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HomeMy WebLinkAboutDAQ-2024-007398DAQC-329-24 Site ID 13031 (B4) MEMORANDUM TO: STACK TEST FILE – PACIFICORP – Lake Side Power Plant THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Paul Morris, Environmental Scientist DATE: April 10, 2024 Subject: Source: CTG11, CTG12, CTG21, and CTG22 Contact: Veronica Reyes – 801-796-1916 Location: 1825 North Pioneer Lane, Lindon, Utah County, UT Test Contractor: Montrose Air Quality Services FRS ID #: UT0000004904900241 Permit/AO#: Title V operating permit 4900241002 dated July 16, 2021 Subject: Review of Stack Test Protocol Dated April 10, 2024 On April 10, 2024, Utah Division of Air Quality (DAQ) received a protocol for testing of the PacifiCorp Lake Side Power Plant combustion turbines CTG11, CTG12, CTG21, and CTG22, in Vineyard, Utah. Testing will be performed on June 11-14, 2024, to determine compliance with Part 63 (40 CFR 63), Subpart YYYY. PROTOCOL CONDITIONS: 1. RM 3A used to determine dry molecular weight of the gas stream: OK 2. RM 320 used to determine formaldehyde emissions: OK DEVIATIONS: No deviations were noted. CONCLUSION: The protocol appears to be acceptable. RECOMMENDATION: Send attached protocol review and test date confirmation notice. 6 , 3 Source Test Plan for 2024 40 CFR Part 63, Subpart YYYY Compliance Testing CTG11, CTG12, CTG21 and CTG22 PacifiCorp Lake Side Power Plant Lindon, Utah Prepared For: PacifiCorp – Lake Side Power Plant 1825 N. Pioneer Lane Lindon, Utah Prepared By: Montrose Air Quality Services, LLC 990 West 43rd Avenue Denver, Colorado 80211 For Submission To: Utah Division of Air Quality 195 North, 1950 West Salt Lake City, Utah 84116 Document Number: GP043AS-039920-PP-829 Proposed Test Dates: June 11 th through 14th, 2024 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Review and Certification I certify that, to the best of my knowledge, the information contained in this document is complete and accurate and conforms to the requirements of the Montrose Quality Management System and ASTM D7036-04. Signature: Date:4/4/2024 Name:Matthew Parks Title: QA/QC Analyst I have reviewed, technically and editorially, details and other appropriate written materials contained herein. I hereby certify that to the best of my knowledge the presented material is authentic and accurate and conforms to the requirements of the Montrose Quality Management System and ASTM D7036-04. Signature: Date:4/4/2024 Name:Tim Wojtach Title: Account Manager GP043AS-039920-PP-829 Page 2 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Table of Contents Section Page 1.0 Introduction ...................................................................................................... 5 1.1 Summary of Test Program ........................................................................... 5 1.2 Applicable Regulations and Emission Limits .................................................... 6 1.3 Key Personnel ............................................................................................ 7 2.0 Plant and Sampling Location Descriptions .............................................................. 8 2.1 Process Description, Operation, and Control Equipment ................................... 8 2.2 Flue Gas Sampling Locations ........................................................................ 8 2.3 Operating Conditions and Process Data .......................................................... 8 2.5 Plant Safety ............................................................................................... 9 2.5.1 Safety Responsibilities ........................................................................ 9 2.5.2 Safety Program and Requirements ...................................................... 10 3.0 Sampling and Analytical Procedures ..................................................................... 11 3.1 Test Methods ............................................................................................ 11 3.1.1 EPA Method 3A ................................................................................. 11 3.1.2 EPA Method 320/ASTM D6348 ............................................................ 12 4.0 Quality Assurance and Reporting ......................................................................... 14 4.1 QA Audits ................................................................................................. 14 4.2 Quality Control Procedures .......................................................................... 14 4.2.1 Equipment Inspection and Maintenance ............................................... 14 4.2.2 Audit Samples .................................................................................. 14 4.3 Data Analysis and Validation ....................................................................... 14 4.4 Sample Identification and Custody ............................................................... 15 4.5 Quality Statement ..................................................................................... 15 4.6 Reporting................................................................................................. 15 4.6.1 Example Report Format ..................................................................... 15 4.6.2 Example Presentation of Test Results ................................................... 16 GP043AS-039920-PP-829 Page 3 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol List of Appendices A Supporting Information ..................................................................................... 18 A.1 Units and Abbreviations ............................................................................. 19 A.2 Accreditation Information/Certifications ....................................................... 2 “S” Field Work Safety Plan...................................................................................... List of Tables 1-1 Summary of Test Program and Proposed Schedule ................................................ 5 1-2 Reporting Units and Emission Limits .................................................................... 6 1-3 Test Personnel and Responsibilities ...................................................................... 7 2-1 Sampling Locations ........................................................................................... 8 4-1 Example Emissions Results ................................................................................ 17 List of Figures 3-1 EPA Method 3A and FTIR Sampling Train ............................................................. 12 4-1 Typical Report Format ...................................................................................... 16 GP043AS-039920-PP-829 Page 4 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 1.0 Introduction 1.1 Summary of Test Program PacifiCorp contracted Montrose Air Quality Services, LLC (Montrose) to perform emission test programs on Combustion Turbine CTG11, CTG12, CTG21, and CTG22 exhaust stacks located at PacifiCorp’s Lake Side Power Plant located in Lindon, Utah. The purpose of the test programs will be to determine the concentrations of formaldehyde (CH2O). Testing will be performed in order to demonstrate compliance with the published standard of 91 parts per billion by volume dry basis (ppbv db) @ 15% O2 from the Code of Federal Regulations, Title 40, Part 63 (40 CFR 63), Subpart YYYY – National Emission Standard for Hazardous Air Pollutants for Stationary Combustion Turbines. The specific objectives are to: Determine the concentrations of CH2O on CTG11, CTG12, CTG21, and CTG22 Conduct the test program with a focus on safety Montrose will provide the test personnel and the necessary equipment to measure emissions as outlined in this test plan. Facility personnel will provide the process and production data to be included in the final report. A summary of the test program and proposed schedule is presented in Table 1-1. Table 1-1 Summary of Test Program and Proposed Schedule Proposed Test Dates Unit ID Activity/ Parameters Test Methods No. of Runs Duration (Minutes) 6/11/2024 CTG12 O2 EPA 3A 3 60 CH2O, H2O EPA 320 6/12/2024 CTG11 O2 EPA 3A 3 60CH2O, H2O EPA 320 6/13/2024 CTG22 O2 EPA 3A 3 60CH2O, H2O EPA 320 6/14/2024 CTG21 O2 EPA 3A 3 60CH2O, H2O EPA 320 To simplify this test plan, a list of Units and Abbreviations is included in Appendix A. Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not defined. Please refer to the list for specific details. GP043AS-039920-PP-829 Page 5 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 1.2 Applicable Regulations and Emission Limits The results from this test program are presented in units consistent with those listed in the applicable regulations or requirements. The reporting units and emission limits are presented in Table 1-2. Table 1-2 Reporting Units and Emission Limits Parameter Reporting Units Emission Limit Emission Limit Reference CH2O ppbvd @ 15% O2 91 ppbv db @ 15% O2 40 CFR 63, Subpart YYYY GP043AS-039920-PP-829 Page 6 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 1.3 Key Personnel A list of project participants is included below: Facility Information Source Location: PacifiCorp Lake Side Power Plant 1825 N. Pioneer Lane Lindon, Utah 84024 Project Contact: Tom Wiscomb Veronica Reyes Role: Environmental Advisor Environmental Analyst Telephone: 801-220-2373 801-796-1916 Email: Tom.Wiscomb@PacifiCorp.com Veronica.Reyes@PacifiCorp.com Agency Information Regulatory Agency: Utah Division of Air Quality Agency Contact: Paul Morris Telephone: 801-536-4165 Email: pfmorris@utah.gov Testing Company Information Testing Firm: Montrose Air Quality Services, LLC Contact: Craig Kormylo Title: District Manager Telephone: 303-810-2849 Email: CKormylo@montrose-env.com Table 1-3 details the roles and responsibilities of the test team. Table 1-3 Test Personnel and Responsibilities Role Primary Assignment Additional Responsibilities Account/Client Project Manager Coordinate Project Post-test follow up Client/Field Project Manager Operate mobile lab Facility interface, test crew coordination Field Technician Execute stack platform responsibilities Preparation, support PM GP043AS-039920-PP-829 Page 7 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 2.0 Plant and Sampling Location Descriptions 2.1 Process Description, Operation, and Control Equipment The Lake Side Power Plant comprises four combined-cycle combustion turbines designated CTG11, CTG12, CTG21 and CTG22. In accordance with 40 CFR 63, Subpart YYYY, formaldehyde emissions from the gas turbine generator exhaust stacks are the subject of this test protocol. 2.2 Flue Gas Sampling Locations Actual stack measurements, number of traverse points, and location of traverse points will be evaluated in the field as part of the test program. Table 2-1 presents the anticipated stack measurements and traverse points for the sampling locations listed. Table 2-1 Sampling Locations Sampling Location Stack Inside Diameter (in.) Distance from Nearest Disturbance Anticipated Number of Traverse Points Downstream EPA “B” (in./dia.) Upstream EPA “A” (in./dia.) CTG11 216 ~576/~2.7 ~120/~0.6 Gaseous: 3 CTG12 216 ~576/~2.7 ~120/~0.6 Gaseous: 3 CTG21 216 ~576/~2.7 ~120/~0.6 Gaseous: 3 CTG22 216 ~576/~2.7 ~120/~0.6 Gaseous: 3 2.3 Operating Conditions and Process Data Emission tests are performed while the source/units and air pollution control devices are operating within 10 percent of 100 percent load, per 40 CFR Part 63, Subpart YYYY, §63.6120.c and Table 3. Plant personnel are responsible for establishing the test conditions and collecting all applicable unit-operating data. Data collected includes the following parameters: Unit load, MW Natural gas flow rate, scfh GP043AS-039920-PP-829 Page 8 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 2.5 Plant Safety Montrose will comply with all safety requirements at the facility. The facility Client Sponsor, or designated point of contact, is responsible for ensuring routine compliance with plant entry, health, and safety requirements. The Client Sponsor has the authority to impose or waive facility restrictions. The Montrose test team leader has the authority to negotiate any deviations from the facility restrictions with the Client Sponsor. Any deviations must be documented. 2.5.1 Safety Responsibilities Planning Montrose must complete a field review with the Client Sponsor prior to the project date. The purpose of the review is to develop a scope of work that identifies the conditions, equipment, methods, and physical locations that will be utilized along with any policies or procedures that will affect our work We must reach an agreement on the proper use of client emergency services and ensure that proper response personnel are available, as needed The potential for chemical exposure and actions to be taken in case of exposure must be communicated to Montrose. This information must include expected concentrations of the chemicals and the equipment used to identify the substances. Montrose will provide a list of equipment being brought to the site, if required by the client Project Day Montrose personnel will arrive with the appropriate training and credentials for the activities they will be performing and the equipment that they will operate Our team will meet daily to review the Project Scope, Job Hazard Assessment, and Work Permits. The Client Sponsor and Operations Team are invited to participate. Montrose will provide equipment that can interface with the client utilities previously identified in the planning phase and only work with equipment that our client has made ready and prepared for connection We will follow client direction regarding driving safety, safe work permitting, staging of equipment, and other crafts or work in the area As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the following provisions at each sample location: o Sampling ports, which meet EPA minimum requirements for testing. The caps should be removed or be hand-tight. o Safe sampling platforms GP043AS-039920-PP-829 Page 9 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol o Safe access to the platforms and test ports, including any scaffolding or man lifts o Sufficient utilities to perform all necessary testing Montrose will use the client communication system, as directed, in case of plant or project emergency Any adverse conditions, unplanned shutdowns or other deviations to the agreed scope and project plan must be reviewed with the Client Sponsor prior to continuing work. This will include any safe work permit and hazard assessment updates. Completion Montrose personnel will report any process concerns, incidents or near misses to the Client Sponsor prior to leaving the site Montrose will clean up our work area to the same condition as it was prior to our arrival We will ensure that all utilities, connection points or equipment have been returned to the pre-project condition or as stated in the safe work permit. In addition, we will walk out the job completion with Operations and the Client Sponsor if required by the facility. 2.5.2 Safety Program and Requirements Montrose has a comprehensive health and safety program that satisfies State and Federal OSHA requirements. The program includes an Illness and Injury Prevention Program, site- specific safety meetings, and training in safety awareness and procedures. The basic elements include: All regulatory required policies/procedures and training for OSHA, EPA and FMCSA Medical monitoring, as necessary Use of Personal Protective Equipment (PPE) and chemical detection equipment Hazard communication Pre-test and daily toolbox meetings Continued evaluation of work and potential hazards Near-miss and incident reporting procedures as required by Montrose and the Client Montrose will provide standard PPE to employees. The PPE will include but is not limited to; hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand protections, and fall protection. In addition, our trailers are equipped with four gas detectors to ensure that workspace has no unexpected equipment leaks or other ambient hazards. The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”. GP043AS-039920-PP-829 Page 10 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 3.0 Sampling and Analytical Procedures 3.1 Test Methods The test methods for this test program have been presented in Table 1-1. Additional information regarding specific applications or modifications to standard procedures is presented below. 3.1.1 EPA Method 3A – Determination of Oxygen Concentrations in Emissions from Stationary Sources (Instrumental Analyzer Procedure) EPA Method 3A is an instrumental test method used to measure the concentration of O2 in stack gas. The effluent gas is continuously or intermittently sampled and conveyed to an analyzer that measures the concentration of O2. The performance requirements of the method must be met to validate data. Pertinent information regarding the performance of the method is presented below: o An extractive sampling system will be used to determine concentrations o A paramagnetic analyzer may be used to measure O2 on a dry volume basis o A zirconium oxide analyzer may be used to measure O2 on a wet volume basis o Minimum Required Sample Duration: 60 minutes A typical sampling system is presented in Figure 3-1. GP043AS-039920-PP-829 Page 11 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Figure 3-1 EPA Method 3A and FTIR Sampling Train HEATED SAMPLE LINE DAS O2 AND/OR CO2 ANALYZER Exhaust SIGNAL Sample / Calibration Gas DATA OUTPUT SAMPLE CONDITIONING SYSTEM WITH PUMP CALIBRATION GAS LINE "SAMPLE” AND “BY-PASS" ROTAMETERS WITH FLOW CONTROL VALVES THREE WAY VALVE BY-PASS “BIAS” ROTAMETER WITH FLOW CONTROL VALVE STACK GAS STACK WALL HEATED SAMPLE LINE HEATED FILTER “ANALYZER” ROTAMETERS WITH FLOW CONTROL VALVES EPA Protocol Calibration Gases MASS FLOW CONTROLLER / CALIBRATION GAS MANIFOLD SAMPLE PROBE SIGNAL FTIR Sample / Calibration Gas Exhaust Heated pump and filter 3.1.2 EPA Method 320/ASTM D6348 – Measurement of Vapor Phase Organic and Inorganic Emissions by Extractive FTIR Spectroscopy Procedures found in EPA Method 320/ASTM D6348 will be used to measure specific analyte concentrations for which EPA reference spectra have been developed or prepared. Extractive emission measurements are performed using FTIR spectroscopy. The FTIR analyzer is composed of a spectrometer and detector, a high optical throughput sampling cell, analysis software, and a quantitative spectral library. The analyzer collects high resolution spectra in the mid infrared spectral region (400 to 4,000 cm-1), which are analyzed using the quantitative spectral library. This provides an accurate, highly sensitive measurement of gases and vapors. Pertinent information regarding the performance of the method is presented below: o The specific analyte concentrations include H2O and formaldehyde GP043AS-039920-PP-829 Page 12 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol o Continuous static sampling is performed at a flow rate of approximately 6 liters per minute o A dynamic matrix spike is performed using a formaldehyde and nitrous oxide (tracer) calibration gas o Formaldehyde sampling will be performed utilizing an MKS model 2030 FTIR analyzer equipped with MAX Starboost Techology in order to achieve the low- level detection limits (~10-15 ppbvd) required to provide the confidence in the low-level measurements for this program o Minimum Required Sample Duration: 60 minutes A typical sampling system is presented in Figure 3-1. GP043AS-039920-PP-829 Page 13 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 4.0 Quality Assurance and Reporting 4.1 QA Audits Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality assurance audits are performed as part of the test program to ensure that the results are calculated using the highest quality data available. This program ensures that the emissions data we report are as accurate as possible. The procedures included in the cited reference methods are followed during preparation, sampling, calibration, and analysis. Montrose is responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose will also perform the sampling, sample recovery, storage, and shipping. Approved contract laboratories may perform some of the preparation and sample analyses, as needed. 4.2 Quality Control Procedures Montrose calibrates and maintains equipment as required by the methods performed and applicable regulatory guidance. Montrose follows internal procedures to prevent the use of malfunctioning or inoperable equipment in test programs. All equipment is operated by trained personnel. Any incidence of nonconforming work encountered during testing is reported and addressed through the corrective action system. 4.2.1 Equipment Inspection and Maintenance Each piece of field equipment that requires calibration is assigned a unique identification number to allow tracking of its calibration history. All field equipment is visually inspected prior to testing and includes pre-test calibration checks as required by the test method or regulatory agency. 4.2.2 Audit Samples When required by the test method and available, Montrose obtains EPA TNI SSAS audit samples from an accredited provider for analysis along with the samples. Currently, the SSAS program has been suspended pending the availability of a second accredited audit sample provider. If the program is reinstated, the audit samples will be ordered. If required as part of the test program, the audit samples are stored, shipped, and analyzed along with the emissions samples collected during the test program. The audit sample results are reported along with the emissions sample results. 4.3 Data Analysis and Validation Montrose converts the raw field, laboratory, and process data to reporting units consistent with the permit or subpart. Calculations are made using proprietary computer spreadsheets or data acquisition systems. One run of each test method is also verified using a separate example calculation. The example calculations are checked against the spreadsheet results and are included in the final report. The “Standard Conditions” for this project are 29.92 inches of mercury and 68 °F. GP043AS-039920-PP-829 Page 14 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol 4.4 Sample Identification and Custody No samples are anticipated to be collected for this test program. 4.5 Quality Statement Montrose is qualified to conduct this test program and has established a quality management system that led to accreditation with ASTM Standard D7036-04 (Standard Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual functional assessments for conformance with D7036-04 which are conducted by the American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04 Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the documented limits in the test methods are met by using approved test protocols for each project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance information is included in the appendices. The content of this test plan is modeled after the EPA Emission Measurement Center Guideline Document (GD-042). 4.6 Reporting Montrose will prepare a final report to present the test data, calculations/equations, descriptions, and results. Prior to release by Montrose, each report is reviewed and certified by the project manager and their supervisor, or a peer. Source test reports will be submitted to the facility or appropriate regulatory agency (upon customer approval) within 60 days of the completion of the field work. The report will include a series of appendices to present copies of the intermediate calculations and example calculations, raw field data, laboratory analysis data, process data, and equipment calibration data. 4.6.1 Example Report Format The report is divided into various sections describing the different aspects of the source testing program. Figure 4-1 presents a typical Table of Contents for the final report. GP043AS-039920-PP-829 Page 15 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Figure 4-1 Typical Report Format Cover Page Certification of Report Table of Contents Section 1.0 Introduction 2.0 Plant and Sampling Location Descriptions 3.0 Sampling and Analytical Procedures 4.0 Test Discussion and Results 5.0 Internal QA/QC Activities Appendices A Field Data and Calculations B Facility CEMS and Process Data C Laboratory Analysis Data D Quality Assurance/Quality Control E Regulatory Information 4.6.2 Example Presentation of Test Results Table 4-1 presents the typical tabular format that is used to summarize the compliance results in the final source test report. Separate tables will outline the results for each target analyte and compare them to their respective emissions limits. GP043AS-039920-PP-829 Page 16 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Table 4-1 Example Emissions Results Parameter/Units Run 1 Run 2 Run 3 Average Date XX XX XX XX Time XX XX XX XX Process Data Unit Load, MW XX XX XX XX Natural Gas Flow Rate, scfh XX XX XX XX Sampling & Flue Gas Parameters O2, % volume dry XX XX XX XX Formaldehyde ppbvd@15%O2 XX XX XX XX GP043AS-039920-PP-829 Page 17 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Appendix A Supporting Information GP043AS-039920-PP-829 Page 18 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Appendix A.1 Units and Abbreviations GP043AS-039920-PP-829 Page 19 of 43 GP043AS-039920-PP-829 Page 20 of 43 GP043AS-039920-PP-829 Page 21 of 43 GP043AS-039920-PP-829 Page 22 of 43 GP043AS-039920-PP-829 Page 23 of 43 GP043AS-039920-PP-829 Page 24 of 43 GP043AS-039920-PP-829 Page 25 of 43 GP043AS-039920-PP-829 Page 26 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Appendix A.2 Accreditation Information/Certifications GP043AS-039920-PP-829 Page 27 of 43 Accredited Air Emission Testing Body A2LA has accredited MONTROSE AIR QUALITY SERVICES In recognition of the successful completion of the joint A2LA and Stack Testing Accreditation Council (STAC) evaluation process, this laboratory is accredited to perform testing activities in compliance with ASTM D7036:2004 - Standard Practice for Competence of Air Emission Testing Bodies. Presented this 27th day of February 2024. _______________________ Vice President, Accreditation Services For the Accreditation Council Certificate Number 3925.01 Valid to February 28, 2026 This accreditation program is not included under the A2LA ILAC Mutual Recognition Arrangement. American Association for Laborator y Accreditation GP043AS-039920-PP-829 Page 28 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol Appendix “S” Field Work Safety Plan GP043AS-039920-PP-829 Page 29 of 43 SITE SAFETY PLAN BOOKLET Project: _____________________ Customer: ___________________ Location: ____________________ Units: _______________________ Client Project Manager: ______________________ Revision Date:January 21, 2022 GP043AS-039920-PP-829 Page 30 of 43 Page 1 of 2 Site Safety Plan and JHA Purpose and Instructions Purpose Employee safety is the top priority of Montrose Environmental Group. All employees must be trained to assess and mitigate hazards. The District Manager and Project Manager are responsible to ensure all hazards have been properly identified and managed. All employees have Stop Work Authority in all situations where an employee feels they or their co-worker cannot perform a job safely or if there is a task for which they have not been adequately trained. The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with identifying physical and health hazards and determining how the hazards will be managed. Additionally, the SSP will help each crew manage the safety of the employees by providing emergency procedures and information. The booklet contains a several safety forms that may be required in the field. Instructions The SSP consists of the following: communicated to all employees, signed, and posted. Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed, CPM will maintain a roster and be responsible for accounting for all employees. The Job to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/ emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior the Emergency Action Plan form and ensure that all employees are familiar with the facility 4. Emergency Action Plan -The Job Supervisor/ Client Project Manager (CPM) will complete observed plus applicable PPE that may be required. administrative controls that a crew can use to reduce or eliminate the hazards they have 3. Hazard Control Matrix - contains useful information on both engineering and with the toolbox topic and signatures can be added to the SSP packet. the hazard analysis is required daily for the duration of the test. An additional sheet of paper modified when conditions change. A toolbox meeting with a daily topic in addition to a review of sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be Each team member has the option to discuss making changes or adding to the JHA and must Section 9 will require at least three tasks, hazards and controls be identified for the project. form for accuracy, making any corrections required and complete the remainder of the JHA. complete the JHA form through section 8. Upon arrival at the test site, the team will review the daily hazard review with sign off by the team. The client Project Manager is responsible to and controls. The form also includes a daily toolbox topic and 2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the prior to the test. 1. A Pre-Mobilization Test Plan AQS-FRM-1.13R1 Extended Hours Formc. Heat Stress Prevention Form Based on Heat Indexb. MEWP Lift Inspection Forma. Additional Forms, as applicable5. GP043AS-039920-PP-829 Page 31 of 43 Page 2 of 2 Site Safety Plan and JHA Purpose and Instructions The SSP is a living document. The Project Manager should continually update their SSPs as new information and conditions change or if new hazards are presented. Each completed SSP should be maintained with the Test Plan in the office for a period of 3 years. There will be an audit process developed for the Site Safety Plans. AQS-FRM-1.13R1 GP043AS-039920-PP-829 Page 32 of 43 Page 1 of 2 PRE-MOBILIZATION TEST INFORMATION Source Type: New Source: ____ Revisit: ____ Prj#/Date/Tech: __________________________ Coal Fired Electric Utility: ____ Ethanol Plant: ____ Chemical Mfg. of _________________________ Cement/Lime Kiln Plant: ____ Specialty Mfg. of: ___________ Other: _______________ Anticipated Effluent Composition check all that apply and fill in expected concentration in ppm/% CO NOX SO2 VOC other If other, explain: _______________________________________________________ Flammable: _______ Toxic: ________ Corrosive: _______ Dust: __________ Engineering Controls to be Implemented: ______________________________________________________________________________________ __________________________________________________________________________________ Additional Safety Equipment Required: Personal gas monitors: ____ Respiratory Protection: Half Face____ Full Face____ HEPA Filters____ Supplied Air: _____ (Safety Dept. Approval) Approximate Flue Gas Temperatures, (F) below 210 210 to 450 450 to 950 above 950 other If other, explain: _______________________________________________________ Approximate Duct Pressure, (iwg): below -3 -3 to +3 +3 to +7 above +7 other If other, explain: _______________________________________________________ PROJECT NAME/LOCATION: ______________________ PROJECT #: ____________________ TEST DATE: ______________________ PROJECT MANAGER: ___________________ TEST SCOPE: _________________________________________________________________ SITE CONTACT: Name: _____________________ Contact Phone: _________________________ AQS-FRM-1.17 GP043AS-039920-PP-829 Page 33 of 43 Page 2 of 2 PRE-MOBILIZATION TEST INFORMATION Sampling Location: Stack Port ____ Duct Port ____ Approximate Sampling Platform Height, (ft) Effluent Chemical Regulatory Limits Gas Name Chemical Formula Cal OSHA PEL1 (ppm) Cal OSHA STEL2 (ppm) NIOSH REL TWA3 (ppm) Cal OSHA Ceiling (ppm) IDLH4 (ppm) Carbon Monoxide CO 25 200 35 200 1,200 Nitric Oxide NOx 25 ND5 25 ND 100 Sulfur Dioxide SO2 2 5 2 ND 100 Hydrogen Chloride HCl 0.3 2 ND 2 50 Hydrogen Sulfide H2S 10 15 10 (10 min.)C 50 100 1: California Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) based on an 8 -hour shift; 2: Cal OSHA Short-term Exposure Limit (STEL) based on a 15-minute period; 3: National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based on an 8-hour shift; 4: Immediately Dangerous to Life or Health (IDLH); 5: Not Defined (ND); C: Ceiling Limit - Maximum allowable human exposure limit for an airborne or gaseous substance, which is not to be exceeded, even momentarily. Prepared by: Date: Reviewed by: Date: ______________________________________________________________________________ ______________________________________________________________________________ Additional Information: ______________________________________________________________________________ ______________________________________________________________________________ Describe how equipment will be mobilized to the sampling location: Other:_____________________________________________________________________________ Guardrails: ____ Toe plate: ____ Engineered Tie Off Points: ____ Heat Shield: ____ Elevators: ____ Ladders: ____ MEWP Lift: ____ Scaffold: ____ Equipment Hoist: ____ Access and Protection: If other, explain: _______________________________________________________ below 6 6 to 50 50 to 100 above 100 other AQS-FRM-1.17 GP043AS-039920-PP-829 Page 34 of 43 Job Hazard Analysis 1 of 3 1. Client Rep Job Preparation Job Site Walk Through Completed Site Specific Training Complete Safe Work Permit Received from Client 2. Facility Information/Emergency Preparedness If non-emergency medical attention is needed, call: AXIOM #: 877-502-9466. Plant Emergency # Certified First Aid Person: EMS Location Evacuation Routes Rally Point Severe Weather Shelter Location Eye Wash & Safety Shower Location Operational: Yes No Source Information: (list type): Stack Gas Temp. (oF)Stack Gas Press. ("H2O)Stack Gas Components: Stack Gas Inhalation Potential?Yes No If yes, see List of Hazard Chemicals. 3. Error Risk Time Pressure Remote Work Location > 12 hr shift Working > 8 consecutive days Lack of procedures Extreme temps, wind >30mph Personal illness/fatigue Vague work guidance Monotonous Activity First day back after time off Multiple job locations Other: 4. Physical Hazards Hazard Controls Dust Hazards Dust Mask Goggles Other: Thermal Burn Hot Gloves Heat Shields Other Protective Clothing: Electrical Hazards Connections Protected from Elements External GFCI Other: XP Rating Requirement Intrinsically Safe Requirement Inadequate Lighting Install Temporary Lighting Headlamps Slip and Trip Housekeeping Barricade Area Other: Hand Protection Cut Resistant Gloves Pinch Pts. General Electrical Impact Resistant Other: Potential Hazards for Consideration Secondary Permits Hot Work Confined Space Excavation Working from Heights Falling objects Fall protection Drop zone protection Platform load ratings See also Sect. 7 Scaffold inspection Ladder inspection Barricades for equipment Electrical Exposed wire/connector Verify equipment grounding Arc Flash Lifting Crane lift plan Rigging inspection Tag lines used Hoists in place Respiratory Unexpected exposure Chemical Dust (combustible) PEL provided See also Sect. 8 Cartridges or supplied air available Gas detection equipment 5. Required PPE Hard Hats Safety Glasses Safety Toe Shoe/Boot Hearing Protection Safety Spotter Hi-Vis Vests Harness/Lanyard*Goggles Personal Monitor Type: Metatarsal Guards Hot Gloves Face Shield Respirator Type: Nomex/FRC Other PPE: Client Contact Name Date Facility SSP Writer PM If the heat index is expected to be above 91°, fill out the Heat Stress Prevention Form. All hazards and mitigation steps must be documented. If this JHA does not cover all the hazards identified, use Section 9 to document that information. AQS-FRM-1.18 GP043AS-039920-PP-829 Page 35 of 43 Job Hazard Analysis 2 of 3 Additional Work Place Hazards 6.Critical Procedures *indicates additional form must be completed or collected from client Heat Stress Prevention* Confined Space* Roof Work Scaffold Cold Weather Work Hazardous Energy Control* Other: 7. Working From Heights Fall Protection Fixed Guardrails/Toe boards Fall Prevention PPE Warning Line System Falling Objects Protection Barricading Netting House Keeping Tethered Tools Catch Blanket or Tarp Fall Hazard Communication Adjacent/Overhead Workers Contractor Contact Client Contact 8.Other Considerations Environmental Hazards - Weather Forecast Heat/Cold Lightning Rain Snow Ice Tornado Wind Speed Steps for Mitigation: Electrical Safety Planning Plant Hook up: 110V 220/240V 480V Generator Hard wired into panel Electrical Classified Area: Yes No Trailer Grounded: Yes No Plug Type Electrical Hook Up Responsibility: List of Hazardous Chemicals Other Chemicals: Acetone Nitric Acid Hydrogen Peroxide Compressed Gases Hexane Sulfuric Acid Isopropyl Alcohol Flammable Gas Toluene Hydrochloric Acid Liquid Nitrogen Non-Flammable Gas H2S Carbon Monoxide Steps for Mitigation: Wildlife/Fauna in Area Poison Ivy Poison Oak Insects: Wildlife: Personnel w/ known allergies to bees stings or other allergens?Yes No 9. Observed Hazards and Mitigation Steps Task Potential Hazard(s)Steps for Mitigation 1 1 2 2 3 3 1 1 2 2 3 3 1 1 2 2 3 3 1 1 2 2 3 3 Exposure Monitoring MEWP* AQS-FRM-1.18 GP043AS-039920-PP-829 Page 36 of 43 Job Hazard Analysis 3 of 3 10.JHA REVIEW: Crew Names & Signatures 11.Daily JHA Meeting & Review Items to review: Change in conditions New workers or contractors Printed Name Signature 2 Discussion TopicDay Initialing demonstrates that site conditions and hazards have not changed from the original SSP. If changes did occur, make the necessary updates to this JHA and add notes as applicable in Section 9. Initials 9 8 7 6 3 Date Printed Name Signature Date 5 4 11 10 AQS-FRM-1.18 GP043AS-039920-PP-829 Page 37 of 43 1 2 3 4 5 6 Local Hospital/ Clinic Telephone Number: 7 8 9 10 11 12 13 14 15 16 17 MEG Job Supervisor/ CPM's Telephone Number: Plant's #1 Contact Person's Name: Plant's #1 Contact Person's Telephone Number: MEG Job Safety Supervisor's Telephone Number: Plant's Emergency Telephone Number: Emergency Ops Radio Channel: The Fire Extinguisher is Located: Eye Wash and Safety Shower Location: The First Aid Kit is Located: Page 1 of 2 The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, and posted. CALL 911 IMMEDIATELLY If non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466. EMERGENCY ACTION PLAN FORM MEG Job Supervisor/ CPM's Name: MEG Job Safety Supervisor (if applicable): Evacuation Routes: Severe Weather Shelter Location: Plant's #2 Contact Person's Name: Plant's #2 Contact Person's Telephone Number: Designated Assembly Point Location: AQS-FRM-1.11 GP043AS-039920-PP-829 Page 38 of 43 1 2 4 5 Signature: Date: Printed Name: Signature: Date: EVACUATE:____________________________________; OTHER:_______________________________________; Alarm Tones: EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures Printed Name: Draw the evacuation and assembly map here Page 2 of 2 EMERGENCY EVACUATION AND ASSEMBLY MAP 3 Designated Shelter(s) Description: Designated Assembly Point(s) Description: YES or NO Facility Name: Facility Alarm (Circle): FIRE:_________________________________________; CHEMICAL/ GAS:_______________________________; SHELTER-IN-PLACE:_____________________________; AQS-FRM-1.11 GP043AS-039920-PP-829 Page 39 of 43 Serial Number: Make: Rented or Owned: Check if an item is adequate, operational, and safe. Yes No N/A 2. Hydraulic fluid level is sufficient, with the platform fully lowered 3. Hydraulic system pressure (see manufacturer specs) is acceptable. If the pressure is low, determine cause and repair in accordance with accepted procedures as outlined in service manual. 4. Tires and wheel lug nuts (for tightness) 5. Hoses and cables (i.e. worn areas or chafing) 6. Platform rails and safety gate (no damage present) 7. Pivot pins secure 8. Welds are not cracked and structural members are not bent or broken 9. Warning and instructional labels are legible and secure, and load capacity is clearly marked. 10 11. Base controls (switches and push buttons) can be properly operated 12. Platform conditions are safe (i.e. not slippery) 13. Fire extinguisher is present, mounted and fully charged, located inside the bucket 14. Headlights, safety strobe light and back-up alarm are functional 15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds, etc.) *Do not operate if winds are 20 mph, unless otherwise specified by manufacturer recommendations. Operator Name & Signature Location Date Ground Control Name & Signature Location Date Harness Inspections: Printed Name Signature Date Printed Name Signature Date Printed Name Signature Date Daily MEWP Lift Inspection Form Page 1 of 1 atthe beginning of each shift or following 6 to 8 hours of use. All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used MEWP Lift Model #: loose hoses, etc.)if something can be easily loosened by hand then it is not sufficient. 1.All MEWP lift components are in working condition (i.e. no loose or missing parts, torn or Items to be Inspected AQS-FRM-1.16 GP043AS-039920-PP-829 Page 40 of 43 Page 1 of 1 001AS-SAFETY-FM-3 Extended Hours Safety Audit Project Number: Date: Time: When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate the condition of the crew, and the safety of the work environment. Permission to proceed into extended work hours must come from a District Manager (DM) or Regional Vice President (RVP). Technical RVPs can authorize moving forward, if they are in the field or if they are managing the project. 1.Hold test crew meeting Test crew initials: The test leader should look for signs of the following in their crews: Irritability Lack of motivation Headaches Giddiness Fatigue Depression Reduced alertness, lack of concentration and memory The test leader should assess the environmental and hazardous concerns: Temperature and weather Lighting Working from Heights Hoisting PPE (i.e. respirators, etc.) Pollutant concentration in ambient air (SO2, H2S, ect.) Reason for extended hours Reason for delay Production limitations Impending Weather 3.Contact the client The PM, DM or RVP must discuss with client any identified safety concerns, the needs and mutually agree on how to proceed. Discussion should also include the appropriate rest period needed shift can begin. The DM and/or a RVP must be informed on the final decision. Final Outcome: Approver: During this time, they can come to an agreement on how to proceed. Itemsto discuss include: extended work period. If the DM is the acting PM on the job site, they must contact the RVP. The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the Notify DM or RVP2. GP043AS-039920-PP-829 Page 41 of 43 Page 1 of 1 001AS-SAFETY-FM-5 Heat Stress Prevention Form This form is to be used when the Expected Heat Index is above 91° F, and is to be kept with project documentation. Project Manager (PM): Expected High Temp: Date(s): Expected Heat Index: 1. Review the signs of Heat Exhaustion and Heat Stroke 2. If Heat Index is above 91° F: Provide cold water and/or sports drinks to all field staff (avoid caffeinated drinks and energy drinks which can increase core temperature). o Bring no less than one gallon of water per employee If employee(s) are dehydrated, on blood pressure medication or not acclimated to heat, ensure they are aware of the heightened risk for heat illness Provide cool head bands/vests/etc. Have ice available to employees Implement work shift rotations and breaks, particularly for employees working in direct sunlight. Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable temporary structures. PM should interview each field staff periodically to evaluate for signs of heat illness 3. If Heat Index is above 103° F: Employees must stop for drinks and breaks every hour (about 4 cups/hour) Employees are not permitted to work alone for more than one hour at a time without a break offering shade and drinks Employees should wear cool bands and vests if working outside more than one hour at a time PM should interview each field staff every 2 hours to evaluate for signs of heat illness GP043AS-039920-PP-829 Page 42 of 43 PacifiCorp – Lake Side Power Plant 2024 40 CFR Part 63, Subpart YYYY Compliance Test, Source Test Protocol This is the Last Page of This Document If you have any questions, please contact one of the following individuals by email or phone. Name: Craig Kormylo Title: District Manager/VP Technical Region: Great Plains Region Email: CKormylo@montrose-env.com Phone: 303-810-2849 Name: Timothy Wojtach Title: Account Manager Region: Great Plains Region, Denver Office Email: TWojtach@montrose-env.com Phone: 303-670-0530 ext. 14304 GP043AS-039920-PP-829 Page 43 of 43