utah 84116

Dear Mr. Wiscomb:

Re: PacifiCorp Lake Side Plant – Pretest Protocol for Carbon Monoxide (CO), Oxygen (O2),
and Nitrogen Oxides (NOx) Relative Accuracy Tests with PM10 and VOC Source
Compliance Testing – Utah County

The Utah Division of Air Quality (DAQ) reviewed the pretest protocol for the PacifiCorp Lake Side
Plant dated May 1, 2024. The proposed test shall be performed under the following conditions:

Lake Side Plant’s monitoring systems to be certified:

Point Source Channel Manufacturer Model # Monitor SN
CTG11
CO TECO 48i 611416457
NOx TECO 42i 611416453
O2 Servomex 1440D 01440DIV02/3731
CTG12
CO TECO 48i 611416458
NOx TECO 42i 611416455
O2 Servomex 1440D 01440DIV02/3779
CTG21
CO TECO 48i 1231355641
NOx TECO 42i 1231355639
O2 Servomex 1440D 01440D1/4770
CTG22
CO TECO 48i 1231355642
NOx TECO 42i 1231355640
O2 Servomex 1440D 01440D1/4783

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DAQC-467-24
Page 2

Montrose Air Quality Services will conduct a relative accuracy/performance specification test on
the Lake Side Plant’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.

The DAQ understands that testing will be conducted as follows:

Test Date Point
Source Parameter EPA Reference Method
June 18, 2024,
through June 26,
2024
CTG11
CTG12
CTG21
CTG22
High Load Flow, O2, CO, and
NOx RATA, with VOC and
PM Compliance Testing
Method 1, 2, 3A, 4, 7E, 10,
25A, 201A, 202

• Reference Method 1 used to determine sample velocity traverses: OK
• Reference Method 2 used to determine stack gas velocity and volumetric flow
rate: OK

• 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 4 used to determine moisture content: OK

• 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 25A - Determination of Total Hydrocarbon Emissions from
Stationary Point Sources — (Flame Ionization Instrumental Procedure) as outlined
in 40 CFR 60 Appendix A.

• Reference Method 201A/202 - Determination PM10/PM2.5 and condensable
particulate emissions as outlined in 40 CFR 60 Appendix A.

• Zero drift and calibration drift checks are required at the beginning and end of each
run.

DAQC-467-24
Page 3

• 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.

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.
DAQC-467-24
Page 4

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

Sincerely,

Paul Morris, Environmental Scientist
Major Source Compliance Section

PM:rh

cc: Utah County Health Department
Montrose Air Quality Services
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Paul Morris