DAQ-2024-007874

DAQE-AN144440002-24
{{$d1 }}
Michelle Kerns
Glen Canyon National Recreation Area
691 Scenic View Road
PO Box 1507
Page, AZ 86040
[e-mail]
Dear Ms. Kerns:
Re: Approval Order: Installation and Operation of Generator Engines and Standby Generator Engines
Project Number: N144440002
The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
November 10, 2022. Glen Canyon National Recreation Area must comply with the requirements of this
AO, all applicable state requirements (R307), and Federal Standards.
The project engineer for this action is Mr. Enqiang He, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received
on this action.
Sincerely,
{{$s }}
Bryce C. Bird
Director
BCB:EH:jg
cc: Southeastern Utah District Health Department
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
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
April 16, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
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APPROVAL ORDER
DAQE-AN144440002-24
Installation and Operation of Generator Engines and Standby
Generator Engines

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Glen Canyon National Recreation Area - Bullfrog Basin Marina

Issued On
{{$d2 }}

Issued By
{{$s }}

Bryce C. Bird
Director
Division of Air Quality

April 16, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description .................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN144440002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Glen Canyon National Recreation Area Glen Canyon National Recreation Area - Bullfrog Basin Marina

Mailing Address Physical Address
691 Scenic View Road PO Box 1507 Page, AZ 86040
Highway 276 Bullfrog Kane County, UT

Source Contact UTM Coordinates
Name: Michelle Kerns 523,619 m Easting
Phone: [phone],153,977 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 9512 (Land, Mineral, Wildlife, & Forest Conservation)

SOURCE INFORMATION
General Description
Glen Canyon National Recreation Area (GCNRA) operates the Bullfrog Marina in Kane County.
Equipment operated at the marina includes diesel-fired power generator engines and diesel fuel storage
tanks. Annual operations for all six (6) 672-hp engine generator sets are limited to 48,786 hours. All
other generator engines are limited to 100 hours per year of operations for maintenance, testing, and
power generation.

NSR Classification
Minor Modification at Minor Source
Source Classification
Located in Attainment Area
Kane County
Airs Source Size: SM
Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN144440002-24
Page 4

Project Description
GCNRA has requested to install and operate six (6) generator engines that were permitted in AO
DAQE-AN144440001-15, dated June 16, 2015. The engines have not been installed since the AO was
issued. Per R307-401-18, the approved engines become invalid because construction and installation
were not commenced within 18 months from the date of the AO. Therefore, GCNRA is seeking approval
to install and operate these generator engines. BACT analysis has been conducted and has shown the
engines meet the BACT requirements. The six (6) generator engines are each rated at 672 hp, with the
generator rated at 455 kW. In addition, GCNRA has also requested to add three (3) standby generator
engines rated at 1800 hp, 1300 hp, and 1300 hp, respectively. All generator engines are fired with diesel
fuel.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -704 17912.00
Carbon Monoxide 2.95 94.86
Nitrogen Oxides 7.09 99.00
Particulate Matter - PM10 0.12 2.77
Particulate Matter - PM2.5 0.12 2.77
Sulfur Dioxide -0.02 0.17
Volatile Organic Compounds -5.29 5.25

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) -754 40
Acrolein (CAS #107028) -96 20
Benzene (Including Benzene From Gasoline) (CAS #71432) 6 180
Formaldehyde (CAS #50000) -665 40
Methanol (CAS #67561) -94 20
Propylene[1-Propene] (CAS #115071) -6 620
Toluene (CAS #108883) 12 60
Xylenes (Isomers And Mixture) (CAS #1330207) -3 40
Change (TPY) Total (TPY)
Total HAPs -0.82 0.51

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-AN144440002-24
Page 5
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Glen Canyon National Recreation Area Bullfrog Basin Marina II.A.2 Generator Engines - new Number: Six (6) Generator output: 455 kW each (Cat C15 ATAAC) Engine rating 672 hp (501 kW) each Fuel Type: Diesel EPA Tier 4 Interim Year of Manufacture: 2014 NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.3 One (1) Standby Generator Engine - new Engine rating: 1800 hp (Cat 3516) Fuel Type: Diesel Year of Manufacture: 1989 MACT Applicability: Subpart ZZZZ
DAQE-AN144440002-24
Page 6
II.A.4 One (1) Standby Generator Engine - new Engine rating: 1300 hp (Cat 3512) Fuel Type: Diesel Year of Manufacture: 1984 MACT Applicability: Subpart ZZZZ II.A.5 One (1) standby Generator Engine - new Engine rating: 1300 hp (Cat 3516) Fuel Type: Diesel Year of Manufacture: 1984 MACT Applicability: Subpart ZZZZ II.A.6 Two (2) Diesel Storage Tanks Capacity: 12,000 gallons - each

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 The Generator Engine Requirements II.B.1.a Visible emissions from the diesel-fired generator engines on site shall not exceed 20% opacity. [R307-201-3, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] II.B.1.b The owner/operator shall not operate the six (6) 672-hp engines for more than 48,786 hours combined per rolling 12-month period. [R307-401-8] II.B.1.b.1 The owner/operator shall: A. Record the readings on the non-resettable hour meter on the last day of each calendar month for each engine. B. Calculate the monthly operating hours for each engine. C. Combine the monthly operating hours for all 455-kW engine generator sets. D. Calculate a new 12-month total by the 20th day of each month using the data from the previous 12 months. E. Keep the above records for all periods the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall not operate the three (3) standby generator engines for more than 100 hours each per rolling 12-month period after the 455-kW engine generator sets are installed and become operational. Engine operations shall include readiness testing, maintenance, and power generation. [R307-401-8, R307-410-4]
DAQE-AN144440002-24
Page 7
II.B.1.c.1 The owner/operator shall: A. Record the readings on the non-resettable hour meter on the last day of each calendar month for each standby engine. B. Calculate the monthly operating hours for each standby engine. C. Calculate a new 12-month total by the 20th day of each month using the data from the previous 12 months for each standby engine. D. Keep the above records for all periods the plant is in operation. [R307-401-8] II.B.1.d The owner/operator shall only conduct readiness testing of the standby generator engines one (1) at a time between the hours of 9:00 am and 3:00 pm. [R307-401-8, R307-410-4] II.B.1.d.1 The owner/operator shall: A. Record the standby generator engine identification numbers. B. Record the date, the start and end times of the testing. . C. Keep records for all periods the plant is in operation. [R307-401-8, R307-410-4] II.B.1.e The owner/operator shall install a non-resettable hour meter for each of the generator engines. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2 Engine Stack Test Limits II.B.2.a The owner/operator shall not emit more than the following rates from each of the stacks of the 455-kW engine generator sets: Pollutant g/hp-hr NOx 2.60 CO 2.60 [R307-401-8] II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emission units according to the stack testing conditions contained in this AO. Engine load during the stack testing shall be at 100%. [R307-165-2, R307-401-8] II.B.2.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission units within 180 days after the startup of the emission units. [R307-165-2] II.B.2.a.3 Test Frequency The owner/operator shall conduct a stack test on each of the emission units at least once every 8,760 hours of operation or every 3 years, whichever comes first. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

DAQE-AN144440002-24
Page 8
II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.a.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.3.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.3.a.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.3.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.3.a.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.3.a.6 Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] II.B.3.b Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K). B. Pressure - 29.92 in Hg (101.3 kPa). C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.3.b.1 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.3.b.2 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.4 Fuel Requirements II.B.4.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the generator engines. [R307-401-8] II.B.4.b The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
DAQE-AN144440002-24
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II.B.4.b.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.4.c The owner/operator shall load the diesel fuel storage tanks on site by the use of submerged loading. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN144440001-15 dated June 16, 2015 Incorporates NOI dated November 10, 2022 Incorporates DAQE-MN144440002-22 dated December 1, 2022 Incorporates Additional information dated February 23, 2023 Incorporates Additional information dated May 12, 2023 Incorporates Additional information dated June 26, 2023 Incorporates Additional information dated July 18, 2023 Incorporates Additional information dated September 27, 2023 Incorporates Additional information dated November 16, 2023 Incorporates Additional information dated December 4, 2023 Incorporates Additional information dated February 14, 2024
DAQE-AN144440002-24
Page 10

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN144440002-24

March 7, 2024

Michelle Kerns
Glen Canyon NRA
691 Scenic View Road
PO Box 1507
Page, AZ 86040
[e-mail]

Dear Ms. Kerns:

Re: Intent to Approve: Installation and Operation of Generator Engines and Standby Generator
Engines
Project Number: N144440002

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Mr. Enqiang He, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Mr. Enqiang He, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:EH:jg

cc: Southeastern Utah District Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN144440002-24
Installation and Operation of Generator Engines and Standby
Generator Engines

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Glen Canyon NRA - Bullfrog Basin Marina

Issued On
March 7, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-IN144440002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Glen Canyon NRA Glen Canyon NRA - Bullfrog Basin Marina

Mailing Address Physical Address
691 Scenic View Road
PO Box 1507
Highway 276 Bullfrog
Kane County, UT
Page, AZ 86040

Source Contact UTM Coordinates
Name: Michelle Kerns 523,619 m Easting
Phone: [phone],153,977 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 9512 (Land, Mineral, Wildlife, & Forest Conservation)

SOURCE INFORMATION
General Description
Glen Canyon National Recreation Area (GCNRA) operates the Bullfrog Marina in Kane County.
Equipment operated at the marina includes diesel-fired power generator engines and diesel fuel storage
tanks. Annual operations for all six (6) 672-hp engine generator sets are limited to 48,786 hours. All
other generator engines are limited to 100 hours per year of operations for maintenance, testing, and
power generation.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Kane County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

DAQE-IN144440002-24
Page 4

Project Description
GCNRA has requested to install and operate six (6) generator engines that were permitted in AO
DAQE-AN144440001-15, dated June 16, 2015. The engines have not been installed since the AO was
issued. Per R307-401-18, the approved engines become invalid because construction and installation
were not commenced within 18 months from the date of the AO. Therefore, GCNRA is seeking approval
to install and operate these generator engines. BACT analysis has been conducted and has shown the
engines meet the BACT requirements. The six (6) generator engines are each rated at 672 hp, with the
generator rated at 455 kW. In addition, GCNRA has also requested to add three (3) standby generator
engines rated at 1800 hp, 1300 hp, and 1300 hp, respectively. All generator engines are fired with diesel
fuel.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -704 17912.00
Carbon Monoxide 2.95 94.86
Nitrogen Oxides 7.09 99.00
Particulate Matter - PM10 0.12 2.77
Particulate Matter - PM2.5 0.12 2.77
Sulfur Dioxide -0.02 0.17
Volatile Organic Compounds -5.29 5.25

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) -754 40
Acrolein (CAS #107028) -96 20
Benzene (Including Benzene From Gasoline) (CAS #71432) 6 180
Formaldehyde (CAS #50000) -665 40
Methanol (CAS #67561) -94 20
Propylene[1-Propene] (CAS #115071) -6 620
Toluene (CAS #108883) 12 60
Xylenes (Isomers And Mixture) (CAS #1330207) -3 40
Change (TPY) Total (TPY)
Total HAPs -0.82 0.51

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the San Juan Record on March 13, 2024. During the public
comment period the proposal and the evaluation of its impact on air quality will be available for the
public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
DAQE-IN144440002-24
Page 5

practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN144440002-24
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Glen Canyon NRA
Bullfrog Basin Marina

II.A.2 Generator Engines - new
Number: Six (6)
Generator output: 455 kW each (Cat C15 ATAAC)
Engine rating 672 hp (501 kW) each
Fuel Type: Diesel
EPA Tier 4 Interim
Year of Manufacture: 2014
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

II.A.3 One (1) Standby Generator Engine - new
Engine rating: 1800 hp (Cat 3516)
Fuel Type: Diesel
Year of Manufacture: 1989
MACT Applicability: Subpart ZZZZ

II.A.4 One (1) Standby Generator Engine - new
Engine rating: 1300 hp (Cat 3512)
Fuel Type: Diesel
Year of Manufacture: 1984
MACT Applicability: Subpart ZZZZ

II.A.5 One (1) Standby Generator Engine - new
Engine rating: 1300 hp (Cat 3516)
Fuel Type: Diesel
Year of Manufacture: 1984
MACT Applicability: Subpart ZZZZ

II.A.6 Two (2) Diesel Storage Tanks
Capacity: 12,000 gallons - each

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 The Generator Engine Requirements
II.B.1.a Visible emissions from the diesel-fired generator engines on site shall not exceed 20% opacity.
[R307-201-3, R307-401-8]

DAQE-IN144440002-24
Page 7

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.1.b The owner/operator shall not operate the six (6) 672-hp engines for more than 48,786 hours
combined per rolling 12-month period. [R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Record the readings on the non-resettable hour meter on the last day of each
calendar month for each engine

B. Calculate the monthly operating hours for each engine

C. Combine the monthly operating hours for all 455-kW engine generator sets

D. Calculate a new 12-month total by the 20th day of each month using the data
from the previous 12 months

E. Keep the above records for all periods the plant is in operation.

[R307-401-8]

II.B.1.c The owner/operator shall not operate the three (3) standby generator engines for more than 100
hours each per rolling 12-month period after the 455-kW engine generator sets are installed and
become operational. Engine operations shall include readiness testing, maintenance, and power
generation. [R307-401-8, R307-410-4]

II.B.1.c.1 The owner/operator shall:

A. Record the readings on the non-resettable hour meter on the last day of each
calendar month for each standby engine

B. Calculate the monthly operating hours for each standby engine

C. Calculate a new 12-month total by the 20th day of each month using the data
from the previous 12 months for each standby engine

D. Keep the above records for all periods the plant is in operation.

[R307-401-8]

II.B.1.d The owner/operator shall only conduct readiness testing of the standby generator engines one at a
time between the hours of 9:00 am and 3:00 pm. [R307-401-8, R307-410-4]

II.B.1.d.1 The owner/operator shall:

A. Record the standby generator engine identification numbers

B. Record the date, the start and end times of the testing

C. Keep records for all periods the plant is in operation.

[R307-401-8, R307-410-4]

II.B.1.e The owner/operator shall install a non-resettable hour meter for each of the generator engines.
[40 CFR 63 Subpart ZZZZ, R307-401-8]

DAQE-IN144440002-24
Page 8

II.B.2 Engine Stack Test Limits
II.B.2.a The owner/operator shall not emit more than the following rates from each of the stacks of the
455-kW engine generator sets:

Pollutant g/hp-hr

NOx 2.60
CO 2.60

[R307-401-8]

II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emission units according to the stack testing conditions contained in
this AO. Engine load during the stack testing shall be at 100%. [R307-165-2, R307-401-8]

II.B.2.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission units within 180 days after
the startup of the emission units. [R307-165-2]

II.B.2.a.3 Test Frequency
The owner/operator shall conduct a stack test on each of the emission units at least once every
8,760 hours of operation or every 3 years, whichever comes first. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.3 Stack Testing Requirements
II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.3.a.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.3.a.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.3.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.3.a.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.3.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.3.a.6 Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

DAQE-IN144440002-24
Page 9

II.B.3.b Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method.

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.3.b.1 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.3.b.2 CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]

II.B.4 Fuel Requirements
II.B.4.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the generator engines. [R307-401-8]

II.B.4.b The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.4.b.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-401-8]

II.B.4.c The owner/operator shall load the diesel fuel storage tanks on site by the use of submerged
loading. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN144440001-15 dated June 16, 2015
Incorporates NOI dated November 10, 2022
Incorporates DAQE-MN144440002-22 dated December 1, 2022
Incorporates Additional information dated February 23, 2023
Incorporates Additional information dated May 12, 2023
Incorporates Additional information dated June 26, 2023
Incorporates Additional information dated July 18, 2023
Incorporates Additional information dated September 27, 2023
Incorporates Additional information dated November 16, 2023
Incorporates Additional information dated December 4, 2023
Incorporates Additional information dated February 14, 2024

DAQE-IN144440002-24
Page 10

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-NN144440002-24

March 7, 2024

San Juan Record
Legal Advertising Dept.
49 S Main
Monticello, UT 84535

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the San Juan Record on
March 13, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: San Juan County
cc: Southeastern Association of Governments

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN144440002-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Glen Canyon NRA
Location: Glen Canyon NRA - Bullfrog Basin Marina – Highway 276, Bullfrog, Kane
County, UT
Project Description: Glen Canyon National Recreation Area (GCNRA) operates the Bullfrog Marina
in Kane County. Equipment operated at the marina includes diesel-fired power
generator engines and diesel fuel storage tanks. GCNRA has requested to install
and operate six (6) generator engines that were approved in the Approval Order
DAQE-AN144440001-15, dated June 16, 2015. The engines have not been
installed since Approval Order was issued. Per R307-401-18, the approved
engines become invalid because construction and installation were not
commenced within 18 months from the date of the Approval Order. Therefore,
GCNRA is seeking approval to install and operate these generator engines. The
six (6) generator engines are each rated at 501 kW (672 hp). In addition,
GCNRA has also requested to add three (3) standby generator engines rated at
1800 hp, 1300 hp, and 1300 hp, respectively. All generator engines are fired
with diesel fuel. Annual operations for all six (6) 672-hp engine generator sets
are limited to 48,786 hours. The standby generator engines are limited to 100
hours per year of operation.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before April 12, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication
of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: March 13, 2024

{{#s=Sig_es_:signer1:signature}}

3/7/24, 3:31 PM State of Utah Mail - Legal Notice to be published March 13, 2024
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permmsgid=msg-f:1792908323422640172&simpl=msg-f:1792908323422640172 1/1
Jeree Greenwood <[e-mail]>
Legal Notice to be published March 13, 2024
News <[e-mail]>Thu, Mar 7, 2024 at 3:30 PM
To: Jeree Greenwood <[e-mail]>
Confirmed
[Quoted text hidden]
[Quoted text hidden]
<DAQE-NN144440002-24.pdf><NN144440002-24.rtf>
DAQE-

RN144440002
March 5, 2024

Michelle Kerns
Glen Canyon NRA
691 Scenic View Road
PO Box 1507
Page, AZ 86040
[e-mail]

Dear Michelle Kerns,

Re: Engineer Review:
Installation and Operation of Generator Engines and Standby Generator Engines
Project Number: N144440002

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Glen Canyon NRA
should complete this review within 10 business days of receipt.

Glen Canyon NRA should contact Mr. Enqiang He at [phone] if there are questions or concerns
with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr.
Enqiang He at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ
will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the
DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ
Director.

If Glen Canyon NRA does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Glen Canyon NRA has concerns that cannot be resolved and the
project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

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
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

MICHELLE KERNS Digitally signed by MICHELLE KERNS
Date: 2024.03.06 14:02:45 -07'00'

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N144440002
Owner Name Glen Canyon NRA
Mailing Address 691 Scenic View Road
PO Box 1507
Page, AZ 86040

Source Name Glen Canyon NRA - Bullfrog Basin Marina
Source Location Highway 276
1 Mile NE of the Bullfrog Boat Ramp
Bullfrog
Kane County, UT

UTM Projection 523,619 m Easting, 4,153,977 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 9512 (Land, Mineral, Wildlife, & Forest Conservation)

Source Contact Michelle Kerns
Phone Number [phone]
Email [e-mail]

Billing Contact Michelle Kerns
Phone Number [phone]
Email [e-mail]

Project Engineer Mr. Enqiang He, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 10, 2022
Date of Accepted Application March 1, 2024

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 2
SOURCE DESCRIPTION

General Description
Glen Canyon National Recreation Area (GCNRA) operates the Bullfrog Marina in Kane County.
Equipment operated at the marina includes diesel-fired power generator engines and diesel fuel
storage tanks. Annual operations for all six (6) 672-hp engine generator sets are limited to 48,786
hours. All other generator engines are each limited to 100 hours per year of operations for
maintenance, testing, and power generation.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in an Attainment Area
Kane County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Proposal
Installation and Operation of Generator Engines and Standby Generator Engines

Project Description
GCNRA has requested to install and operate six (6) generator engines that were permitted in AO
DAQE-AN144440001-15, dated June 16, 2015. The engines have not been installed since the
AO was issued. Per R307-401-18, the approved engines become invalid because the construction
and installation were not commenced within 18 months from the date of the AO. Therefore,
GCNRA is seeking approval to install and operate these generator engines. BACT analysis has
been conducted and has shown the engines meet the BACT requirements. The six (6) generator
engines are each rated at 672 hp with the generator rated at 455 kW. In addition, GCNRA has
also requested to add three standby generator engines rated at 1800 hp, 1300 hp, and 1300 hp,
respectively. All generator engines are fired with diesel fuel.

EMISSION IMPACT ANALYSIS
A dispersion modeling analysis was performed for the following source:
Company: GCNRA
Site: Bullfrog Basin Marina

The individual criteria emission increases triggered the requirement to model under R307-410-4 for the
following pollutants:
-NO2

The modeling analysis was based on the following operating restrictions:

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 3
1. The owner/operator shall not operate the standby generator engines for more than 100 hrs a year;
2. The owner/operator shall only conduct readiness testing on one standby generator engine at a time, and
3. The owner/operator shall only conduct readiness testing on the standby generator engines between 9:00 am
and 3:00 pm.

Using the above conditions, the predicted total concentrations are less than the NAAQS (92.34% for the 1-hr
average and 23.80% for the annual average). Therefore, the above conditions are incorporated into the ER.
[Last updated January 17, 2024]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 4
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -704 17912.00
Carbon Monoxide 2.95 94.86
Nitrogen Oxides 7.09 99.00
Particulate Matter - PM10 0.12 2.77
Particulate Matter - PM2.5 0.12 2.77
Sulfur Dioxide -0.02 0.17
Volatile Organic Compounds -5.29 5.25

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) -754 40
Acrolein (CAS #107028) -96 20
Benzene (Including Benzene From Gasoline) (CAS #71432) 6 180
Formaldehyde (CAS #50000) -665 40
Methanol (CAS #67561) -94 20
Propylene[1-Propene] (CAS #115071) -6 620
Toluene (CAS #108883) 12 60
Xylenes (Isomers And Mixture) (CAS #1330207) -3 40
Change (TPY) Total (TPY)
Total HAPs -0.82 0.51

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 5
Review of BACT for New/Modified Emission Units

1. BACT review regarding generator engines each rated at 672 hp (501 kW)
The owner/operator was approved to install and operate six (6) new generator engines each rated at
672 hp under AO DAQE-AN144440001-15. However, the permitted engines have not been
installed and operated within 18 months after the date of the current AO. Therefore, the previous
BACT analysis is no longer valid, and the owner/operator is required to conduct a new BACT
analysis.

The source conducted a BACT analysis using SCR for controlling NOx emissions based on the
following parameters:

The capital costs: these costs include SCR system cost of $100,000, installation cost of $15,000,
indirect costs of $23,000, project contingency of $20,700, pre-production cost of $3,174, initial
DEF inventory of $11,250. The total capital costs are summed at $173,124. Based on a 10-year
project life at an 8.0% interest rate, the annualized capital cost is calculated at $25,779

Operating costs: these costs include operating and maintenance (O&M) labor $9,361, O&M
management/supervision $936, Power needs for the SCR $22,237, DEF consumption $75,884 for
100% load or $80,811 for 70% load, SCR catalyst replacement $10,000, filter assembly
replacement $5,000. The annualized operating cost is calculated at $123,417 for 100% load or
$128,345 for 70% load.

Total annualized costs = annualized capital cost + annualized operating cost = $149196 for 100%
load or $154,124 for 70% load.

NOx emission reductions are based on the difference between Tier 4i (3.5 g/kW-hr) and Tier 4
final (0.67 g/kW-hr), operating continuously. The NOx emissions reductions are calculated at
13.68 tpy for 100% load and 9.58 tpy for 70% load.

Therefore, the annualized cost-effectiveness ($/ton of NOx removed) is $10,907 for 100% load or
$16,083 for 70% load. Considering the engines will not be operated at 100% load most of time,
they will probably be operated at between 80% and 90% engine loads or lower for the majority of
engine operations. As a result, the cost-effectiveness would be most likely at a higher end of the
range between $11,000 and $16,000. For this reason, the Tier 4 final standard for NOx would not
be considered as a BACT for engines that are already at Tier 4i. It is, therefore, concluded that
Tier 4i is considered as the BACT for these engines proposed to be operated at the Bullfrog Basin
Marina.

As a part of BACT, the source shall also comply with the following requirements:
1. Use of ultra-low (15 ppm) sulfur diesel fuel,
2. Visible emissions are limited to less than or equal to 20 % opacity,
3. Manufacturer recommended maintenance and testing to ensure optimal performance, and
4. Periodic stack testing to verify emissions.

[Last updated January 17, 2024]

2. BACT review regarding standby generator engines
The three (3) generator engines, rated at 1,800 hp, 1,300 hp, and 1,300 hp, respectively, are
standby generator engines. They are limited to 100 hrs/yr of operations for testing, maintenance,
and power generation operations. The most emissions from the engines are NOx, calculated at

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 6
2.09, 1.28, and 1.5 tpy, respectively. Other emissions are much smaller. The source conducted a
BACT analysis using Selective Catalytic Reduction (SCR) technology for NOx control. The
annualized cost-effectiveness for the 1,800-hp engine is estimated at $36,942 per ton of NOx
removed. For the two 1,300-hp engines, the annualized cost-effectiveness is estimated at more
than $50,000 per ton of NOx removed. It is, therefore, economically infeasible to use the SCR
control technology to control such small NOx emissions.

The source shall comply with the following requirements as BACT:
1. Use of ultra-low (15 ppm) sulfur diesel fuel,
2. Visible emissions are limited to less than or equal to 20 % opacity,
3. Manufacturer recommended maintenance to ensure optimal engine performance.

[Last updated January 17, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 7
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Glen Canyon NRA
Bullfrog Basin Marina

II.A.2 Generator Engines - new
Number: Six (6)
Generator output: 455 kW each (Cat C15 ATAAC)
Engine rating 672 hp (501 kW) each
Fuel Type: Diesel
EPA Tier 4 Interim
Year of Manufacture: 2014
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

II.A.3
NEW
One (1) Standby Generator Engine - new
Engine rating: 1800 hp (Cat 3516)
Fuel Type: Diesel
Year of Manufacture: 1989
MACT Applicability: Subpart ZZZZ

II.A.4
NEW
One (1) Standby Generator Engine - new
Engine rating: 1300 hp (Cat 3512)
Fuel Type: Diesel
Year of Manufacture: 1984
MACT Applicability: Subpart ZZZZ

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 8
II.A.5
NEW
One (1) standby Generator Engine - new
Engine rating: 1300 hp (Cat 3516)
Fuel Type: Diesel
Year of Manufacture: 1984
MACT Applicability: Subpart ZZZZ

II.A.6 Two (2) Diesel Storage Tanks
Capacity: 12,000 gallons – each

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1
NEW
The Generator Engine Requirements
II.B.1.a
NEW
Visible emissions from the diesel-fired generator engines on site shall not exceed 20%
opacity. [R307-201-3, R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.1.b
NEW
The owner/operator shall not operate the six (6) 672-hp engines for more than 48,786 hours
combined per rolling 12-month period. [R307-401-8]

II.B.1.b.1
NEW
The owner/operator shall:

A. Record the readings on the non-resettable hour meter on the last day of each calendar
month for each engine

B. Calculate the monthly operating hours for each engine

C. Combine the monthly operating hours for all 455-kW engine generator sets

D. Calculate a new 12-month total by the 20th day of each month using the data from the
previous 12 months

E. Keep the above records for all periods the plant is in operation

[R307-401-8]

II.B.1.c
NEW
The owner/operator shall not operate the three (3) standby generator engines for more than
100 hours each per rolling 12-month period after the 455-kW engine generator sets are
installed and become operational. Engine operations shall include readiness testing,
maintenance, and power generation. [R307-401-8, R307-410-4]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 9
II.B.1.c.1
NEW
The owner/operator shall:

A. Record the readings on the non-resettable hour meter on the last day of each calendar
month for each standby engine

B. Calculate the monthly operating hours for each standby engine

C. Calculate a new 12-month total by the 20th day of each month using the data from the
previous 12 months for each standby engine

D. Keep the above records for all periods the plant is in operation

[R307-401-8]

II.B.1.d
NEW
The owner/operator shall only conduct readiness testing of the standby generator engines one
at a time between the hours of 9:00 am and 3:00 pm. [R307-401-8, R307-410-4]

II.B.1.d.1
NEW
The owner/operator shall:

A. Record the standby generator engine identification numbers

B. Record the date, the start and end times of the testing

C. Keep records for all periods the plant is in operation.

[R307-401-8, R307-410-4]

II.B.1.e
NEW
The owner/operator shall install a non-resettable hour meter for each of the generator engines.
[R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.2
NEW
Engine Stack Test Limits
II.B.2.a
NEW
The owner/operator shall not emit more than the following rates from each of the stacks of the
455-kW engine generator sets:

Pollutant g/hp-hr

NOx 2.60
CO 2.60

[R307-401-8]

II.B.2.a.1
NEW
Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emission units according to the stack testing conditions contained
in this AO. Engine load during the stack testing shall be at 100%. [R307-165-2, R307-401-8]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 10
II.B.2.a.2
NEW
Initial Test
The owner/operator shall conduct an initial stack test on the emission units within 180 days
after the startup of the emission units. [R307-165-2]

II.B.2.a.3
NEW
Test Frequency
The owner/operator shall conduct a stack test on each of the emission units at least once every
8,760 hours of operation or every 3 years, whichever comes first. The Director may require
the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.3
NEW
Stack Testing Requirements
II.B.3.a
NEW
The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.3.a.1
NEW
Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.3.a.2
NEW
Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.3.a.3
NEW
Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.3.a.4
NEW
Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.3.a.5
NEW
Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.3.a.6
NEW
Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 11
II.B.3.b
NEW
Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.3.b.1
NEW
NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.3.b.2
NEW
CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

II.B.4
NEW
Fuel Requirements
II.B.4.a
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in the generator engines. [R307-401-8]

II.B.4.b
NEW
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.4.b.1
NEW
To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements. [R307-401-8]

II.B.4.c
NEW
The owner/operator shall load the diesel fuel storage tanks on site by the use of submerged
loading. [R307-401-8]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 12
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN144440001-15 dated June 16, 2015
Incorporates NOI dated November 10, 2022
Incorporates DAQE-MN144440002-22 dated December 1, 2022
Incorporates Additional information dated February 23, 2023
Incorporates Additional information dated May 12, 2023
Incorporates Additional information dated June 26, 2023
Incorporates Additional information dated July 18, 2023
Incorporates Additional information dated September 27, 2023
Incorporates Additional information dated November 16, 2023
Incorporates Additional information dated December 4, 2023
Incorporates Additional information dated February 14, 2024

REVIEWER COMMENTS

1. Comment regarding 40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile
Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which
Construction, Reconstruction, or Modification Commenced After July 23, 1984:
This federal rule does not apply to Bullfrog, as each tank is 12,000 gallons. This rule applies to
vessels greater than 19,800 gallons [Last updated November 10, 2022]

2. Comment regarding 40 CFR Part 60 Subpart K -Standards of Performance for Storage
Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification
Commenced After June 11, 1973, and Prior to May 19, 1978:
This federal rule does not apply to Bullfrog. It applies to sources that were constructed between
June 11, 1973 and May 19, 1978. Bullfrog's tanks were constructed in 1989. [Last updated
November 10, 2022]

3. Comment regarding 40 CFR Part 60 Subpart Ka - Standards of Performance for Storage
Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification
Commenced After May 18, 1978, and Prior to July 23, 1984:
This federal rule does not apply to Bullfrog. It applies to sources that were constructed between
May 18, 1978 and July 23, 1984. Bullfrog's tanks were constructed in 1989. [Last updated
November 10, 2022]

4. Comment regarding emission calculations:
Emissions from the 672-hp generator engines were calculated assuming that all six (6) engines each
operate 8,131 hours per year at 100 % load. Emission factors were obtained from the manufacturer,
EPA Tier 4 Interim emission standards, and the fifth edition of AP-42 Chapter 3.4. The engine
power used in the emission calculations was 672 hp (501.49 kW).

Emissions from the three older engines, rated at 1,300, 1,300, and 1,800 hp, were calculated using
the rated engine capacities and emission factors from the Caterpillar engine specs and the fifth
edition of AP-42 Chapter 3.4.

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 13

SOx emissions were estimated from the AP-42 emission factor and 15 ppm S diesel. SO2 emissions
were set equal to SOx emissions.

The emission factors for formaldehyde, acrolein, acetaldehyde, and methanol were supplied by the
manufacturer. The remaining HAPs were estimated from emission factors supplied inAP-42.

CO2e emissions were estimated from CO2 and methane emissions, which were estimated from the
emission factors given in AP-42. GHG emission factors were obtained from 40 CFR 98 Subpart C.

Tank emissions from the diesel storage tanks were calculated using EPA Tanks.

[Last updated January 16, 2024]

5. Comment regarding source determination:
Source determination made in AO DAQE-AN144440001-15:
Glen Canyon National Recreation Area covers 1.2 million acres along and near Lake Powell
stretching from Lees Ferry in Arizona northeastward to the Orange Cliffs in Utah. The primary uses
of the area are water-based recreation on Lake Powell and backcountry recreation in the off-shore
areas. All lands within the area are managed by the National Park Service within the U.S.
Department of the Interior. Within the recreation area, multiple emitting units are present within
geographic regions, i.e., Hite, Bullfrog, and Halls Crossing.

The DAQ has determined that the geographic regions are each considered one source. To make this
determination, the DAQ used the documents Source Determinations for NSR, PSD, and Title V:
Aggregating Emissions prepared by Lenore Epstein in 1997 and Site Determination Guidance
prepared by the Georgia Department of Natural Resources, Environmental Protection Division, Air
Protection Branch in 1996. For these facilities to be considered one source, three elements must be
present to constitute a "source": common control, same industrial grouping (2-digit SIC code), and
located on adjacent or contiguous (or continuous) property.

The DAQ has determined that the National Park Service has common control of all of the regions.
The same industrial groupings are located within each of the regions, i.e. power generating
operations are located at Hite, Bullfrog, and Halls Crossing.

The DAQ has determined that the regions are not adjacent or contiguous even though they are
located within the same recreation area. The regions that are the closest to each other are Halls
Crossing and Bullfrog at 5.7 miles across Lake Powell. The regions do not have a dedicated
physical connection other than public roads and ferries that connect them. The power generated is
transmitted only to the localized area where it is produced (power is not transmitted to the other side
of the lake). The regions are not dependent on each other and operate if the others are shut down.
The regions do not have a permit history that requires the operations be permitted as one source.
The regions have minimal operational relationships, as they have the potential to have the same plant
manager and the potential for some of the employees to be employed at multiple sites.

In addition to the power generating operations, fueling stations exist within the regions of Hite, Halls
Crossing, and Bullfrog. The DAQ has determined that the power generation operation within a
region is a separate source from the fueling stations located within the same region. The power
generation sites have different 2-digit SIC codes than the fueling station sites and the two do not
support each other. [Last updated March 5, 2024]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 14
6. Comment regarding EPA Tier 4i standards for the new generator engines each rated at 672
hp:
The new generator sets each use a C15 CAT engine. The sets were manufactured on November 11,
2014. To generate 455 kW of electric power, each engine will have to output at least 610 hp of
mechanical power. Considering there are also power losses and additional power needed to start
high inrush loads in a timely manner, the engines are capable of running at 790 hp (590 kW). The
engines only need to generate high power for a few seconds. The mechanical power needed to
sustain a 455-kW electric power generation will be 672 hp. Therefore, the engines fall under Table 7
of 40 CFR 1039.102. The Tier 4i standards are listed below:

PM = 0.10 g/kW-hr
NOx = 3.5 g/kW-hr
NMHC = 0.40 g/kW-hr
CO = 3.5 g/kW-hr

[Last updated January 16, 2024]

Engineer Review N144440002: Glen Canyon NRA- Bullfrog Basin Marina
March 5, 2024
Page 15
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

3/5/24, 5:09 PM State of Utah Mail - Re: Bullfrog Air Permit Comments
https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-a:r-4009592572043128026&simpl=msg-a:r-40095925720431…1/2
Enqiang He <[e-mail]>
Re: Bullfrog Air Permit Comments
Enqiang He <[e-mail]>Thu, Feb 15, 2024 at 12:01 AM
To: "Miller, Debra C" <[e-mail]>
Cc: "Kerns, Michelle R" <[e-mail]>, "Devore, Lisa M" <[e-mail]>, "Grigg, Heidie H"
<[e-mail]>, "Rich, Nichelle M" <[e-mail]>, Alan Humpherys <[e-mail]>
Hello Debra,
The Utah Division of Air Quality has received your comments on the draft AO currently
under review. The following are our responses:
1.Condition II.B.1.b.1 is revised to read:
The owner/operator shall:
A. Record the readings on the non-resettable hour meter on the last day of each
calendar month for each engine
B. Calculate the monthly operating hours for each engine
C. Combine the monthly operating hours for all 455-kW engine generator sets
D. Calculate a new 12-month total by the 20th day of each month using the data from
the previous 12 months
E. Keep the above records for all periods the plant is in operation
2. Condition II.B.1.c.1 is revised to read:
The owner/operator shall:
A. Record the readings on the non-resettable hour meter on the last day of each
calendar month for each standby engine
B. Calculate the monthly operating hours for each standby engine
C. Calculate a new 12-month total by the 20th day of each month using the data from
the previous 12 months for each standby engine
D. Keep the above records for all periods the plant is in operation
3. Condition II.B.1.c is revised to read:
The owner/operator shall not operate the three (3) standby generator engines for more
than 100 hours each per rolling 12-month period after the 455-kW engine generator
sets are installed and become operational.
4. Condition II.B.1.d only applies to readiness testing. No change needed.
3/5/24, 5:09 PM State of Utah Mail - Re: Bullfrog Air Permit Comments
https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-a:r-4009592572043128026&simpl=msg-a:r-40095925720431…2/2
5. Condition II.B.2.a.3 is a federal requirement. Each engine has an hour meter which
makes it easy for tracking of operating hours. No change needed.
6. “The regions that are the closest to each other are Hite and Bullfrog at 3.5 miles
across Lake Powell.” is revised to read:
“The regions that are the closest to each other are Halls Crossing and Bullfrog at 5.7
miles across Lake Powell.”
Please let us know if the above revisions would meet your needs. Please respond
within two weeks from today. Thanks,
EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
[Quoted text hidden]
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 1/12
Enqiang He <[e-mail]>
FW: NPS Bullfrog Engine Certification Status from Caterpillar
1 message
Miller, Debra C <[e-mail]>Mon, Dec 4, 2023 at 9:55 AM
To: Enqiang He <[e-mail]>
Hi EQ

Sam Strobel’s response to my latest email is just below.

Thanks!
Debbie

Debbie Miller
Environmental Protection Specialist
NPS Air Resources Division
12795 W. Alameda Parkway, Lakewood, CO 80228
[e-mail]
303-987-6926

From: Sam Strebel <[e-mail]>
Sent: Wednesday, November 15, 2023 12:35 PM
To: Miller, Debra C <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

Debbie-
After talking further with technical support we’ve suggested the changes below.
I also found out that there are settings in the control panels that cap the kw output, but we can review those settings and
adjust if needed.

Caterpillar has informed us that the C15 engine will operate as described in the attached specification sheet. The
specification sheet is the same as the one originally provided with the Notice of Intent.

1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 2/12
When the 455KW generator is operating at 100% load, the C15 engine will run at 672 hp. The C15 engine will
not operate at its maximum power setting in this configuration.

Caterpillar has told us: “It is not unusual to have an engine that has a higher HP capacity than the generator set is
rated. The KW rating is typically based on the generator and not the engine. The engine that is part of this
generator configuration is used in several different machines and applications and therefore has a higher rated
HP to accommodate those situations. “ The engine hp is sized larger than kW output of the generator to help the
generator start high inrush loads (starting motors etc.) in a timely manner. In this type of application, the
horsepower needed is substantially higher but only needed for a very short duration (seconds). The horsepower
needed to sustain a 455kw load is much less than what’s needed for a high inrush load.

Our understanding is that UDAQ is concerned that the C15 engine might operate at or near its maximum power
setting of 790 hp. However, in the proposed operating configuration, the engine power would be physically
limited to 672 hp. The C15 engine would only operate at the power setting needed to run the 455 KW gen set.
There is no other outlet for additional engine power above 672 hp. In this configuration, the expected power loss
is approximately 9%.

Let me know if you have any questions.

Thanks,

Sam Strebel | PSD Sales Manager | Wheeler Machinery Co.
4901 West 2100 South, Salt Lake City, UT 84120
Office: 801.978.1661 | Mobile: [phone]
[e-mail] | www.wheelercat.com
Built to Listen. Built to Deliver.
How can we better serve you? Please share your feedback.

From: Miller, Debra C <[e-mail]>
Sent: Wednesday, November 15, 2023 8:14 AM
To: Sam Strebel <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Thanks!

Debbie Miller
Environmental Protection Specialist
NPS Air Resources Division
12795 W. Alameda Parkway, Lakewood, CO 80228
[e-mail]
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 3/12
303-987-6926

From: Sam Strebel <[e-mail]>
Sent: Wednesday, November 15, 2023 8:09 AM
To: Miller, Debra C <[e-mail]>
Subject: Re: NPS Bullfrog Engine Certification Status from Caterpillar

Debbie
I’m adjusting the response slightly and will have it back to you shortly.

Thanks
Sam

Sent from my iPhone

On Nov 14, 2023, at 11:55 AM, Miller, Debra C <[e-mail]> wrote:
This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Hi Sam

I would like to move ahead with getting the Bullfrog Marina generators permitted and it seems like you’ve
probably found everything on our genset by now that is available. Utah is concerned that the generators
could operate at a higher output than 672 hp when used with the supplied generator as part of the genset.
Based on the emails you have sent us, and a spec sheet we already had that appears to match what you
sent me, I am planning to write the following to Utah:

Caterpillar has informed us that the C15 engine will operate as described in the attached
specification sheet. The specification sheet is the same as the one originally provided with the
Notice of Intent.

When the 455KW generator is operating at 100% load, the C15 engine will run at 672 hp. The C15
engine will not operate at its maximum power setting in this configuration.

Caterpillar has told us: “It is not unusual to have an engine that has a higher HP capacity than the
generator set is rated. The KW rating is typically based on the generator and not the engine. The
engine that is part of this generator configuration is used in several different machines and
applications and therefore has a higher rated HP to accommodate those situations. “

Our understanding is that UDAQ is concerned that the C15 engine might operate at or near its
maximum power setting of 790 hp. However, in the proposed operating configuration, the engine
power would be physically limited to 672 hp. The C15 engine would only operate at the power
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 4/12
setting needed to run the 455 KW gen set. There is no other outlet for additional engine power
above 672 hp. In this configuration, the expected power loss is approximately 9%.

Would you mind reviewing these statements and confirming that I am accurately describing the genset
operation? It would really help me to move this project forward. Feel free to call me if you have any
questions.

Thanks a bunch!

Debbie

Debbie Miller
Environmental Protection Specialist
NPS Air Resources Division
12795 W. Alameda Parkway, Lakewood, CO 80228
[e-mail]
303-987-6926

From: Sam Strebel <[e-mail]>
Sent: Thursday, November 9, 2023 7:42 AM
To: Miller, Debra C <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

Hi Debbie-
I found some performance data on this generator showing the BHP at the 455kw rating (highlighted in
yellow). This test is serial number specific to one that you are trying to permit. I’m still digging into putting a
setting in the control panel to limit the output on the generator, but I haven’t made much progress there. I’m
also looking to see if we performed any load tests on the generators while they were at our facility to see if
the HP data was logged.

I am also looking for information on altitude derate on the engines which will also impact the HP maximum.
In the worst-case scenario, if you have to use the maximum engine HP rating, I should be able to provide
documentation that shows the level of impact elevation has on the engine.

Does the attached document help at all?

Thanks,

Sam Strebel | PSD Sales Manager | Wheeler Machinery Co.
4901 West 2100 South, Salt Lake City, UT 84120
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 5/12
Office: 801.978.1661 | Mobile: [phone]
[e-mail] | www.wheelercat.com
<image001.png>
Built to Listen. Built to Deliver.
How can we better serve you? Please share your feedback.

From: Miller, Debra C <[e-mail]>
Sent: Thursday, November 2, 2023 7:08 AM
To: Sam Strebel <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Hi Sam

When I spoke with you last week you had some ideas to try to document the maximum available power
available from the engines based on the generators our engines are paired with. Have you been able to find
any new information?

Thanks!
Debbie

Debbie Miller
Environmental Protection Specialist
NPS Air Resources Division
12795 W. Alameda Parkway, Lakewood, CO 80228
[e-mail]
303-987-6926

From: Sam Strebel <[e-mail]>
Sent: Monday, October 9, 2023 3:02 PM
To: Devore, Lisa M <[e-mail]>
Cc: Miller, Debra C <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

Lisa-
I apologize for the delayed response. I am reviewing the emails that I received from Howard Gebhart on this
issue as well. I will see if I can get supporting documentation for the power loss between the engine and
generator end. It’s not unusual to have an engine that has a higher HP capacity than the package
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 6/12
generator set is rated. The KW rating is typically based on the generator end rating and not the engine. The
engine that is part of this generator configuration is used in several different machines and applications and
therefore has a higher rated HP to accommodate those situations. I will see what I can find and respond to
Howard’s email with both of you copied.

Thanks,

Sam Strebel | PSD Sales Manager | Wheeler Machinery Co.
4901 West 2100 South, Salt Lake City, UT 84120
Office: 801.978.1661 | Mobile: [phone]
[e-mail] | www.wheelercat.com
<image001.png>
Built to Listen. Built to Deliver.
How can we better serve you? Please share your feedback.

From: Devore, Lisa M <[e-mail]>
Sent: Thursday, October 5, 2023 4:28 PM
To: Sam Strebel <[e-mail]>
Cc: Miller, Debra C <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Hi Sam,

We had a call with the state of Utah earlier today to discuss our air quality permit application. The question
arose regarding the maximum generator output. We understand the engines are rated at 589 KW per the
latest specification sheet, but the generators likely operate lower. We have been citing 455 kW, but the
state thinks there is a power loss of 5-10% between the engines and the generators, which means the
engine’s maximum output for the generators would be 475-500 kW. Could you provide documentation of
power loss between the engines and the generators? The state requires this documentation unless we use
the maximum rating of 589 kW which will not be how they will actually operate. Please let us know if you
have any questions.
Thank you,
Lisa

Lisa Devore
National Park Service Intermountain Region (Regions 6, 7 & 8)
Air Quality Specialist
[e-mail]
📱 720.660.0108
Air (U.S. National Park Service) (nps.gov)
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 7/12
IMR Air Resources (sharepoint.com)
FEATURE: National Parks in the History of Science: Visibility (Video) (U.S. National Park Service) (nps.gov)

From: Devore, Lisa M
Sent: Monday, October 2, 2023 11:36 AM
To: Sam Strebel <[e-mail]>
Cc: Miller, Debra C <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar

Hi Sam,

Thank you so much for reaching out and providing us with your updated contact information, we really
appreciate this! We may need technical support demonstrating that while the Bullfrog generators have a
maximum rating of 790 HP, they will not be able to operate beyond 672 HP with the current layout. We will
keep you posted after we hopefully have a call with Utah this week. Appreciate the personal warm wishes
as well.

Sincerely,
Lisa

Lisa Devore
National Park Service Intermountain Region (Regions 6, 7 & 8)
Air Quality Specialist
[e-mail]
📱 720.660.0108
Air (U.S. National Park Service) (nps.gov)
IMR Air Resources (sharepoint.com)
FEATURE: National Parks in the History of Science: Visibility (Video) (U.S. National Park Service) (nps.gov)

From: Sam Strebel <[e-mail]>
Sent: Monday, October 2, 2023 9:25 AM
To: Devore, Lisa M <[e-mail]>
Cc: Miller, Debra C <[e-mail]>
Subject: FW: NPS Bullfrog Engine Certification Status from Caterpillar

Lisa-
I received the message below from Steve Losee who has been your contact with Wheeler for several years.
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 8/12
I want to make sure that you have the appropriate contact at Wheeler since Steve Losee is retiring. We wish
him well and the best of luck in his future. He will still have access to email for a few more weeks, but I
want to minimize the risk of communication being dropped or lost. Specifically, regarding any assistance or
additional information you may need on the generators that you are trying to get permitted to run at
Bullfrog.
Going forward please reach out directly to me for any questions or additional information you may have.

I have copied Debbie here as you mentioned that you are expecting and will be out until May.
Congratulations and best of luck.

Best regards,

Samantha Strebel | PSD Sales Manager | Wheeler Machinery Co.
4901 West 2100 South, Salt Lake City, UT 84120
Office: 801.978.1661 | Mobile: [phone]
[e-mail] | www.wheelercat.com
<image001.png>
Built to Listen. Built to Deliver.
How can we better serve you? Please share your feedback.

From: Steve Losee <[e-mail]>
Sent: Friday, September 29, 2023 8:25 PM
To: Sam Strebel <[e-mail]>; Ben Thompson <[e-mail]>
Subject: Fwd: NPS Bullfrog Engine Certification Status from Caterpillar

Just FYI the latest e-mail between NPS and DEQ in regards to the Bullfrog generators.
Have a good weekend.
Steve
Begin forwarded message:
From: "Devore, Lisa M" <[e-mail]>
Date: September 29, 2023 at 3:45:50 PM MDT
To: Enqiang He <[e-mail]>
Cc: Howard Gebhart <[e-mail]>, "Miller, Debra C"
<[e-mail]>, Steve Losee <[e-mail]>
Subject: RE: NPS Bullfrog Engine Certification Status from Caterpillar
This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and
attachments.
Hi EQ,

1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424782 9/12
We will need to sort out issues such as how to conduct the modeling if we calculate PTE at
589 KW. The engines are sold as a generator set, so they won’t operate beyond 455 KW –
you could write our permit to cap that output if that helps or perhaps there is another solution
we could consider. We can also connect with Caterpillar to confirm that relationship if that
helps (Steve is CCed here).

Depending on when the government reopens, I may or may not be available. I am expecting
a baby near the end of October and will go on maternity leave for 6 months (returning
beginning of May 2024). Debbie, CCed on this email chain, will be covering this project in the
meantime. She may contact you if I am already out on leave. Otherwise, I will reach back out
if the shutdown is short and we can discuss our options.

Thank you,
Lisa

Lisa Devore
National Park Service Intermountain Region (Regions 6, 7 & 8)
Air Quality Specialist
[e-mail]
📱 720.660.0108
Air (U.S. National Park Service) (nps.gov)
IMR Air Resources (sharepoint.com)
FEATURE: National Parks in the History of Science: Visibility (Video) (U.S. National Park Service)
(nps.gov)

From: Enqiang He <[e-mail]>
Sent: Wednesday, September 27, 2023 2:53 PM
To: Devore, Lisa M <[e-mail]>
Cc: Howard Gebhart <[e-mail]>; Miller, Debra C
<[e-mail]>; Steve Losee <[e-mail]>
Subject: Re: NPS Bullfrog Engine Certification Status from Caterpillar

Lisa,

It looks like the engines are rated at max. 790
HP/589 kW based on the attached table.
Therefore, Table 7 is where the standards are.
However, when you calculate emissions, which is
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424…10/12
the potential to emit from the engines, use 790
HP/589 kW in the emission calculations.

Let me know if you have any other questions.
Thanks,

<image002.jpg>

EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
<image002.jpg>

<image002.jpg>

On Wed, Sep 20, 2023 at 2:59 PM Devore, Lisa M <[e-mail]> wrote:
Hi EQ,

Upon further consideration, The engines power the gen set and the gen set has a max
capacity of 455KW. The engine will only run as needed to generate 455KW at the gen
set. The equipment is a system; e.g., the engine and the gen set. The gen set capacity is
what limits the engine load. So we will remain consistent with our application with the
engines at 455 KW. Please reach out if we need to chat or if you have questions.

Thanks,
Lisa

Lisa Devore
National Park Service Intermountain Region (Regions 6, 7 & 8)
1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424…11/12
Air Quality Specialist
[e-mail]
📱 720.660.0108
Air (U.S. National Park Service) (nps.gov)
IMR Air Resources (sharepoint.com)
FEATURE: National Parks in the History of Science: Visibility (Video) (U.S. National Park
Service) (nps.gov)

From: Devore, Lisa M
Sent: Wednesday, September 20, 2023 12:01 PM
To: [e-mail]
Cc: Howard Gebhart <[e-mail]>; Miller, Debra C
<[e-mail]>; Steve Losee <[e-mail]>
Subject: NPS Bullfrog Engine Certification Status from Caterpillar

Hi EQ,

Attached is an engine certification status sheet from Caterpillar (Steve Losee CCed) that
should clear up the emissions level(s) of the 2014 engines. They belong in Table 7. We
are working on recalculating emissions based on the most conservative value listed in the
cert of 790 HP/589 KW. Please let me know if you don’t feel that is appropriate. We are
also discussing compliance using fuel consumption for the engines as noted in your
comments. Reach out if you have any other questions.

Thank you,
Lisa

Lisa Devore
National Park Service Intermountain Region (Regions 6, 7 & 8)
Air Quality Specialist
[e-mail]
📱 720.660.0108
Air (U.S. National Park Service) (nps.gov)
IMR Air Resources (sharepoint.com)
FEATURE: National Parks in the History of Science: Visibility (Video) (U.S. National Park
Service) (nps.gov)

1/10/24, 10:42 AM State of Utah Mail - FW: NPS Bullfrog Engine Certification Status from Caterpillar
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permthid=thread-f:1784371130708424782&simpl=msg-f:1784371130708424…12/12
<EM0176 Tech Data for 455 kW C15.pdf>
1/11/24, 6:05 PM State of Utah Mail - Discuss Utah Generator Bullfrog Generator Permit Options
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1782765497534266451&simpl=msg-f:1782765497534266451 1/3
Enqiang He <[e-mail]>
Discuss Utah Generator Bullfrog Generator Permit Options
Miller, Debra C <[e-mail]>Thu, Nov 16, 2023 at 4:34 PM
To: Enqiang He <[e-mail]>, "Devore, Lisa M" <[e-mail]>
Cc: Howard Gebhart <[e-mail]>
Hi EQ

Caterpillar has informed us that the C15 engine will operate as described in the attached specification sheet.
The specification sheet is the same as the one originally provided with the Notice of Intent.

When the 455KW generator is operating at 100% load, the C15 engine will run at 672 hp. The C15 engine
will not operate at its maximum power setting in this configuration.

Caterpillar has told us: “It is not unusual to have an engine that has a higher HP capacity than the generator
set is rated. The KW rating is typically based on the generator and not the engine. The engine hp is sized
larger than kW output of the generator to help the generator start high inrush loads (starting motors etc.) in a
timely manner. In this type of application, the horsepower needed is substantially higher but only needed
for a very short duration (seconds). The horsepower needed to sustain a 455kw load is much less than what’s
needed for a high inrush load.”
Our understanding is that UDAQ is concerned that the C15 engine might operate at or near its maximum
power setting of 790 hp. However, in the proposed operating configuration, the engine power would be
physically limited to 672 hp. The C15 engine would only operate at the power setting needed to run the 455
KW gen set. There is no other outlet for additional engine power above 672 hp. In this configuration, the
expected power loss is approximately 9%.

To ensure that our understanding of the genset operation is accurate, I sent the four preceding paragraphs to
our Caterpillar representative, who confirmed that this information is correct.

In order to move the NOI forward, the National Park Service (NPS) proposes that the permit contain
appropriate enforceable permit limits to restrict the C15 engine operation, which should satisfy UDAQ’s
concerns related to operation of the engine. Some alternatives for UDAQ to consider include:

1. Limit the power output from the six generators combined to no more than 2,730 KW. (455KW x 6
engines = 2,730KW). NPS monitors the total power output from the Bullfrog generator building (all
engines combined) and can maintain records showing compliance with such a limit. Restricting the
maximum generator output would effectively restrict the C15 engine load.
1/11/24, 6:05 PM State of Utah Mail - Discuss Utah Generator Bullfrog Generator Permit Options
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1782765497534266451&simpl=msg-f:1782765497534266451 2/3
2. Include a condition that only the 455KW power generation equipment can be connected to the C15
engine. Such a condition will assure that there will be no additional load on the C15 engine above 672
hp.
3. Include appropriate emission limitations (lb/hr and/or ton/yr) consistent with the Caterpillar
specification sheet. An emissions limitation would essentially be a restriction on the engine operation
given that higher emissions would be expected if the engine operated above 672 hp.

I am hoping that the information provided above and confirmed by Caterpillar, along with the addition of
enforceable limit(s) if needed, will help us move forward with the NOI. Please let me know if you have any
questions or I need to provide you with additional information.

Thanks for helping us with this permit application!

Debbie

Debbie Miller
Environmental Protection Specialist
NPS Air Resources Division
12795 W. Alameda Parkway, Lakewood, CO 80228
[e-mail]
303-987-6926

From: Enqiang He <[e-mail]>
Sent: Wednesday, November 1, 2023 10:49 PM
To: Devore, Lisa M <[e-mail]>
Cc: Miller, Debra C <[e-mail]>
Subject: [EXTERNAL] Re: Discuss Utah Generator Bullfrog Generator Permit Options

This email has been received from outside of DOI - Use cauon before clicking on links, opening aachments, or responding.

Dear Lisa and Debra,
[Quoted text hidden]
[Quoted text hidden]
1/11/24, 6:05 PM State of Utah Mail - Discuss Utah Generator Bullfrog Generator Permit Options
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1782765497534266451&simpl=msg-f:1782765497534266451 3/3
EM0176 Tech Data for 455 kW C15.pdf
79K

Supplemental Best Available Control Technology (BACT) Analysis
Bullfrog Marina Generator Project
Tier 4i Engine with Selective Catalytic Reduction (SCR)

Prepared on behalf of National Park Service – Glen Canyon National Recreation Area
By Air Resource Specialists, Inc.
May 2023

Introduction and Background

National Park Service (NPS) has submitted a Notice of Intent (NOI) to the Utah Division of Air
Quality (UDAQ) to install and operate diesel-fired electrical power generation equipment at the
Bullfrog Marina within Glen Canyon National Recreation Areas (GCNRA). At Bullfrog, GCNRA plans
to install six (6) Model Year 2014 Caterpillar (CAT) Prime power generation sets sized at
455 kilowatts (KW) each. Each generator will be driven by a CAT Model C15 ATAAC engine. The
proposed equipment will replace older diesel-fired power generation equipment at Bullfrog. The older
generators will remain on-site to serve as backup capacity for the new equipment.

The 2022 NOI replaces an earlier NOI submitted by GCNRA for the same equipment. UDAQ
approved the prior NOI and issued an Approval Order (AO) in 2015. GCNRA purchased the equipment,
but never installed the units and the AO expired. The six 455 KW generators and associated C15 engines
have been in storage since that time. The purchased equipment meet the Tier 4 interim emissions
standards for diesel-fired engines listed in 40 CFR Part 1039.

This report investigates the potential use of selective catalytic reduction (SCR) on the exhaust
stream of the proposed Tier 4 Interim engines to reduce nitrogen oxide (NOx) emissions to levels
meeting the Tier 4 Final engine emission standards.

BACT Requirements

Under the Utah Air Conservation Regulations (UACR), all new/modified sources of air pollution
emissions must install Best Available Control Technology (BACT) for emissions control (See: UACR
R307-401-2(d)). The BACT determination takes into account various factors, including energy,
environmental, and economic impacts of the emission control options under evaluation.

In the 2022 NOI, GCNRA proposed that BACT was achieving the Tier 4 interim emission
standards which were the best emissions control technology for nitrogen oxide (NOx) emissions that
was available at the time for Model Year 2014 engines.

UDAQ has since requested a supplemental BACT analysis to evaluate emission controls that
could achieve the Tier 4 Final standards listed in 40 CFR Part 1039. This report contains the BACT
evaluation for the SCR emissions control alternative.

BACT Analysis – Tier 4 Interim Engines Equipped with Selective Catalytic Reduction
This analysis addresses using selective catalytic reduction (SCR) to reduce NOx emissions at the
proposed Tier 4i engines to levels at or below the emission limits established for Tier 4 Final engines.

The BACT analysis has been prepared on a per engine basis. In addition, the BACT cost
calculations have been based on two engine operating scenarios: 100% load and 70% load. The SCR
reagent consumption varies depending on engine load, with the reagent consumption rate and associated
costs increasing at lower engine load conditions. The 70% load operating condition also likely represents
a more typical operating load for the proposed GCNRA engines.

The BACT cost analysis below is supported by a calculation spreadsheet, which is attached to
this report. Technical specifications provided by CAT on the proposed Tier 4i engines selected for the
BACT evaluation have been provided to UDAQ with prior application materials.

For the Tier 4i engines, the applicable emission standards are listed in Table 7 of
40 CFR 1039.102. For the purpose of this BACT analysis, the allowable Tier 4i standards represent the
assumed inlet concentration at the SCR control equipment. Table 7 in Part 1039 applies because the
C15 diesel-fired engines used to power the generators are by necessity larger than the generator capacity
(455 KW) to account for power losses at the generators.

As shown by the engine nameplate below, the proposed CAT C15 engines are regulated under
Part 1039 in the 560 to 900 KW power category.

For Tier 4i engines in the range of 560 to 900 KW, the applicable emission limits are as follows:

Pollutant PM NOx NMHC CO
Standard (g/Khar) 0.10 3.5 0.40 3.5

The applicable emission standards for the Tier 4 Final engine standards are listed in Table 1 of
40 CFR 1039.101. The allowable Tier 4 Final emissions standard represents the assumed outlet
concentration for the proposed Tier 4i engines after application of SCR. For engines sized above
560 KW that power generator sets, the applicable Tier 4 Final emission limits are as follows:

Pollutant PM NOx NMHC CO
Standard (g/Khar) 0.03 0.67 0.19 3.5

UDAQ has requested that the emissions control benefit for SCR be calculated using the
maximum allowable emission limits shown above. When the generator is at at 100% load (455 KW),
the operating load on the C15 engine is 672 hp or 501 KW (See CAT C15 engine spec sheet, attached).
This yields maximum allowable NOx emissions of 3.86 lb/hr at the SCR inlet and 0.74 lb/hr at the
SCR outlet. The net NOx reduction across the SCR control device for 100% load is therefore 3.12 lb/hr
or 13.67 tpy.

When the generator is at 70% load, the operating load on the C15 engine is 478 hp or 356 KW.
This yields maximum allowable NOx emissions of 2.74 lb/hr at the SCR inlet and 0.53 lb/hr at the SCR
outlet. The net NOx reduction across the SCR control device for 70% load is therefore 2.21 lb/hr or
9.68 tpy.

SCR Technical Description

In a typical SCR system, ammonia (NH3) is injected into the exhaust stream in the presence of a
catalyst. The NH3 reacts with the NOx emissions in the exhaust stream to create nitrogen gas (N2) and
water vapor (H2O).

In the SCR application on the proposed CAT C15 engines, the ammonia reagent is delivered by
injecting Diesel Exhaust Fluid (DEF), which is an aqueous solution of urea in water (32.5% urea with
67.5% de-ionized water). Urea decomposes to form ammonia at temperatures above 200 degrees C.

The DEF consumption rate varies with engine load. At 100% load, the expected DEF
consumption rate is 3.5 gal DEF per 100 gallons diesel fuel consumed. The C15 engines that operate
the 455 KW generator set have a listed fuel consumption rate of 33.0 gal/hr at 100% load, so the DEF
consumption at 100% load is 1.155 gal/hr. However, the DEF consumption rate increases at lower
engine loads, to a level as high as 5.5 gal DEF per 100 gallons diesel fuel consumed. For this BACT
analysis, the 70% load scenario uses DEF consumption at 5.0 gal DEF per 100 gallons diesel fuel.
At 70% load, the engine fuel consumption is 24.6 gal/hr and the associated DEF consumption would be
1.23 gal/hr. So, even at 70% operating load, the DEF consumption on a mass basis is similar to the
100% operating load scenario. The lower operating load (70%) is likely more typical of the expected
Bullfrog Marina engine operation as compared to full-time operation at 100% load.

On the proposed CAT engines, the SCR equipment must be manually started. As such, a site
operator is required for the SCR emissions control option. The start-up may occur once the required
operating conditions are achieved. The required operating conditions for SCR are: 1) the exhaust gas
temperature must be at or above 200 degrees C, 2) the pressure drop across the catalyst must be within
specified limits, and 3) the engine load must be within specified limits. Once the unit starts, the SCR
operation is electronically monitored and controlled.

In order to achieve maximum levels of NOx reductions, excess ammonia is typically injected
into the SCR units. The excess ammonia passes through the SCR unit, a phenomenon known as
“ammonia slip”. In the CAT engine SCR system, a second catalyst bed (Ammonia Oxidation Catalyst
or AMOX) is positioned downstream of the SCR catalyst bed to remove excess NH3 and help minimize
the level of ammonia slip.

Economic Factors

Capital costs for the SCR equipment and installation were provided by Caterpillar (equipment
costs of $100,000 and installation costs of $15,000 per engine). Consistent with the EPA Cost Control
Manual, indirect capital costs have been included for general facilities (5%), engineering (10%), and
process contingency (5%). Adding these factors increases the total capital cost (direct plus indirect) to
$138,000 per engine.

Additional factors as per the EPA Cost Control Manual include project contingency (15%),
preproduction costs (2%), plus the initial DEF inventory. The total capital investment for the SCR
equipment is calculated to be almost $160,000 per engine and the total capital costs to equip all six
C15 engines with SCR would be approximately $960,000. This level of capital expenditure has not been
budgeted by NPS and there is no assurance that such a large capital expenditure would be approved by
NPS in a timely manner.

In the BACT analysis, capital costs are recovered over the expected life of the equipment. For
this BACT analysis, the equipment life for the SCR alternative has been set at 10 years, which is the
engine useful life as defined by 40 CFR Part 1039, Table 4.

The capital cost recovery factor is 0.14903, as taken from the EPA Cost Control Manual,
Table A-2. This factor represents the 10-year project life at an interest rate of 8.0%. The interest rate is
based on the Federal Funds rate from April 25, 2023 (5.0%) plus a 3% margin, which represents the
normal difference between the Federal Funds rate and commercial lending rates. Using the above data,
the annualized capital recovery costs have been calculated to be $25,779 per year.

SCR operating costs considered in the BACT evaluation include the following:

• Operating & Maintenance (O&M) Labor: GCNRA is not an industrial plant. As such,
there are currently no on-site GCNRA staff capable of operating and maintaining
complex industrial equipment such as an SCR emissions control system. Also, as
mentioned above, the SCR startup requires manual intervention. As such, for the purpose
of the GCNRA BACT evaluation, there is a need to employ a full-time person to operate
and maintain the SCR equipment. The annual costs for O&M labor are priced based on
a full-time Facilities Operation Services position at the GS-7 level. Including fringe
benefits at 20%, the current annual payroll for a GS-7 staff member is $56,166. These
O&M costs have been divided equally over the six engines. Also, management and
supervision for this staff person is included at 10% of the annual labor costs.

• SCR Power Consumption: The SCR unit requires power to operate. For the SCR BACT
analysis, these costs are calculated based on an assumed power loss at the engine,
i.e., the power needed to operate the SCR unit is not available as engine power output.
The assumed power loss at the unit is 5 KW, which is approximately 1% of the engine
power output at 100% load. The diesel fuel consumption needed to produce 5 KW of
energy is used to compute these operating costs. The assumed diesel fuel cost is
$7.00 per gallon (the retail price for diesel fuel at the Bullfrog Marina as of late
April 2023 was $7.65/gal).

• Diesel Exhaust Fluid (DEF): The SCR requirements for the ammonia reagent
(diesel exhaust fluid) has been estimated at 3.5 gallons DEF per 100 gallons of diesel
fuel (100% load) and 5.0 gallons DEF per 100 gallons of diesel fuel (70% load). The
CAT spec sheet for the C15 Tier 4i engines lists fuel consumption of 33 gal/hr
(100% load and 24.6 gal/hr (70% load). DEF has a unit price of $7.50 per gallon
(delivered), yielding an annualized cost of approximately $75,000 (100% load) and
$80,000 (70% load). The DEF consumption is the largest factor in the annualized
operating costs for the SCR BACT alternative.

• Exhaust Catalyst Refurbishment: The SCR/AMOX catalyst degrades over time and must
be refurbished/replaced on a periodic basis. CAT recommends replacement of the
SCR/AMOX catalyst approximately every 20,000 engine operating hours. For the
BACT evaluation, it is assumed that the SCR/AMOX catalyst replacement occurs every
two years at a unit cost of $20,000. These assumptions yield an annualized cost of
$10,000 per year.

• PETU Filter Assembly Replacement: Similarly, CAT recommends replacement of the
PETU filter assembly at an interval of 5,000 engine operating hours. For the purpose of
the BACT evaluation, the assumption is that the PETU filter assembly is replaced twice
per year at a unit cost of $2,500. This yields an annualized cost of $5,000.

The annual cost for the SCR BACT alternative as described above ranges between
$149,000 to $154,000 per year depending on engine load. The annual SCR costs are dominated by the
DEF reagent consumption, which represent approximately 50% of the overall annual cost.

For the 100% load scenario, the estimated NOx emissions reduction (per engine) is 13.67 tpy,
which yields a calculated cost-effectiveness of just under $11,000 per ton of NOx reduced. For the
70% load condition (which is believed to better represent the typical engine operating loads at Bullfrog
Marina), the estimated NOx emissions reduction (per engine) is 9.68 tpy and the calculated
cost-effectiveness is almost $16,000 per ton of NOx reduced. The calculation details are provided in the
attached spreadsheet.

Energy Factors

As described above, the SCR operation comes with an energy penalty at the engines as generated
power goes to operate the SCR equipment as opposed to being available for external use. The
incremental fuel consumption associated with the engine power loss has been factored into the economic
factors listed above.

In addition, shipping the required DEF reagent to the Bullfrog Marina would require energy
associated with diesel and/or gasoline consumption associated with highway truck travel.

Environmental Factors

Adverse environmental factors associated with the SCR equipment include the following:

• Emissions of ammonia from the engine exhaust associated with SCR “ammonia slip”.

• Emissions from trucking the required SCR DEF volumes to the Bullfrog Marina. The
associated emissions would include NOx from diesel/gasoline truck exhaust, which would
in part offset the SCR NOx emissions control benefit. The trucking emissions would also
include greenhouse gases (GHG).

Conclusions

The SCR BACT alternative does not represent BACT because the calculated
cost-effectiveness for SCR ranges between $10,913 and $15,922 per ton NOx reduced depending on the
engine load. The proposed Bullfrog Marina engines are not likely to continuously operate at or near
100% load. As such, the higher end of the SCR cost range ($15,922 per ton NOx reduced) most likely
better represents the accurate costs for the SCR BACT alternative.

The projected costs to equip the proposed CAT C15 Tier 4i engines with SCR for the purpose of
reducing NOx emissions to levels equivalent to the Part 1039 Tier 4 Final engine emission standards is
excessive and would exceed the standard cost effectiveness level that represents BACT.

The Tier 4i engine alternative described in the NOI is BACT.



  
 
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01 

Supplemental Best Available Control Technology (BACT) Analysis
Bullfrog Marina Generator Project
Tier 4 Final Engine BACT Alternative

Prepared on behalf of National Park Service – Glen Canyon National Recreation Area
By Air Resource Specialists, Inc.
Supplement #2: March 2023

Introduction and Background

National Park Service (NPS) has submitted a Notice of Intent (NOI) to the Utah Division of
Air Quality (UDAQ) to install and operate new diesel-fired electrical power generation equipment at
the Bullfrog Marina within Glen Canyon National Recreation Areas (GCNRA). At Bullfrog, GCNRA
plans to install six (6) Model Year 2014 Caterpillar (CAT) Prime power generation sets sized at
455 kilowatts (KW) each. This equipment will replace older diesel-fired power generation equipment
at Bullfrog. The older generators will remain on-site to serve as backup capacity for the new
equipment.

The 2022 NOI replaces an earlier NOI submitted by GCNRA for the same equipment. UDAQ
approved the prior NOI and issued an Approval Order (AO) in 2015. GCNRA purchased the
equipment, but never installed the units and the AO expired. The purchased equipment meet the
Tier 4 interim emissions standards for diesel-fired equipment listed in 40 CFR Part 1039. The six
455 KW generators have been in storage since that time.

BACT Requirements

Under the Utah Air Conservation Regulations (UACR), all new/modified sources of air
pollution emissions must install Best Available Control Technology (BACT) for emissions control
(See: UACR R307-401-2(d)). The BACT determination takes into account various factors, including
energy, environmental, and economic impacts of the emission control options under evaluation.

In the 2022 NOI, GCNRA proposed that BACT was achieving the Tier 4 interim emission
standards which were the best emissions control technology for nitrogen oxide (NOx) emissions that
was available at the time for Model Year 2014 engines.

UDAQ has since requested a supplemental BACT analysis to evaluate emission controls that
could achieve the Tier 4 Final standards listed in 40 CFR Part 1039. An initial evaluation addressing
the Tier 4 Final BACT alternative was submitted in February 2023. UDAQ has asked some follow-up
questions regarding the Tier 4 Final BACT analysis which are addressed in this supplemental report.

Applicable Tier 4 Emission Standards from 40 CFR Part 1039

UDAQ has requested that GCNRA document the applicable emissions standards for the
Tier 4 engines proposed as BACT as well as the Tier 4 Final engines selected for the BACT alternative
analysis.

The apparent confusion regarding the applicable engine emission standards listed in Part 1039
exists because the proposed Bullfrog Marina generator sets are sized at 455 KW. However, the
diesel-fired engines used to power the generators are by necessity larger than 455 KW to account for
power losses at the generators. The maximum rated capacity for the diesel-fired engines on the
proposed generator units will exceed 560 KW (approximately 750 hp).

For the Tier 4i engines proposed as BACT, the applicable standards are listed in Table 7 of
40 CFR 1039.102. For Tier 4i engines in the range of 560 to 900 KW, the applicable emission limits
are as follows:

Pollutant PM NOx NMHC CO
Standard (g/KW-hr) 0.10 3.5 0.40 3.5

The applicable emission standards for the alternative Tier 4 Final engine standards are listed in
Table 1 of 40 CFR 1039.101. For engines sized above 560 KW that power generator sets, the
applicable emission limits are as follows:

Pollutant PM NOx NMHC CO
Standard (g/KW-hr) 0.03 0.67 0.19 3.5

The data listed above match the information on the applicable emission standards that have
been provided to UDAQ using the specification sheets for each of the engines under consideration.

Economic Factors

UDAQ questioned the February 2023 economic analysis for the Tier 4 Final BACT alternative
because the engine capital cost for was used to represent the capital cost of the emission controls
represented by the Tier 4 Final engines.

GCNRA stands by the economic analysis as provided in the February 2023 BACT analysis. In
this case, the only option to provide emission reductions equivalent to the Tier 4 Final standards is to
purchase a certified Tier 4 Final engine. In a Tier 4 Final engine, the emission controls are internal to
the engine itself and there is no way to differentiate between the cost for the emission controls and the
cost of the engine. One must purchase a Tier 4 Final engine in order to receive the associated emission
control benefits. As such, the engine costs are legitimate capital costs in the BACT economic analysis
as these are the real capital costs for achieving the desired level of emissions control.

This situation above is analogous to a low-NOx or ultra low-NOx boiler where the emission
controls are inherent to the emissions units itself. In these cases, the common practice is to use the
capital cost for the emissions unit as the emission control system capital cost because the associated
emission controls are not available separate from the entire emissions unit.

Also, according to the vendor (Caterpillar), an add-on emission control package that would
reduce emissions to the Tier 4 Final emissions level is not available for the proposed Tier 4i engine.
The only approach available to achieve emission reductions equal to the Tier 4 emissions standards is
to purchase a certified Tier 4 Final engine.

Actual vs. Allowable Emissions

UDAQ has questioned whether the emission control benefits in the February 2023 BACT
analysis should be based on allowable emissions vs. actual emissions. The Tier 4 BACT analysis
provided in February 2023 calculated the emission control benefits using actual emissions at
100% engine load using vendor data for the engines in question.

The engine manufacturers certify compliance with the Part 1039 engine standards using engine
test data across a specified range of operating conditions. As such, the emission limits listed in
Part 1039 may or may not represent the engine emissions at the operating load of interest. Since
compliance with Part 1039 is based on average emissions across a range of operating conditions, the
engine emissions at any given operating condition may in fact exceed the Part 1039 limits.

In the Tier 4 alternative BACT analysis, the focus was on the engine emissions at 100% load as
such emissions provide a reasonable estimate of maximum engine emissions. The engine emissions at
100% load were best represented by the manufacturers data, e.g., actual emissions at 100% load and
not the Part 1039 emission limits.

Conclusions

• As requested by UDAQ, the regulatory citations for the applicable Tier 4 Final and
Tier 4i engine emission standards have been provided. Although the generator power
output is 455 KW, the actual engine size is greater than 560 KW, which impacts the
applicable Part 1039 emissions standard. The applicable performance standards for the
proposed Tier 4i engines are listed in Table 7 of 40 CFR 1039.102. The applicable
performance standards for the alternative Tier 4 Final engine standards are listed in
Table 1 of 40 CFR 1039.101 (engines sized above 560 KW that power generator sets).

• The capital costs for the generator engines represents an accurate estimate the capital
costs necessary to meet the Tier 4 final engine emission standards. The requested level
of emissions control can only be achieved by purchasing a certified Tier 4 Final engine.

• The actual emissions as taken from vendor data on engine emissions is the best
representation for the emission control benefits of alternative BACT control strategies.
The engine emissions standard in Part 1039 represents the average emissions across a
range of operating conditions and may or may not accurately depict emissions at the
100% load operating condition.

Based on the above conclusions, the BACT review of the Tier 4 engine alternative previously
submitted to UDAQ in February 2023 is a true and accurate BACT analysis. The proposed Tier 4i
engines as listed in the NOI represent BACT.

The most compelling argument for the Tier 4i engines as BACT is that the Tier 4i engines are
immediately available for installation at the Bullfrog Marina and will provide an immediate and
significant emissions reduction compared to the current engines in use. By contrast, there would be a
26-month delay in the implementation of the Tier 4 Final BACT alternative based on the current
Caterpillar Tier 4 Final engine delivery times. During this 26-month period, the current engines with
higher NOx emissions would remain in service. As already documented in the February 2023 BACT
analysis, the Tier 4i BACT alternative would provide for an immediate reduction in NOx emissions.
In contrast, the 26-month delay in acquiring Tier 4 Final engines from the manufacturer means that the
Tier 4i BACT alternative and the associated immediate emission reductions would actually produce
lower NOx emissions over the life of the project.

The proposed Tier 4i engines represent BACT for the Bullfrog Marina generator project.



  
  
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DAQE-MN144440002-22

M E M O R A N D U M

TO: Enqiang He, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler

DATE: December 1, 2022

SUBJECT: Modeling Analysis Review for the Notice of Intent for Glen Canyon NRA – Bullfrog
Basin Marina, San Juan County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Glen Canyon NRA (Applicant) is seeking an approval order for their Bullfrog Basin Marina located
in San Juan County, Utah. The Applicant will be installing six (6) new diesel-fired generator
engines. Three existing diesel-fired generators will remain on site as emergency use generators.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

III. MODELING METHODOLOGY

A. Applicability

Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a
modified approval order. The emission rates for NOx triggered the requirement to model under
R307-410. Modeling was performed by the Applicant.

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

+ .
JK
DAQE-MN144440002-22
Page 2
B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 3740 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12

b. Approximate Location:

UTM (NAD83): 523631 meters East
415966 meters North

2. Urban or Rural Area Designation

After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is
“rural” for air modeling purposes.

3. Ambient Air

It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash

The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Page, AZ NWS: 2007-2011
Upper Air – Flagstaff, AZ NWS: 2007-2011

6. Background

The background concentrations were based on concentrations measured in Shiprock, New
Mexico.

7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.

DAQE-MN144440002-22
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

EMISSIONS

Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
EXISTING 523618 4153976 41.7102 2.086 100
NEW#1 523587 4153950 3.6600 16.031 8760
NEW#2 523583 4153949 3.6600 16.031 8760
NEW#3 523580 4153947 3.6600 16.031 8760
NEW#4 523576 4153945 3.6600 16.031 8760
NEW#5 523572 4153944 3.6600 16.031 8760
NEW#6 523569 4153942 3.6600 0.183 100

Total 63.6703 82.4229

10. Source Location and Parameters
PARAMETERS

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (ft)
EXISTING POINT 3735.0 12.2 40.0 786 31.93 0.53
NEW#1 POINT 3730.5 12.2 40.0 755 113.11 0.14
NEW#2 POINT 3730.0 12.2 40.0 755 113.11 0.14
NEW#3 POINT 3729.5 12.2 40.0 755 113.11 0.14
NEW#4 POINT 3729.0 12.2 40.0 755 113.11 0.14
NEW#5 POINT 3728.5 12.2 40.0 755 113.11 0.14
NEW#6 POINT 3727.9 12.2 40.0 755 113.11 0.14

DAQE-MN144440002-22
Page 4
IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the
NAAQS. The predicted total concentrations are less than the NAAQS.

RESULTS

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2
1-
Hour 163.9 7.5 9.7 0.0 173.6 188 92.34%
Annual 8.1 1.0 15.7 0.0 23.8 100 23.80%

V. PERMIT CONDITIONS

The following suggested permit language should be included under the Terms and Conditions in the
AO:

● The owner/operator shall not operate the emergency-use generator engines for than 100 hours
each per rolling 12-month period.
● The owner/operator shall limit readiness testing to one emergency-use generator at a time.
● The owner operator shall only conduct readiness testing between the hours of 9:00 am and 3:00
pm.

JMK:jg

{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}
EMISSIONS IMPACT ASSESSMENT
BULLFROG MARINA GENERATOR PROJECT
Applicant:
National Park Service – US Department of Interior
Glen Canyon National Recreation Area
PO Box 1507 – 691 Scenic View Road
Page, AZ 86040
NOI Prepared by:
1901 Sharp Point Drive, Suite F
Fort Collins, CO 80525
970-484-7941
www.air-resource.com
November 2022
TABLE OF CONTENTS
Section Page
Executive Summary 1
1.0 Introduction and Background 2
1.1 Overview 2
1.2 Site Description 2
2.0 Emissions and Source Description 4
2.1 Engine Emissions and Stack Exhaust Parameters 4
2.2 Generator Building Configuration 5
3.0 Dispersion Modeling Input Data 7
3.1 Model Selection and Technical Inputs 7
3.2 Receptor Inputs 7
3.3 Meteorological Data Inputs 9
3.4 Ozone Limiting Method 10
3.4.1 In-Stack NO2-to-NOX Ratio 10
3.4.2 Background Ozone Concentrations 11
3.4.3 Background NO2 Concentrations 12
4.0 Results and Discussion 14
LIST OF FIGURES
Figure Page
1-1 Bullfrog Location Map from Google Earth 3
2-1 Bullfrog Generator Project Generator Building Locations 5
3-1 AERMOD Receptor Grid, Bullfrog Generator Project 8
3-2 AERMOD Receptor Grid 50-meter Resolution, Bullfrog Generator Project 9
4-1 Predicted AERMOD 1-hour NO2 Concentrations Bullfrog Generator Project 15
LIST OF TABLES
Table Page
ES-1 Summary of Modeling Results 1
2-1 Bullfrog Emissions and Point Source Input Parameters 4
2-2 Bullfrog Generator Buildings: Building Dimensions 6
3-1 Background Ozone Concentrations (in ppb)12
3-2 1-Hour NO2 Season and Hour of Day Background Concentrations (ppb)13
4-1 Predicted NO2 Concentrations for NAAQS Compliance (GCNRA-Bullfrog)14
i
EXECUTIVE SUMMARY
This report documents the results of an air emissions impact assessment for nitrogen
oxide (NO2) from proposed diesel-fired electric power generators at the Bullfrog Marina in
Glen Canyon National Recreation Area (GCNRA). The dispersion modeling analysis has been
prepared on behalf of GCNRA by Air Resource Specialists, Inc. (ARS) of Fort Collins, CO.
GCNRA has proposed to install and operate diesel-fired internal combustion (IC) engines
at the Bullfrog Marina within GCNRA. A Notice of Intent (NOI) for this equipment has been
filed by GCNRA. Based on the emissions inventories in the NOI, the NOX emissions exceed
40 tons per year (tpy), and as such, trigger the need for an air emissions impact analysis under
State of Utah air quality guidelines. This report describes the air quality impact analysis and
documents the emissions from generator operations. The operations will not cause or contribute
to an exceedance of the allowable National Ambient Air Quality Standards (NAAQS).
The Utah Division of Air Quality (UDAQ) Emissions Impact Assessment Guidelines,
Table 1, provides minimum emission thresholds for selected regulated air pollutants that warrant
an emissions impact assessment using a dispersion model. Based on the emissions data presented
in the NOI, the NOX emissions from the Bullfrog Generator Project will exceed 40 tpy, and as
such, a dispersion modeling analysis is required. For pollutants other than NOX, the relevant NOI
document that emissions will be less than the modeling thresholds.
Dispersion modeling was conducted using the most recent regulatory version of the
AMS/EPA Regulatory Model (AERMOD, Version 21112). The modeling results are based on
five (5) years of meteorological data collected at Page, AZ for 2007-2011.
Modeling results are summarized in Table ES-1. The modeling results show that
operation of the proposed generator engines at Bullfrog Marina will not cause or contribute to an
exceedance of the NAAQS for NO2.
Table ES-1
SUMMARY OF MODELING RESULTS
Proposed Diesel-fired Electric Generators: Bullfrog Marina
Location Pollutant Averaging Time Maximum Air Quality
Impact NAAQS
Bullfrog NO2 1-Hour (1)185.69 µg/m3 (3) 188 µg/m3 (4)
Bullfrog NO2 Annual (2) 26.52 µg/m3 (3) 100 µg/m3
(1) 1-Hour model prediction based on the 5-year average of the 98th-percentile (daily maximums).
(2)Annual model prediction based on the highest annual concentration over the five-year modeling period.
(3)Includes the NO2 background concentration. Background NO2 concentrations vary by season and time-of-day.
(4)The 1-hour NO2 NAAQS is 100 parts per billion (ppb), measured as the 98th percentile daily maximum 1-hour
concentration averaged over three years. This converts to a mass concentration of 188 µg/m3
1
1.0 INTRODUCTION AND BACKGROUND
1.1 Overview
Glen Canyon National Recreation Area (GCNRA) is proposing to install and operate
diesel-fired reciprocating internal combustion engines (RICE) to provide electrical power to the
Bullfrog Marina (Bullfrog) within the GCNRA. Bullfrog is not currently serviced by commercial
power sources.
At Bullfrog, GCNRA proposes to install six (6) identical diesel-fired generators, sized at
455 kilowatts (KW) each. All generators will include a Caterpillar Model C15 diesel-fired engine
meeting US Environmental Protection Agency (USEPA) Tier 4 Interim emission specifications.
This dispersion modeling assessment is being provided in support of the
Notice of Intent (NOI) filed separately by GCNRA for the proposed generators at Bullfrog.
The modeling analysis is provided to assess compliance with the applicable National Ambient Air
Quality Standards (NAAQS). The dispersion modeling study and report were prepared by
Air Resource Specialists, Inc. (ARS) of Fort Collins, Colorado.
Consistent with applicable UDAQ modeling guidelines, the dispersion modeling analysis
assessed the predicted impacts of nitrogen dioxide (NO2). Only nitrogen oxide (NOX) emissions
at the proposed generator project were above the minimum thresholds established by UDAQ to
trigger a dispersion modeling assessment. Emissions for other regulated pollutants were less than
the UDAQ modeling thresholds.
Dispersion modeling was conducted using the most recent regulatory version of the
AMS/EPA Regulatory Model (AERMOD, Version 21112). ARS uses the AERMOD software
interface supplied by Providence-Oris dba Bee-Line Software. These modeling results are based
on five (5) years of meteorological data collected at Page, AZ for 2007-2011. Modeling followed
approved U.S. Environmental Protection Agency (USEPA) procedures, as contained in the
USEPA Guideline of Air Quality Models found in 40 CFR 51, Appendix W, as well as
procedures outlined in UDAQ’s Emissions Impact Assessment Guidelines.
1.2 Site Description
The GCNRA covers over 1.2 million acres along and near Lake Powell stretching from
Lees Ferry in Arizona northeastward to the Orange Cliffs in Utah. The primary uses for GCNRA
are water–based recreation on Lake Powell and backcountry recreation in the off-shore regions.
All lands within the GCNRA are managed by the National Park Service, part of the
U.S. Department of Interior.
2
Bullfrog is located on the north side of Lake Powell near the Utah Highway 276 ferry
crossing (Kane County). Figure 1-1 shows a Google Earth image of the Bullfrog site.
*Star indicates the location of the GCNRA Bullfrog Generator Building
Figure 1-1: Bullfrog Location Map – From Google Earth
3
2.0 EMISSIONS & SOURCE INFORMATION

Please refer to the Bullfrog NOI for detailed information regarding the emissions data
used in the modeling. All emissions and modeling data are based on continuous operation of the
new generator sets at 100% operating load (455 KW).

In addition, three existing RICE generator engines at Bullfrog will be retained for use in a
backup/standby capacity. The three existing generator engines were also included in the
modeling, but at a reduced operating rate.

2.1 Engine Emissions and Stack Exhaust Parameters

Table 2-1 shows the RICE engines emissions data and stack exhaust parameters for the
Bullfrog generator sets.

Table 2-1
Bullfrog Emissions and Point Source Input Parameters

Unit
ID
UTM E
(m)
UTM N
(m)

Elevation
(m)
Stack
Height
(m)
Temp
(K)
Velocity
(m/s)
Stack
Diameter
(m)
NOX Emissions
(g/s)
NEW1 523586.8 4153950.3 1137.05 12.192 755.37 113.108 0.1397 0.46
NEW2 523583.2 4153948.6 1136.89 12.192 755.37 113.108 0.1397 0.46
NEW3 523579.6 4153946.9 1136.74 12.192 755.37 113.108 0.1397 0.46
NEW4 523576.0 4153945.2 1136.60 12.192 755.37 113.108 0.1397 0.46
NEW5 523572.4 4153943.5 1136.45 12.192 755.37 113.108 0.1397 0.46
NEW6 523568.8 4153941.8 1136.26 12.192 755.37 113.108 0.1397 0.46
EXIST 523618.0 4153976.0 1138.44 12.192 785.93 31.9278 0.5334 5.25

For the six new engines, NOx emissions represent the manufacturer’s specifications for
engine operation at 100% load. The proposed generator sets will meet EPA Tier 4 Interim
emissions specifications. However, these specifications are based on the weighted average
emissions across a specific set of engine operating conditions and the emissions at any particular
load may be above or below the specification by a small margin. As the 100% load condition
represents the worst-case emissions rate, modeling has used the appropriate emissions level for
100% load based on the manufacturer specification sheet. Engine data for the 100% load
condition such as exhaust temperature, exhaust airflow, etc. were also used for the modeling. The
NOI contains the manufacturer’s engine data sheets documenting the emissions and other
modeling inputs.

For the existing engines, modeling included NOx emissions for the largest existing
engine (Caterpillar Model 3516, sized at 1275 KW). Emissions and other engine data used for
the modeling were determined using the engines specification sheet for a CAT 3516 engine as
obtained from the Internet and/or from other historical modeling conducted by ARS for a
CAT 3516 engine. It was assumed that the existing engines would be operated for testing
4
concurrently with the normal operation of the new engines, but that testing would occur for only
one engine at a given time. As such, NOx emissions from the largest existing engine was
simulated in the model.

As emergency/standby engines, the existing equipment would be allowed up to 100 hours
per year of operation (non-emergency operation, i.e. testing). The limited hours of operation
were simulated using the HRDOW7 keyword in AERMOD. It was assumed that the CAT 3516
emergency/standby engine would operate two days per week (MON/THU) between the hours of
9am and 3pm. The engine operating assumption (6 hr/day, 2 day/wk) equates to 624 hours per
year, which exceeds the engine operation allowed by regulation and represents a conservative
assumption.

2.2 Generator Building Configuration

Because the generator set stack heights are less than 2.5 time the height of nearby
buildings, the effect of these buildings has been included in the AERMOD modeling analysis.

At Bullfrog, the existing generator building is oriented roughly northwest-to-southeast
and the building houses three (3) existing RICE engines. The new generator building will be
constructed in the open area to the southwest of the existing generator building, with the new
building oriented roughly southwest-to-northeast. Figure 2-1 shows a Google Earth image of the
existing generator building with the location of the new building overlaid on the image. Building
dimensions are provided in Table 2-2.

Figure 2-1
Bullfrog Generator Project
Generator Building Locations

5

Table 2-2
Bullfrog Generator Buildings: Building Dimensions

Dimension Existing New
Length (m) 24.9 33.2
Width (m) 12.5 10.1
Height (m) 8.5 4.4

The building data were entered into the Building Profile Input Program (BPIP), which
calculates the crosswind building dimensions (length and width) along with building height for
each of the 36 cardinal wind directions. This modeling study used the version of BPIP supplied
with the Providence-Oris dba Bee-Line Software AERMOD interface. These data are then
transferred to the AERMOD modeling for the transport and dispersion calculations. Building
location data used the building corner UTM coordinates as extracted from Google Earth.

The BPIP data are included with the electronic modeling files included with this report.

6
3.0 DISPERSION MODELING INPUT DATA

3.1 Model Selection and Technical Inputs

Dispersion modeling was conducted using the AMS/EPA Regulatory Model
(AERMOD). All AERMOD technical options selected followed the regulatory default option.
Model inputs also specified rural conditions for dispersion coefficients and other variables.
AERMOD version 21112 was utilized for this analysis.

The application of AERMOD follows guidance from the EPA Guideline for Air Quality
Models (40 CFR 51, Appendix W), as well as procedures outlined in UDAQ’s Emissions Impact
Assessment Guidelines.

All modeling used the Universal Transverse Mercator (UTM) grid coordinates.
Electronic copies of the AERMOD input/output files have been provided to UDAQ with this
report.

3.2 Receptor Inputs

As explained previously, the GCNRA is comprised of over 1.2 million acres of public
lands bordering Lake Powell and covers portions of Kane, Garfield, and San Juan Counties in
southeastern Utah. Generally, access to public lands is unrestricted within GCNRA. However, in
the vicinity of certain NPS buildings (along with buildings supporting activities of the NPS
concessionaire), public access may be restricted. Where access is restricted, signs are posted
indicating that the area is off limits to the general public.

Near the Bullfrog generator buildings (See Figure 2-1), the surrounding area is not fenced
and nearby areas house a storage yard for personal watercraft. Since the general public may
access the area near the generator building in order to reach the storage yard, there is no
restricted access and all areas outside of the Bullfrog generator building were considered to be
“public access” for the AERMOD modeling analysis The two compressor building locations
were entered into the BEEST software interface as a “fenceline” so that receptors would not be
generated within the outline of the two compressor buildings.

Around each facility, receptors were originally placed on a Cartesian coordinate system
at a 50-meter interval out to a downwind distance of 200 meters and at a 100-meter interval out
to a distance of approximately 500 meters. Based on initial modeling results, the 50-meter grid
was extended generally to the north and east in order to assure that the maximum impact location
was captured within the 50-meter grid. Also, the 100-meter grid was extended out to
two (2) kilometers in order to capture impacts to elevated terrain located generally to the north of
the generator buildings.

The modeling results were evaluated for compliance with the recommendations in
UDAQ’s Emission Impact Assessment Guidelines (Page 14) to assure that the receptor density
was sufficiently dense such that that there was a high confidence that the maximum pollutant
concentration has been properly identified. In general, UDAQ recommends that the gradient of
7
the concentration between adjoining receptors should be less than 50% of the difference between
the NAAQS and the maximum predicted concentration at that receptor. The modeling results
around the maximum impact location were within the tolerance recommended in the Utah
guidelines.

The final AERMOD receptor grids are shown in Figure 3-1 and Figure 3-2. Figure 3-1
shows the overall receptor grid overlayed on a Goggle Earth image of the Bullfrog area. The
modeling used 2,165 receptors. Figure 3-2 is the same data, but for the denser 50-meter
resolution receptor grid located closer to the emission sources.

Figure 3-1
AERMOD Receptor Grid, Bullfrog Generator Project

8

Figure 3-2
AERMOD Receptor Grid 50-meter Resolution, Bullfrog Generator Project

Terrain elevations for receptors were determined from the 3D Elevation Program (3DEP)
maintained by the US Geological Survey (USGS). Data downloaded from USGS is not directly
compatible with AERMAP. However, EPA has converted the USGS 3DEP data to be
compatible with AERMAP and had made these data available on a public-facing website:
https://gaftp.epa.gov/Air/aqmg/3dep/. ARS downloaded the 1-arcsecond 3DEP data from the
EPA site for input to AERMAP. Terrain elevations for receptors, point sources, and buildings
were calculated using the most recent version of AERMAP (Version 18081) supplied with the
Beeline Software AERMOD model interface.

3.3 Meteorological Data Inputs

The meteorological data inputs for AERMOD were a five-year data set from the
National Weather Service (NWS) observation site at Page, AZ. The five-year period covered
2007-11. As these data are older, they were processed using an older version of AERMET
(Version 18081). UDAQ performed the AERMET data processing and provided these data
electronically to ARS. The meteorological data are included with the electronic modeling files.

UDAQ had also provided ARS with a newer meteorological data set for Page, AZ spanning
the period 2016 to 2020 processed with AERMET Version 21112. However, after initially using
the newer 2016-2020 data, it was found that this data set had excessive missing observations
(over 37 percent of hourly observations were flagged by AERMOD as missing). Due to the high
frequency of missing observations, the newer 2016-2020 data were deemed unusable and it was
decided to revert back to the older 2007-2011 meteorological data set.
9

3.4 Ozone Limiting Method

The 1-hour average NAAQS for NO2 requires more specific information for AERMOD
to properly execute. Under 40 CFR Part 51, Appendix W, Section 5.2.4, a three-tiered screening
approach is recommended for NO2 modeling. USEPA has stated that the
Appendix W recommendations regarding the annual NO2 standard are also applicable to the new
1-hour NO2 standard, with additional considerations.

For the GCNRA modeling analysis, the Ozone Limiting Method (OLM) has been applied
using AERMOD. Under OLM, the conversion of NO to NO2 during plume transport is assumed
to be limited by the available atmospheric ozone to complete the reaction:

NO + O3  NO2 + O2.

Within AERMOD, the user may select groups of individual sources that act as a coherent
plume to react with the available ozone. Otherwise, the model assumes that the background
ozone concentration is available to react with each plume individually, which would overstate
the available ambient ozone when individual plumes are transported downwind together. In the
Bullfrog modeling, the source emission points are in close proximity to one another and would
compete with each other for the available ambient ozone. So, at Bullfrog, all six (6) of the new
generator engines were considered one OLM group. The existing CAT 3516 engine, although
located nearby, was considered a separate OLM group. This approach added additional
conservatism to the analysis.

Application of the OLM option within AERMOD also requires additional data, including:
1) in-stack NO2-to-NOX ratios, 2) background ozone concentrations, and 3) background NO2
concentrations. These data are discussed below.

3.4.1 In-Stack NO2-to-NOX Ratio

In a memorandum dated March 1, 2011, EPA provided additional clarification regarding
application of Appendix W Modeling Guidance for the 1-hour NO2 NAAQS. While USEPA’s
guidance addresses a number of items, the most critical to the current modeling analysis was the
recommendation that the default in-stack ratio of NO2/NOX for the PVMRM/OLM options
within AERMOD should be 0.5, “in the absence of more appropriate source-specific
information”.

USEPA maintains a Microsoft Excel data base where information on measured in-stack
NO2/NOX ratios can be submitted by state/local regulatory agencies. ARS accessed the USEPA
database on October 15, 2022. The equipment type is listed within the Microsoft Excel
spreadsheet in Column L and the fuel in Column M. The EPA data were sorted in order to
extract information for RICE engines fired on diesel-fuel. Based on this step, data on
approximately 40 individual NOX emission tests were identified, mostly from IC electric
generator sets located in rural areas of Alaska, where power must be locally generated in rural
communities. The NO2-to-NOX ratio from these measurements is listed in Column AL of the
10
USEPA database. The entire USEPA database and the diesel-only extracted data have been
included with the electronic modeling files.

With a single exception, all of the IC engine tests for diesel-fired equipment show the
NO2-to-NOX in the range of 2.2% to 9.8%. One outlier in the EPA dataset showed a
NO2-to-NOX ratio of about 22%, but this engine was listed as having “LeanNOX” emission
controls with a NOx outlet concentration below 100 ppmdv. This engine was deemed to be not
representative of the type of diesel-fired generator engines proposed at Bullfrog. For this
modeling study, a NO2-to-NOX ratio of 8.8% has been identified, which represents the
90th percentile NO2-to-NOx ratio for the available testing data reported in the EPA database (the
fourth-highest test result was used because the data set had 39 different observations for
diesel-fired RICE engines).

3.4.2 Background Ozone Concentrations

Another required input for AERMOD-OLM modeling was the selected background
ozone concentration. In this instance, calendar year 2021 ozone data from a monitor operated by
the State of New Mexico in the vicinity of the San Juan Generating Station (Shiprock, NM) were
used to generate the background ozone estimates. UDAQ has recommended this monitoring data
as being representative of the Bullfrog location. The ozone data were downloaded using the
monthly Matrix Table format from https://aqi.air.env.nm.gov.

The AERMOD model applied the SEASHR keyword for the background ozone data,
meaning that the data were provided for each hour of the day sorted by season. The background
ozone concentrations input to AERMOD are provided in Table 3-1.

The ozone measurements were first sorted to obtain the maximum ozone concentration
by month for each hour of the day. The seasonal values required for AERMOD input were then
obtained by averaging the maximum hourly ozone concentrations for the individual months,
e.g., summer was calculated as the average of the maximum 1-hour ozone concentrations for
June, July, and August. This approach yields a conservative estimate which overstates the true
background ozone concentration for most hours. A spreadsheet documenting the calculation of
the background ozone values is included with the electronic modeling files.
11
Table 3-1: Background Ozone Concentrations (in ppb)
Hour of Day Winter Spring Summer Fall
1 42.33 52.00 49.67 44.33
2 43.33 50.00 48.00 43.67
3 45.33 49.67 46.00 43.67
4 43.67 49.00 46.00 39.67
5 43.00 49.33 45.00 41.67
6 42.33 48.67 43.67 41.33
7 42.00 47.67 44.67 42.67
8 40.67 47.33 48.33 41.00
9 40.33 52.67 54.67 42.00
10 40.33 55.67 61.00 46.67
11 42.00 56.33 67.33 49.00
12 43.67 57.33 71.67 52.00
13 46.33 58.33 78.00 55.33
14 45.67 60.33 77.67 58.00
15 48.33 60.00 75.00 59.67
16 46.33 59.33 76.00 57.67
17 47.67 59.67 75.67 57.33
18 45.67 58.67 75.33 54.67
19 45.00 56.67 69.67 51.67
20 42.67 53.00 65.00 51.00
21 42.33 53.67 64.67 48.33
22 41.67 53.00 62.33 47.00
23 43.67 54.00 57.33 47.67
24 42.33 50.67 52.33 45.67
3.4.3 Background NO2 Concentrations
Once the modeling results are obtained, a background NO2 concentration is added to the
modeling results that reflects the contribution of non-modeled emission sources to the total
atmospheric loading for NO2. As an option within AERMOD, the background contribution can
be calculated internally within AERMOD and ARS has selected that option.
Given the remote location of Bullfrog, background NO2 levels are believed to be low.
There are no significant industrial emission sources in the region, and local NO2 background is
generally contributed from local sources (motor vehicles and watercraft) and also long-range
transport from more distant emission sources. Actual background measurements for NO2 are
limited. UDAQ has recommended monitoring data from Shiprock, NM to define the NO2
background (the same monitoring site described above for background ozone). These data
probably overstate the true background given that the NO2 concentration data may be impacted
12
by two (2) coal-fired power plants in the region along with regional oil and gas emission sources
located in northwest New Mexico and southwest Colorado.
The nitrogen dioxide (NO2) data from the SJGS Shiprock monitoring site were
downloaded using the monthly Matrix Table format from https://aqi.air.env.nm.gov.
The AERMOD model applied the SEASHR keyword for the background NO2 data,
meaning that the data were provided for each hour of the day sorted by season. The background
NO2 concentrations input to AERMOD are provided in Table 3-2.
The NO2 measurements were first sorted to obtain the maximum concentration by month
for each hour of the day. The seasonal values required for AERMOD input were then obtained
by averaging the maximum hourly NO2 concentrations for the individual months,
e.g., summer was calculated as the average of the maximum 1-hour NO2 concentrations for
June, July, and August. This approach yields a conservative estimate which overstates the true
background concentration for most hours. A spreadsheet documenting the calculation of the
background NO2 values is included with the electronic modeling files.
Table 3-2
1-Hour NO2 Season and Hour of Day Background Concentrations (ppb)
1 2 3 4 5 6 7 8
Winter 14.33 15.33 15.67 16.33 13.67 18.00 16.33 17.67
Spring 8.67 9.33 8.33 7.67 9.33 10.00 13.00 15.67
Summer 4.67 5.33 8.00 6.67 8.00 7.00 10.67 12.67
Fall 11.33 13.67 9.67 9.00 13.00 14.33 14.67 14.33
9 10 11 12 13 14 15 16
Winter 15.00 14.33 20.67 20.33 16.33 14.33 11.00 11.67
Spring 14.33 15.67 7.67 8.33 8.00 6.00 3.33 4.67
Summer 18.00 14.33 10.00 8.33 3.67 2.00 2.00 3.33
Fall 14.00 14.67 13.67 10.67 8.33 7.33 4.33 7.00
17 18 19 20 21 22 23 24
Winter 10.33 10.67 9.67 9.33 8.67 11.33 11.67 12.00
Spring 5.67 3.00 2.67 5.00 7.33 3.67 4.67 6.67
Summer 4.67 4.33 4.33 7.33 9.00 7.33 8.00 7.00
Fall 7.00 9.00 6.33 4.67 5.33 6.67 9.00 10.33
13
4.0 RESULTS AND DISCUSSION

Table 4-1 summarizes the dispersion modeling results and documents compliance with
Federal and Utah NO2 air quality standards. Dispersion modeling results are presented using the
98th percentile of the maximum daily 1-hour NO2 concentrations averaged over the five (5) year
meteorological data set. The annual concentration represents the maximum annual mean
concentrations for the five-year meteorological data set, e.g., each year was modeled separately.
The background NO2 concentration is included within the reported modeling results.

The dispersion modeling predicts that all receptors in and near the Bullfrog Marina
comply with the primary NAAQS 1-hour average NO2 standard of 100 ppb (188 µg/m3) based on
the average of the 98th-percentile daily maximum concentration. Figure 4-1 shows the predicted
1-hour AERMOD NO2 concentrations around the maximum impact location (overlayed on a
Google Earth image). The maximum 1-hour NO2 concentration in AERMOD was predicted to
occur just to the east of the two generator buildings. Readers with an electronic copy of the
report can click on the image to enlarge the picture. A JPEG version of Figure 4-1 is also
included with the electronic modeling files.

The dispersion modeling also predicts that the highest annual average NO2 concentration
will comply with the primary NAAQS standard of 53 ppb (100 µg/m3).

Table 4-1
Predicted NO2 Concentrations for NAAQS Compliance (GCNRA-Bullfrog)

AVERAGING
PERIOD
NO2 MODEL
PREDICTION1
(µg/m3)
PRIMARY
NAAQS
(µg/m3)
RECEPTOR
UTM
(METERS)
E-W
RECEPTOR
UTM
(METERS)
N-S
1-Hour Average
(98th Percentile) 185.69 188 523,550 4,153,850
Annual Average2 26.52 100 523,700 4,153,950
1: Model prediction includes background concentration
2: Annual average is the maximum annual mean AERMOD result for the 5-year modeling period

14
Figure 4-1
Predicted AERMOD 1-hour NO2 Concentrations
Bullfrog Generator Project
15
AIR QUALITY NOTICE OF INTENT
BULLFROG GENERATOR PROJECT
Applicant:
National Park Service – US Department of Interior
Glen Canyon National Recreation Area
PO Box 1507
691 Scenic View Road
Page, AZ 86040
NOI Prepared by:
1901 Sharp Point Drive, Suite F
Fort Collins, CO 80525
970-484-7941
www.air-resource.com
November 2022
TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION & BACKGROUND 1-1
1.1 Overview 1-1
1.2 Project Location 1.2

2.0 NOI FORMS 2-1

3.0 AIR EMISSIONS INFORMATION 3-1
3.1 Air Emission Inventory 3-1
3.1.1 Caterpillar 455 KW Generator Sets 3-1
3.1.2 Existing Generator Engines 3-3
3.1.3 Fuel Storage Tanks 3-4
3.1.4 Emissions Summary 3-4
3.2 Separate Source Determination 3-5

4.0 BEST AVAILABLE CONTROL TECHNOLOGY 4-1

5.0 SUPPLEMENTAL DATA 5-1
5.1 Location of Planned Emission Sampling Points 5-1
5.2 Operating Schedule 5-1
5.3 Construction Schedule 5-1
5.4 Plans and Specifications 5-1

APPENDIX

TABLES & FIGURES
Table Page

3-1 Bullfrog Generator Emissions (455 KW) 3-1
3-2 HAP Emissions Summary – Bullfrog (Six 455 KW Caterpillar Generator Sets) 3-2
3-3 GHG Emissions Summary – Bullfrog (Six 455 KW Caterpillar Generator Sets) 3-2
3-4 Existing Bullfrog Marina Generator Equipment 3-3
3-5 Existing Bullfrog Marina Emissions Data 3-3
3-6 Bullfrog Emissions Summary (tons per year) 3-4
4-1 BACT Controls – Caterpillar Prime 455 KW Generator Set 4-2

Figure Page

1-1 GCNRA Bullfrog Marina Complex 1-2
1-2 GCNRA Bullfrog Marina Existing and Proposed Generator Buildings 1-3

i
1.0 INTRODUCTION & BACKGROUND
1.1 Overview
This document constitutes a formal Notice of Intent (NOI) pursuant to R307-401-5,
Utah Air Conservation Regulations (UACR), for approval to install and operate new diesel-fired
electric generator engines within the Glen Canyon National Recreation Area (GCNRA) at the
Bullfrog Marina, Bullfrog, UT. GCNRA is managed by the National Park Service (NPS),
U.S. Department of Interior.
At Bullfrog, GCNRA plans to install six (6) Model Year 2014 Caterpillar (CAT)
Prime power generation sets sized at 455 kilowatts (KW) each. Each generator set will utilize a
CAT Model C15 ATAAC diesel-fired engine. These generator sets will be fired on diesel fuel
and will meet the US Environmental Protection Agency (USEPA) Tier 4 Interim emission
standards valid for Model Year 2014 engines. The new generators are intended to replace older
aging electric generation equipment at Bullfrog. The older generator engines will remain onsite
to serve as backup capacity for the proposed new units.
This NOI replaces an earlier NOI submitted by GCNRA in 2014. In early 2015, the Utah
Division of air Quality (UDAQ) issued an Approval Order authorizing the installation and
operation of the six 455 KW engines at Bullfrog. At that time, the six 455 KW generator sets
approved by the AO were purchased; however, the permitted equipment was never installed and
the authorization under the AO expired. The six 455 KW generator sets have been in storage
since that time.
This NOI document provides all of the information required under R307-401-5, including
quantification for emissions of regulated air pollutants and a demonstration that emissions
control will utilize best available control technology (BACT). An air dispersion modeling
analysis is also required and is being provided in a separate document.
1-1
1.2 Project Location

The generator complex is located at the north end of the Bullfrog Marina. The proposed
455KW generator equipment will be housed in a new building constructed adjacent to the
existing generator building. Figure 1-1 shows a Google Earth image of the GCNRA Bullfrog
Complex showing the location of the generator building relative to other features of the
Bullfrog Marina. Figure 1-2 is a closeup view of the Bullfrog generator building complex. The
Google Earth image shows the existing generator building and the location of the adjacent new
generator building.

*Star indicates the location of the GCNRA Bullfrog Generator Buildings

Figure 1-1: GCNRA Bullfrog Marina Complex

1-2
Figure 1-2
GCNRA Bullfrog Marina
Existing and Proposed Generator Buildings
Proposed Building shown in Red Outline
1-3
2.0 NOI FORMS
This section of the NOI contains the relevant UDAQ application forms for the generator
engines and associated fuel storage tanks. Where the information is repeated for particular
equipment, only one set of forms is provided. For example, the NOI covers six (6) identical
Caterpillar 455 KW generator sets, but only one form covering the engines is included as the
data is identical for each generator set.
The required forms are:
•Form 2 – Notice of Intent
•Form 11 – Internal Combustion Engines, and
•Form 20 – Organic Liquid Storage Tanks
2-1
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
3.0 AIR EMISSIONS INFORMATION

This section describes the air emissions inventory for the proposed generator engines and
any ancillary equipment such as storage tanks for the diesel fuel. Other emission sources at the
Bullfrog Marina, including the marina and a gasoline service station operated by the on-site
GCNRA concessionaire have been determined to be separate emission sources under the
Clean Air Act and are not included in the NOI. Please see Section 3.2 for documentation of the
basis for the “separate sources” determination for the marina and service station.

The proposed equipment will replace older diesel-fired electric generation equipment and
as such, will produce electricity to support Bullfrog operations at a lower emissions level
compared to existing equipment. On an actual emissions basis, a significant decrease in
emissions is expected once the new generator equipment becomes operational.

3.1 Air Emissions Inventory

3.1.1 Caterpillar 455 KW Generator Sets

Table 3-1 summarizes the air emissions information for the proposed 455 KW Caterpillar
power generation equipment. The generators are each driven by a Caterpillar C15 ATAAC
four-stroke water cooled diesel engine that will meet the US Environmental Protection Agency
(USEPA) Tier 4 Interim emission standards for such equipment. The Tier 4 Interim standards
were those in effect at the time that the engines were manufactured (2014). The equipment will
also be fired using ultra low sulfur diesel (ULSD) fuel, with a sulfur content at or below
15 parts per million (ppm) by weight. A specification sheet and performance data for the
Caterpillar 455 KW generator set have been provided in Appendix A.

Table 3-1
Bullfrog Generator Emissions (New 455 KW Units)

Pollutant Tier 4 Interim
Std (g/KW-hr)
PTE based on
Tier 4 Std
(lb/hr)
Performance
Data at 100%
Load (lb/hr)
MAX (lb/hr)
NOX 3.5 3.51 3.66 3.66
CO 3.5 3.51 0.47 3.51
HC 0.4 0.40 0.47 0.47
PM 0.1 0.10 0.04 0.10

Please note that the Tier 4 Interim emission standards are represented by the engine
emissions over a weighted cycle average as per 40 CFR Part 1039 Subpart F. However, for any
particular load condition (such as the peak load), the generator emissions may actually exceed
the Tier 4 Interim level. As such, the potential-to-emit (PTE) calculation for the proposed
Caterpillar 455 KW engine has used the maximum emissions value, either described by the
Tier 4 Interim emissions level or the engine performance data for the peak load condition,
3-1
whichever yielded the higher emissions for a particular pollutant. If the pollutant of interest was
not covered under the Tier 4 Interim standard, then the engine performance data was used to
estimate the PTE for that particular regulated pollutant.

Hazardous air pollutant (HAP) emissions for the 455 KW generator set are shown in
Table 3-2. The HAP emissions are based on the engine performance data provided by Caterpillar
and cover four (4) regulated HAPs: formaldehyde, acrolein, acetaldehyde, and methanol. These
pollutants are the most significant HAP emitted by the proposed engines. Emissions of other
HAPs not listed in Table 3-2 are minor and not significant. HAPs emissions vary with engine
load and may be highest on a ppm basis for lower engine loads. For conservatism and to keep the
NOI emission calculations simple, the highest HAP ppm value at any load was combined with
the airflow rate at 100% load to generate the HAP emissions estimate. Even with these
conservative assumptions, the HAP emissions are small.

Table 3-2
HAP Emissions Summary – Bullfrog
(Six 455 KW Caterpillar Generator Sets – New Equipment)

Formula Molecular
WT
Exhaust
ppm
Exhaust
lb/hr Exhaust tpy
Total
HAPs (tpy)
6 Engines
Formaldehyde HCHO 30 2.84 0.013 0.06 0.35
Acrolein C3H4O 56 0.25 0.002 0.01 0.06
Acetaldehyde CH3CHO 44 2.18 0.015 0.07 0.40
Methanol CH3OH 32 0.43 0.002 0.01 0.06

Table 3-3 lists the greenhouse gas (GHG) pollutant emissions calculated from the fuel
combustion at the proposed engines. The main GHG pollutant of concern is carbon dioxide
(CO2). The CO2 emissions were calculated using the AP-42 emissions factor (Table 1.3-12)
assuming that fuel consumption was represented by continuous operations at 100% load.
AP-42 provides only data for CO2 emissions and no data are available to estimate emissions for
the other GHG pollutants. However, CO2 is the most important GHG pollutant emitted during
fuel combustion.

Table 3-3
GHG Emissions Summary – Bullfrog
(Six 455 KW Caterpillar Generator Sets – New Equipment)

Pollutant
Engine Fuel Use
(gal/hr) –
Per Engine
Engine Fuel Use
(gal/yr) – Total
AP-42
Emissions Factor
(lb/1,000 gal)
CO2 Emissions
(ton.yr)
CO2 33.0 1,734,480 22,300 19,339

3-2
3.1.2 Existing Generator Engines

There are three existing generator engines at Bullfrog, as listed below (Table 3-4):

Table 3-4
Existing Bullfrog Marina Generator Equipment

Generator Year Manufactured Engine Size/Load
hp KW
Caterpillar 3516 1989 1800 1275
Caterpillar 3512 1984 1300 970
Caterpillar 3516 1984 1300 1025

The three engines listed above (Table 3-4) will be retained for use as standby generator
capacity in the event that one or more of the new 455 KW generator engines is out-of-service.
Emissions for the existing engines have been calculated based on the Caterpillar engine
specification sheets for each engine under the assumption that each of the standby units will
operate 100 hours per year. The emissions data for the existing generator engines are shown in
Table 3-5. These calculations assume that the engine will operate at 100% load during testing.

Table 3-5
Existing Bullfrog Marina Emissions Data
(Based on 100 hrs/yr use as standby equipment)

Unit
Engine
Load
(hp)
Emissions Data
(from Caterpillar Specs:
STANDBY Use)
g/hp-hr
Annual Emissions (tpy)
Based on 100 hr/yr operation
NOx CO HC PM NOx CO HC PM
Cat 3516
(1989) 1800 10.52 1.4 0.04 0.08 2.09 0.28 0.01 0.02
Cat 3512
(1984) 1300 8.92 1.3 1.16 0.24 1.28 0.19 0.17 0.03
Cat 3516
(1984) 1300 10.52 1.4 0.04 0.08 1.51 0.20 0.01 0.01
TOTALS 4.87 0.66 0.18 0.06

3-3
3.1.3 Fuel Storage Tanks

Emissions for the diesel fuel storage tanks at the Bullfrog generator building were
estimated using the EPA TANKS model. The TANKS model output is provided in Appendix B.

GCNRA utilizes two identical above-ground horizontal tanks for diesel fuel storage at the
Bullfrog generator building. These tanks are approximately 32 feet long and 8 feet in diameter,
with a capacity of 12,000 gallons each.

Fuel throughputs for the emission calculations were estimated based on worst-case
assumptions, i.e., fuel use at 100% load for all engines for 8,760 hours per year. For the 455 KW
generator set, the maximum fuel consumption is 33 gal/hr per engine, which yields slightly more
than 1.73 million gallons of diesel fuel consumed on an annual basis for the total at all six (6)
engines. This converts to 867,240 gal/yr per storage tank, assuming that the tank utilization is
split equally. In reality, the diesel fuel consumption is much less; however, this approach yields a
worst-case emissions estimate for the diesel fuel storage tanks.

3.1.4 Emissions Summary

The total emissions for Bullfrog were estimated based on operating all six of the 455 KW
engines at 100% load for 8,760 hours per year, with operation limited to 100 hours per year for
the standby equipment. Volatile organic compound (VOC) emissions from the diesel fuel storage
were estimated as described above. Table 3-3 summarizes the annual emission totals for all
generator sets and the fuel storage tanks. Only NOX emissions exceed the air quality dispersion
modeling threshold. The dispersion modeling information is provided in a separate report.

Based on the worst-case assumptions described above, the total NOx emissions would
exceed the 100 tpy major source threshold. In order not to trigger the Title V operating permit
requirements, GCNRA will agree to a voluntary limit to restrict emissions to less than 100 tpy.
The voluntary GCNRA limit would equal 8,750 hours per year operating time (average) for the
new engines, or a total operating time of 52,500 hours per year across all six engines.

Table 3-6
Bullfrog Emissions Summary (tons per year)

NOX CO VOC PM
Six 455 KW Generator Sets (New) 96.18 92.18 12.35 2.63
Existing Generator Engines (Standby) 4.87 0.66 0.18 0.06
Two 12,000 gal Diesel Storage Tanks 0 0 <0.01 0
Total Facility Emissions 101.05 92.84 12.53 2.69
Voluntary GCNRA Emissions Limit 99.0 92.8 12.5 2.7

Dispersion Modeling Threshold 40 100 N/A 15

3-4
3.2 Separate Source Determination

GCNRA has been advised that the NOI for a particular location should consider all
known emission sources at that location. The GCNRA covers over 1.2 million acres along and
near Lake Powell stretching from Lees Ferry in Arizona northeastward to the Orange Cliffs in
Utah. The primary uses for GCNRA are water–based recreation on Lake Powell and backcountry
recreation in the off-shore regions. All lands within the GCNRA are managed by the
National Park Service, part of the U.S. Department of Interior.

When considering a large geographic area such as GCNRA, the analogous situation for
assessing the determination of “source” under the Clean Air Act is that of a military installation.
Military installations are similar to GCNRA is that they cover large parcels of land yet have
diverse air emission sources scattered over the property. The US Environmental Protection
Agency (USEPA) issued guidance in 1996 describing protocols for assessing whether or not
individual facilities within a single military installation should be aggregated as a single “source”
under the Clean Air Act (See: Major Source Determinations for Military Installations under the
Air Toxics, New Source Review, and Title V Operating Permit Programs of the Clean Air Act;
Memo from John S. Seitz, August 2, 1996). For the purposes of this NOI, the protocols for a
military installation have been adopted to define “source” within the confines of GCNRA.

First, physically separated emission units within the GCNRA have not been aggregated
based on the “common sense notion of a plant”. For the purpose of this particular NOI, only
emission units within the immediate Bullfrog geographic area have been considered. Emission
sources at other separate GCNRA recreation facilities such as Halls Crossing and Hite have not
been considered for aggregation. Emission sources are only considered for aggregation as a
single “source” where these are located within a distinct geographic region in proximity to one
another.

Also, under USEPA’s 1996 guidance for military installations, each pollutant-emitting
activity is assigned the 2-digit code under the Standard Industrial Classification (SIC) system
that best describes that individual operation. The recommended USEPA approach involves
considering each activity within the GCNRA in the same manner as most industrial and
commercial sources are distinguished; i.e., following the basis of a “common sense notion of a
plant”. The SIC code was assigned based on the primary activity at an individual facility, using
that facilities principal product and/or service.

Under the 1996 USEPA guidance for military installations, activities such as shopping
centers, grocery stores, and gas stations are listed as among the types of emission sources that
might be found on-site, but that would normally be considered as separate sources and not
aggregated. Bullfrog has two such emission units that are located within the legal GCNRA
boundaries that are operated for the convenience of the visitors using the Bullfrog site for
recreation: 1) the Bullfrog Marina, and 2) the Corner Store gasoline service station.

At the marina and service station, the emission sources of interest are storage tanks for
fuels (gasoline and/or diesel fuel) and well as fuel transfer facilities for use by watercraft and
automobiles.
3-5

The relevant SIC codes for each facility are as follows:

Marina: SIC Code 4493
Gasoline Station: SIC Code 5541
GCNRA: SIC Code 9512 (Land, Mineral, Wildlife, and Forest Conservation)

As shown above, each individual emissions unit within the Bullfrog region can be
identified using a unique 2-digit SIC Code (44 vs. 55 vs. 95). As such, these facilities are
separate and distinct emission sources under the Clean Air Act, following the USEPA guidance
for military installations as an appropriate model for making a similar “source” determination at
GCNRA. Given that the marina and gasoline service station are separate sources from the
GCNRA generator building, emissions from equipment not at the generator building are not
considered in the NOI.

3-6
4.0 BEST AVAILABLE CONTROL TECHNOLOGY

In Utah, a basic requirement at a new or modified emission source is that the emissions
control meet “best available control technology” (BACT). BACT is a defined term in the UACR
(See R307-401-2(d)):

Best Available Control Technology means an emissions limitation (including a
visible emissions standard) based on the maximum degree of reduction for each
air contaminant which would be emitted from any proposed stationary source or
modification which the Director, on a case-by-case basis, taking into account
energy, environmental, and economic impacts and other costs, determines is
achievable for such source or modification through application of production
processes or available methods, systems, and techniques, including fuel cleaning
or treatment or innovative fuel combustion techniques for control of such
pollutant.

BACT is typically selected following a “top-down” approach. First, available emissions
control technologies and/or work practices for the source and pollutant in question are ranked in
order where the best performing emissions control technology is ranked highest. The highest
ranked technology is then evaluated for energy, environmental, and economic impacts. If the
highest ranked technology is determined to represent BACT, the analysis is complete. If this
technology is determined not to represent BACT because of energy, environmental, and/or
economic factors, the analysis then defaults to the next highest ranked alternative. The analysis is
repeated until one of the selected technologies is determined to represent BACT.

The proposed Bullfrog Caterpillar Prime 455 KW diesel-fired generator sets will be a
operated using a Caterpillar C15 ATAAC diesel engine. Six identical 455 KW units are
proposed in this NOI. This equipment was manufactured in 2014 and was also purchased at the
time of the earlier permitting action (2014/15). This equipment has been in storage since that
time. The proposed equipment meets the USEPA Tier 4 Interim emission standards (Tier 4i)
which are listed in 40 CFR Part 1039. Tier 4i is the applicable Part 1039 emissions standard for
Model Year 2014 engines.

Features of the CAT Tier 4i emissions control systems include the following:

• Next Generation Fuel Systems: The CAT Tier 4i injection timing precisely
controls the fuel injection process and provides for improved fuel efficiency and
reduced emissions.

• Innovative Air Management: The CAT Tier 4i engines utilize simplified
turbocharging solutions that optimize engine performance and reduce emissions.

• CAT NOx Reduction System: The CAT Tier 4i engines sized under 900 KW
reduce NOx emissions by capturing and cooling a portion of the exhaust gas,
which reduced the engine firing temperature and associated emissions when this
gas is reintroduced into the combustion chamber.
4-1
• CAT Clean Emissions Module (CEM) for PM emissions reduction: Depending
on the specific engine model, CAT Tier 4i engines are equipped either with a
diesel oxidation catalyst and/or a diesel particulate filter. Also, for engines in the
130-560 KW range, the high-temperature CAT regeneration system (CRS) is also
used. The CRS elevates the temperature at optimum times such as steady-state
load conditions to burn off soot in the particulate filter and regenerate the system
for continued high-efficiency operation.

The Tier 4i emission controls described above represent the most stringent emissions
control available for 2014 model year diesel-fired internal combustion engines in the proposed
size category (455 KW). These controls reduce engine exhaust emissions for NOx, CO, VOC,
and PM to the maximum practical extent.

An additional post-combustion emission control technologies for reducing
NOx emissions at diesel-fired engines includes selective catalytic reduction (SCR). Although
SCR has been successfully applied on other diesel-fired engines, discussions with Caterpillar
representatives have indicated that SCR is not technically viable for the specific engines
proposed in this NOI. The Model Year 2014 Tier 4i engines proposed in this NOI meet the
applicable federal emission standards in 40 CFR Part 1039 without the use of SCR or other
post-combustion emission controls. Furthermore, these specific engines were not designed with
the expectation that SCR or other post-combustion controls would be applied and as such, SCR
and other post-combustion emission controls are not commercially available for these specific
engines.

For SO2 emissions control, the fuel choice for the engine is ultra-low sulfur diesel
(ULSD), with a maximum sulfur content of 15 ppm. ULSD fuel contains the lowest sulfur
concentration for any commercially-available diesel fuel.

The best performing emissions technology and/or work practice available for the specific
engines described in this NOI is planned for emissions control. As such, the emissions control
listed above by definition represents BACT. In summary, the proposed BACT for the
CAT 455 KW electric generators operated using a CAT C15 diesel-fired internal combustion
engines is listed in Table 4-1:

Table 4-1
BACT Controls – Caterpillar Prime 455 KW Generator Set

Pollutant NOX CO VOC PM SO2
BACT
Emission
Controls
Tier 4 Interim
Engine
Controls
Tier 4 Interim
Engine
Controls
Tier 4 Interim
Engine
Controls
Tier 4 Interim
Engine
Controls
ULSD Fuel

4-2
5.0 SUPPLEMENTAL DATA

This section provides other data required for the NOI as per R307-401-5.

5.1 Location of Planned Emission Sampling Points

There are no explicit emissions monitoring requirements in UACR or any of the
underlying federal regulations as they apply to the proposed 455 KW Caterpillar generator sets,
e.g., New Source Performance Standards (NSPS) at 40 CFR Part 60 and/or National Emission
Standards for Hazardous Air Pollutants (NESHAPs) at 40 CFR Part 63. Nevertheless, assuming
that stack emissions compliance testing may be required as a condition of the Approval Order at
one or more units, each exhaust stack will be equipped with testing ports as per the appropriate
USEPA testing methods in 40 CFR 60 Appendix A.

5.2 Operating Schedule

The NOI is based on all six Caterpillar engines operating full time at 100% load in order
to provide for a worst-case emission estimate. However, the engine utilization has been capped at
8,750 hours per year per engine on average (50,500 hours per year total for six engines) in order
to keep total facility emissions under 100 tpy NOx. Actual operation for the generator sets will
vary depending on the actual electrical demands at Bullfrog. It is expected that fewer than six
engines will be operating at any one time and engines may operate at less than 100% load.

Based on historical operating data, the average electrical load at GCNRA Bullfrog was
about 610 KW, with a peak load of about 1,450 KW. Peak loads above 1,200 KW have occurred
only on rare occasions (less than 15 hours per year based on historical data). Peak loads
typically occur during the summer when GCNRA recreation visits are highest.

5.3 Construction Schedule

Construction will be initiated as soon as possible following issuance of the required
Approval Order, The proposed Tier 4 Interim generator sets were acquired following the 2014
permit action and have been in storage since that time.

5.4 Plans and Specifications

Vendor information from Caterpillar concerning the proposed Tier 4 Interim generator
sets is provided elsewhere in the NOI.

5-1

APPENDIX

CATERPILLAR GENERATOR SPEC SHEET

LEHE0306-01

FEATURES

Image shown may not reflect actual package

Prime
455 ekW 568.7 kVA
60 Hz 1800 rpm 480 Volts

Caterpillar is leading the power generation
Market place with Power Solutions engineered to
deliver unmatched flexibility, expandability,
reliability, and cost-effectiveness.
FUEL/EMISSIONS STRATEGY
• EPA Tier 4 Interim

DESIGN CRITERIA
• The generator set accepts 100% rated load in
one step per NFPA 110 and meets ISO 8528-5
transient response.

UL 2200
• UL 2200 packages available. Certain
restrictions may apply. Consult with your Cat®
dealer.

FULL RANGE OF ATTACHMENTS
• Wide range of bolt-on system expansion
attachments, factory designed and tested
• Flexible packaging options for easy and cost
effective installation

SINGLE-SOURCE SUPPLIER
• Fully prototype tested with certified torsional
vibration analysis available

WORLDWIDE PRODUCT SUPPORT
• Cat dealers provide extensive post
sale support including maintenance and
repair agreements
• Cat dealers have over 1,800 dealer branch
stores operating in 200 countries.
• The Caterpillar S•O•SSM program effectively
detects internal engine component condition,
even the presence of unwanted fluids and
combustion by products.

CAT® C15 ATAAC DIESEL ENGINE
• Reliable, rugged, durable design
• Field proven in thousands of applications
worldwide
• Four-stroke diesel engine combines consistent
performance and excellent fuel economy with
minimum weight

CAT GENERATOR
• Matched to the performance and output
characteristics of Cat engines
• Single point access to accessory connections
• UL 1446 Recognized Class H insulation

CAT EMCP 4 CONTROL PANELS
• Simple user friendly interface and navigation
• Scalable system to meet a wide range of
customer needs
• Integrated Control System and Communications
Gateway

DIESEL GENERATOR SET
PRIME 455 ekW 568.7 kVA
60 Hz 1800 rpm 480 Volts

LEHE0306-01 2

FACTORY INSTALLED STANDARD & OPTIONAL EQUIPMENT

System Standard Optional
Air Inlet • Standard duty air filter [ ] Air cleaner- Single stage canister style
[ ] Heavy duty air filter- Single stage canister
w/pre-cleaner
Cooling • Radiator package mounted
• Coolant drain line with valve. Drain hose terminated at
edge
• Fan and belt guards
• Coolant level sight gauge
• Cat Extended Life Coolant
[ ] Radiator duct flange (open set only)
[ ] Radiator guard (open set only)

Exhaust • Dry exhaust manifold
• Male full V-band style flanged outlet
• Stainless steel flex with female
full V-band flange connections
[ ] Mufflers
[ ] Male full V-band weld flange with V-band clamp

Fuel • Primary fuel filter with integral water separator
• Secondary fuel filters-spin on
• Fuel priming pump
• Flex fuel lines
• Fuel cooler
[ ] 12 & 24 hour UL listed dual wall sub-base fuel tanks
with low fuel level switch
Generator

• Brushless Exciter
• Class H insulation
• IP 23 Protection
• VR6 voltage regulator with 3 phase sensing
[ ] Cat digital voltage regulator (Cat DVR) with reactive
droop control
[ ] Oversize harsh environment generators
[ ] Permanent magnet excitation
[ ] Anti-condensation space heaters
Power
Termination
• Power termination strips mounted inside power center
• Segregated low voltage wiring panel
• Bottom entry
[ ] Circuit breakers, UL/EC listed, 3 pole
[ ] Circuit breaker shunt trip
[ ] Circuit breaker auxiliary contact
Governor • ADEM™ A4 [ ] Load share module
Control
Panel

• EMCP 4.2 (rear mounted)
• Speed adjust
• Emergency Stop Pushbutton
• Voltage adjust
[ ] EMCP 4.4
[ ] Local annunciator modules (NFPA 99/110)
[ ] Remote annunciator modules (NFPA 99/110)
[ ] Discrete I/O module
Lube

• Lubricating oil and filter
• Oil drain line with valves
• Open crankcase ventilation (OCV) filter
• Gear type lube oil pump

Mounting

• Rails - engine / generator / radiator mounting
• Rubber vibration isolator

Starting /
Charging

• 24 volt starting motor
• Batteries with rack and cables (dry)
• 45 amp charging alternator
• Battery disconnect switch
[ ] Jacket water heater
[ ] 10 Amp UL recognized battery charger

General • Paint – Cat yellow except rails and radiators gloss
black

[ ] UL 2200 listed
[ ] CSA Certification

*Not included with packages without radiators
PRIME 455 ekW 568.7 kVA
60 Hz 1800 rpm 480 Volts

LEHE0306-01 3
SPECIFICATIONS

CAT GENERATOR
Frame ……………………..…………………….. 6124F
Excitation …………………………………………..…IE
Pitch………………………………………………0.6667
Number of poles……………………………………….4
Number of leads……………………………………..12
Number of bearings ……………….……………Single
Insulation ……………………………………….Class H
IP rating ………………………………..Drip proof IP23
Over speed capability - % of rated………………125%
Wave form deviation………………………………...2 %
Voltage regulator…………. 3 phase sensing with load
adjustable module
Voltage regulation….Less than ±1/2% (steady state)
Less than ±1/2% (3% speed change)
Telephone Influence Factor …………….Less than 50
Harmonic Distortion ……………………..Less than 5%

CAT DIESEL ENGINE
C15 ATAAC, L-6, 4 stroke, water-cooled diesel

Bore …………………………… ...137.20 mm (5.4 in)
Stroke ……………………………171.4 mm (6.75 in)
Displacement …………………...15.20 L (927.56 in3)
Compression ratio……………..………………..16:1
Aspiration…………………….….…….……….ATAAC
Fuel system…………………………….………..MEUI
Governor Type…….…………………….. ADEM™ A4

CAT EMCP 4 CONTROL PANELS
EMCP 4 controls including:
- Run / Auto / Stop Control
- Speed & Voltage Adjust
- Engine Cycle Crank
- Emergency stop pushbutton
EMCP 4.2 controller features:
- 24-volt DC operation
- Environmental sealed front face
- Text alarm/event descriptions
Digital indication for:
- RPM
- DC volts
- Operating hours
- Oil pressure (psi, kPa or bar)
- Coolant temperature
- Volts (L-L & L-N), frequency (Hz)
- Amps (per phase & average)
- Power Factor (per phase & average)
- kW (per phase, average & percent)
- kVA (per phase, average & percent)
- kVAr (per phase, average & percent)
- kW-hr & kVAr-hr (total)
Warning/shutdown with common LED indication
of shutdowns for:
- Low oil pressure
- High coolant temperature
- Overspeed
- Emergency stop
- Failure to start (overcrank)
- Low coolant temperature
- Low coolant level
Programmable protective relaying functions:
- Generator phase sequence
- Over/Under voltage (27/59)
- Over/Under Frequency (81 o/u)
- Reverse Power (kW) (32)
- Reverse Reactive Power (kVAr) (32RV)
- Overcurrent (50/51)
Communications
- Customer data link (Modbus RTU)
- Accessory module data link
- Serial annunciator module data link
- 6 programmable digital inputs
- 4 programmable relay outputs (Form A)
- 2 programmable relay outputs (Form C)
- 2 programmable digital outputs
Compatible with the following optional modules:
- Digital I/O module
- Local Annunciator
- Remote annunciator
- RTD module
- Thermocouple module
PRIME 455 ekW 568.7 kVA
60 Hz 1800 rpm 480 Volts

LEHE0306-01 4

TECHNICAL DATA

Open Generator Set - 1800 rpm/60 Hz/480 Volts PRIME
EM0176
Package Performance
Power rating
Power rating @ 0.8 pf

455 ekW
568.7 kVA
Fuel Consumption1
100% load with fan
75% load with fan
50% load with fan

124.8 L/hr 33.0 Gal/hr
99.0 L/hr 26.2 Gal/hr
72.3 L/hr 19.1 Gal/hr
Cooling System2
Ambient air temperature
Air flow restriction (system)
Air flow (max @rated speed)
Engine coolant Capacity with radiator arrangement)
Engine coolant capacity
Radiator coolant capacity

43 °C 109 °F
0.12 kPa 0.5 in water
913 m3/min 32,242 cfm
63 L 16.6 US Gal
27 L 7.1 US Gal
36 L 9.5 US Gal
Inlet Air
Combustion air inlet flow rate

39.7 m3/min 1402 cfm
Exhaust System
Exhaust stack gas temperature
Exhaust gas flow rate
Exhaust flange size (internal diameter)
Exhaust system backpressure (minimum allowable)3
Exhaust system backpressure (maximum allowable) 3

482 °C 900 °F
104 m3/min 3673 cfm
139 mm 5.5 in
1 kPa 4 in. water
10 kPa 40 in. water
Heat Rejection
Heat rejection to coolant (total)
Heat rejection to exhaust (total)
Heat rejection to atmosphere from engine
Heat rejection to atmosphere from generator

244 kW 13890 Btu/min
420 kW 23910 Btu/min
78.4 kW 4463 Btu/min
26 kW 1480 Btu/min
Alternator4
Motor starting capability @ 30% voltage dip
Frame
Temperature Rise

1712 skVA
LC6124F
105°C 189°F
Lube System5
Lube oil refill with filter change for standard sump

60 L 15.9 US Gal
Emissions (Nominal)6
NOx
CO
HC
PM

3.5 g/kW-hr 2.6 g/hp-hr
3.5 g/kW-hr 2.6 g/hp-hr
0.4 g/kW-hr 0.298 g/hp-hr
0.1 g/kW-hr 0.075 g/hp-hr

1 EPA Tier 4 Interim diesel engines required the use of Ultra Low Sulfur Diesel (ULSD) fuel in order to protect emissions control
systems, help comply with emissions standards, and meet published maintenance intervals. ULSD fuel will have < 15 ppm
(0.0015%) sulfur using the ASTM D5453, ASTM 2622, or SIN 51400 test methods.
2 For ambient and altitude capabilities consult your Cat dealer. Air flow restriction (system) is added to existing restriction from
factory.
3 Backpressure allowance is total backpressure available for the customer.
4 Some packages may have oversized generators with a different temperature rise and motor starting characteristics. Generator
temperature rise is based on a 40 degree C ambient per NEMA MG1-32.
5 Requires the use of CJ4 oil in order to meet published maintenance intervals.
6 Emissions data measurement procedures are consistent with those described in EPA CFR 40 Part 89, Subpart D & E and
ISO8178-1 for measuring HC, CO, PM, NOx. Data shown is based on steady state operating conditions of 77°F, 28.42 in HG and
number 2 diesel fuel with 35° API and LHV of 18,390 btu/lb. The nominal emissions data shown is subject to instrumentation,
measurement, facility and engine to engine variations. Emissions data is based on 100% load and thus cannot be used to compare
to EPA regulations which use values based on a weighted cycle.
PRIME 455 ekW 568.7 kVA
60 Hz 1800 rpm 480 Volts

LEHE0306-01 5

RATING DEFINITIONS AND CONDITIONS

Meets or Exceeds International Specifications: ·
AS1359, CSA, IEC60034-1, ISO3046, ISO8528, NEMA
MG 1-22, NEMA MG 1-33, UL508A, 72/23/EEC,
98/37/EC, 2004/108/EC

Prime -
Output available with varying load for an unlimited time.
Average power output is 70% of the prime power rating.
Typical peak demand is 100% of prime rated ekW with
10% overload capability for emergency use for a
maximum of 1 hour in 12. Overload operation cannot
exceed 25 hours per year. Prime power in accordance
with ISO3046. Prime ambients shown indicate ambient
temperature at 100% load which results in a coolant top
tank temperature just below the alarm temperature.

Ratings are based on SAE J1349 standard conditions.
These ratings also apply at ISO3046 standard conditions

Fuel Rates are based on fuel oil of 35º API [16º C (60º
F)] gravity having an LHV of 42 780 kJ/kg (18,390 Btu/lb)
when used at 29º C (85º F) and weighing 838.9 g/liter
(7.001 lbs/U.S. gal.). Additional ratings may be available
for specific customer requirements, contact your Cat
representative for details. For information regarding Low
Sulfur fuel and Biodiesel capability, please consult your
Cat dealer.

PRIME 455 ekW 568.7 kVA
60 Hz 1800 rpm 480 Volts

LEHE0306-01 6

DIMENSIONS

Package Dimensions
Length 4273 mm 169 in
Width 2058 mm 81 in
Height 2092 mm 83 in
Weight 3759 kg 8288 lb

www.Cat-ElectricPower.com

©2011 Caterpillar
All rights reserved.

Materials and specifications are subject to change without notice.
The International System of Units (SI) is used in this publication.

CAT, CATERPILLAR, their respective logos, "Caterpillar Yellow," the “Power
Edge” trade dress as well as corporate and product identity used herein, are
trademarks of Caterpillar and may not be used without permission.
NOTE: For reference only - do not use for
installation design. Please contact your
local dealer for exact weight and
dimensions.
General Dimension Drawing: 372-5845
Performance No. EM0176

Feature Code: C15DEBH

Gen. Arr. Number: 235-1212

Sourced: U.S. Sourced

LEHE0306-01 (06/11)


  
 
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01 

Standard Features
Standby
60 Hz ekW (kVA)
Mission Critical
60 Hz ekW (kVA)
Prime
60 Hz ekW (kVA)
Continuous
60 Hz ekW (kVA)Emissions Performance
1750 (2187)1750 (2187)1600 (2000)1450 (1750)Optimized for
Low Fuel Consumption
Image shown may not reflect actual configuration
Bore – mm (in)170 (6.69)
Stroke – mm (in)190 (7.48)
Displacement – L (in3)69 (4210.64)
Compression Ratio 13.5:1
Aspiration TA
Fuel System MUI
Governor Type Mechanical
Cat® Diesel Engine
• Designed and optimized for low fuel
consumption
• Reliable performance proven in thousands of
applications worldwide
Generator Set Package
• Accepts 100% block load in one step and meets
NFPA 110 loading requirements
• Conforms to ISO 8528-5 G3 load acceptance
requirements
• Reliability verified through torsional vibration,
fuel consumption, oil consumption, transient
performance, and endurance testing
Alternators
• Superior motor starting capability minimizes
need for oversizing generator
• Designed to match performance and output
characteristics of Cat diesel engines
Cooling System
• Cooling systems available to operate in ambient
temperatures up to 50°C (122°F)
• Tested to ensure proper generator set cooling
EMCP 4 Control Panels
• User-friendly interface and navigation
• Scalable system to meet a wide range of
installation requirements
• Expansion modules and site specific
programming for specific customer requirements
Warranty
• 24 months/1000-hour warranty for standby and
mission critical ratings
• 12 months/unlimited hour warranty for prime
and continuous ratings
• Extended service protection is available to
provide extended coverage options
Worldwide Product Support
• Cat dealers have over 1,800 dealer branch
stores operating in 200 countries
• Your local Cat dealer provides extensive
post-sale support, including maintenance and
repair agreements
Financing
• Caterpillar offers an array of financial products
to help you succeed through financial service
excellence
• Options include loans, finance lease,
operating lease, working capital, and revolving
line of credit
• Contact your local Cat dealer for availability in
your region
Cat® 3516
Diesel Generator Sets
LEHE1372-02 Page 1 of 4
3516 Diesel Generator Sets
Electric Power
LEHE1372-02 Page 2 of 4
Optional Equipment
Note: Some options may not be available on all models. Certifications may not be
available with all model configurations. Consult factory for availability.
Engine
Air Cleaner
 Single element
Dual element
Muffler
Industrial grade (15 dB)
Starting
Standard batteries
Oversized batteries
Standard electric starter(s)
Heavy duty electric starter(s)
Air starter(s)
Jacket water heater
Alternator
Output voltage
380V  6300V
440V  6600V
480V  6900V
600V  12470V
2400V  13200V
4160V  13800V
Temperature Rise
(over 40°C ambient)
150°C
125°C/130°C
105°C
80°C
Winding type
Random wound
Form wound
Excitation
Internal excitation (IE)
Permanent magnet (PM)
Attachments
Anti-condensation heater
 Stator and bearing temperature
monitoring and protection
Power Termination
Type
Bus bar
Circuit breaker
1600A  2000A
2500A  3000A
3200A  4000A
5000A
IEC  UL
 3-pole  4-pole
Manually operated
Electrically operated
Trip Unit
LSI LSI-G
LSIG-P
Control System
Controller
EMCP 4.2B
Attachments
Local annunciator module
Remote annunciator module
Expansion I/O module
Remote monitoring software
Charging
Battery charger – 10A
Battery charger – 20A
Battery charger – 35A
Vibration Isolators
 Rubber
 Spring
Seismic rated
Cat Connect
Connectivity
 Ethernet
 Cellular
Satellite
Extended Service Options
Terms
2 year (prime)
3 year
5 year
10 year
Coverage
Silver
Gold
Platinum
Platinum Plus
Ancillary Equipment
 Automatic transfer switch
(ATS)
 Uninterruptible power supply
(UPS)
Paralleling switchgear
Paralleling controls
Certifications
UL 2200 Listed
CSA
IBC seismic certification
 OSHPD pre-approval
3516 Diesel Generator Sets
Electric Power
LEHE1372-02 Page 3 of 4
Package Performance
Performance Standby Mission Critical Prime Continuous
Frequency 60 Hz 60 Hz 60 Hz 60 Hz
Gen set power rating with fan 1750 ekW 1750 ekW 1600 ekW 1400 ekW
Gen set power rating with fan @
0.8 power factor 2187 kVA 2187 kVA 2000 kVA 1750 kVA
Emissions Low Fuel Low Fuel Low Fuel Low Fuel
Performance number DM7958-02 EM0498-01 DM7959-03 DM7960-02
Fuel Consumption
100% load with fan – L/hr (gal/hr)469.8 (124.1)469.8 (124.1)437.5 (115.6)400.5 (105.8)
75% load with fan – L/hr (gal/hr)363.2 (95.9)363.2 (95.9)337.7 (89.2)309.2 (81.7)
50% load with fan – L/hr (gal/hr)256.4 (67.7)256.4 (67.7)238.9 (63.1)220.1 (58.1)
25% load with fan – L/hr (gal/hr)149.8 (39.6)149.8 (39.6)140.4 (37.1)130.7 (34.5)
Cooling System
Radiator air flow restriction (system) –
kPa (in. water)0.12 (0.48)0.12 (0.48)0.12 (0.48)0.12 (0.48)
Radiator air flow – m3/min (cfm)1671.0 (59010.0)1671.0 (59010.0)1671.0 (59010.0)1671.0 (59010.0)
Engine coolant capacity – L (gal)280.0 (61.6)280.0 (61.6)280.0 (61.6)280.0 (61.6)
Radiator coolant capacity – L (gal)195.5 (43.0)195.5 (43.0)195.5 (43.0)195.5 (43.0)
Total coolant capacity – L (gal)475.5 (104.6)475.5 (104.6)475.5 (104.6)475.5 (104.6)
Inlet Air
Combustion air inlet flow rate – m3/min (cfm)155.8 (5501.5)155.8 (5501.5)150.1 (5300.2)141.0 (4978.8)
Exhaust System
Exhaust stack gas temperature – °C (°F)512.8 (955.0)512.8 (955.0)505.4 (941.7)496.2 (925.2)
Exhaust gas flow rate – m3/min (cfm)428.1 (15116.8)428.1 (15116.8)408.3 (14417.4)378.8 (13375.8)
Exhaust system backpressure
(maximum allowable) – kPa (in. water)6.7 (27.0)6.7 (27.0)6.7 (27.0)6.7 (27.0)
Heat Rejection
Heat rejection to jacket water – kW (Btu/min)1028 (58463)1028 (58463)954 (54253)867 (49306)
Heat rejection to exhaust (total) – kW (Btu/min)1960 (111465)1960 (111465)1850 (105208)1690 (96109)
Heat rejection to aftercooler – kW (Btu/min)321 (118256)321 (118256)268 (15241)215 (12227)
Heat rejection to atmosphere from engine –
kW (Btu/min)142 (8075)142 (8075)140 (7962)138 (7848)
Heat rejection from alternator – kW (Btu/min)86 (4895)86 (4895)77 (4383)66 (3757)
Emissions* (Nominal)
NOx mg/Nm3 (g/hp-h)4370.3 (10.52)4370.3 (10.52)4286.0 (10.24)4422.4 (10.36)
CO mg/Nm3 (g/hp-h)583.7 (1.40)583.7 (1.40)572.5 (1.37)540.7 (1.27)
HC mg/Nm3 (g/hp-h)17.3 (0.04)17.3 (0.04)52.7 (0.13)89.0 (0.21)
PM mg/Nm3 (g/hp-h)32.1 (0.08)32.1 (0.08)66.6 (0.16)74.9 (0.18)
Emissions* (Potential Site Variation)
NOx mg/Nm3 (g/hp-h)5244.4 (12.62)5244.4 (12.62)5143.2 (12.28)5306.9 (12.43)
CO mg/Nm3 (g/hp-h)1050.7 (2.53)1050.7 (2.53)1030.5 (2.46)973.3 (2.28)
HC mg/Nm3 (g/hp-h)23.0 (0.06)23.0 (0.06)70.1 (0.17)118.4 (0.28)
PM mg/Nm3 (g/hp-h)44.9 (0.11)44.9 (0.11)93.2 (0.22)104.9 (0.25)
*mg/Nm3 levels are corrected to 5% O2. Contact your local Cat dealer for further information.
3516 Diesel Generator Sets
Electric Power
Weights and Dimensions
Dim “A”
mm (in)
Dim “B”
mm (in)
Dim “C”
mm (in)
Dry Weight
kg (lb)
6228 (245.2)2286 (90.0)2410 (94.9)13 080 (28,840)
Standby
Output available with varying load for the duration of
the interruption of the normal source power. Average
power output is 70% of the standby power rating. Typical
operation is 200 hours per year, with maximum expected
usage of 500 hours per year.
Mission Critical
Output available with varying load for the duration of
the interruption of the normal source power. Average
power output is 85% of the mission critical power rating.
Typical peak demand up to 100% of rated power for
up to 5% of the operating time. Typical operation is
200 hours per year, with maximum expected usage of
500 hours per year.
Prime
Output available with varying load for an unlimited time.
Average power output is 70% of the prime power rating.
Typical peak demand is 100% of prime rated ekW
with 10% overload capability for emergency use for a
maximum of 1 hour in 12. Overload operation cannot
exceed 25 hours per year.
Continuous
Output available with non-varying load for an unlimited
time. Average power output is 70-100% of the
continuous power rating. Typical peak demand is 100%
of continuous rated kW for 100% of the operating hours.
www.cat.com/electricpower
©2019 Caterpillar
All rights reserved.
Materials and specifications are subject to change without notice.
The International System of Units (SI) is used in this publication.
3516 PGFL
LEHE1372-02 (10/19)
A B
C
CAT, CATERPILLAR, LET'S DO THE WORK, their respective logos, “Caterpillar Yellow”,
the “Power Edge” and Cat “Modern Hex” trade dress as well as corporate and product
identity used herein, are trademarks of Caterpillar and may not be used without permission.
Note: For reference only. Do not use for installation design. Contact your local Cat dealer for precise weights and dimensions.
Ratings Definitions
Applicable Codes and Standards
AS 1359, CSA C22.2 No. 100-04, UL 142, UL 489,
UL 869, UL 2200, NFPA 37, NFPA 70, NFPA 99,
NFPA 110, IBC, IEC 60034-1, ISO 3046, ISO 8528,
NEMA MG1-22, NEMA MG1-33, 2014/35/EU,
2006/42/EC, 2014/30/EU.
Note: Codes may not be available in all model
configurations. Please consult your local Cat dealer
for availability.
Data Center Applications• ISO 8528-1 Data Center Power (DCP)
compliant per DCP application of Cat diesel
generator set prime power rating.• All ratings Tier III/Tier IV compliant per Uptime
Institute requirements.• All ratings ANSI/TIA-942 compliant for Rated-1
through Rated-4 data centers.
Fuel Rates
Fuel rates are based on fuel oil of 35º API [16°C (60ºF)]
gravity having an LHV of 42,780 kJ/kg (18,390 Btu/lb)
when used at 29ºC (85ºF) and weighing 838.9 g/liter
(7.001 lbs/U.S. gal.)
Standard Features
Standby
60 Hz ekW (kVA)
Mission Critical
60 Hz ekW (kVA)
Prime
60 Hz ekW (kVA)
Continuous
60 Hz ekW (kVA)Emissions Performance
1100 (1375)1100 (1375)1000 (1250)890 (1113)Optimized for Low Fuel Consumption
1250 (1563)1250 (1563)1135 (1419)1010 (1263)Optimized for Low Fuel Consumption
Image shown may not refl ect actual confi guration
Bore – mm (in)170 (6.69)
Stroke – mm (in)190 (7.48)
Displacement – L (in3)51.8 (3161.03)
Compression Ratio 13.5:1
Aspiration TA
Fuel System MUI
Governor Type Woodward
Cat® Diesel Engine
• Designed and optimized for low fuel
consumption
• Reliable performance proven in thousands of
applications worldwide
Generator Set Package
• Accepts 100% block load in one step and meets
NFPA 110 loading requirements
• Conforms to ISO 8528-5 G3 load acceptance
requirements
• Reliability verified through torsional vibration,
fuel consumption, oil consumption, transient
performance, and endurance testing
Alternators
• Superior motor starting capability minimizes
need for oversizing generator
• Designed to match performance and output
characteristics of Cat diesel engines
Cooling System
• Cooling systems available to operate in ambient
temperatures up to 50°C (122°F)
• Tested to ensure proper generator set cooling
EMCP 4 Control Panels
• User-friendly interface and navigation
• Scalable system to meet a wide range of
installation requirements
• Expansion modules and site specific
programming for specific customer requirements
Warranty
• 24 months/1000-hour warranty for standby and
mission critical ratings
• 12 months/unlimited hour warranty for prime
and continuous ratings
• Extended service protection is available to
provide extended coverage options
Worldwide Product Support
• Cat dealers have over 1,800 dealer branch
stores operating in 200 countries
• Your local Cat dealer provides extensive
post-sale support, including maintenance and
repair agreements
Financing
• Caterpillar offers an array of financial products
to help you succeed through financial service
excellence
• Options include loans, finance lease,
operating lease, working capital, and revolving
line of credit
• Contact your local Cat dealer for availability in
your region
Cat® 3512
Diesel Generator Sets
LEHE1246-03 Page 1 of 5
3512 Diesel Generator Sets
Electric Power
LEHE1246-03 Page 2 of 5
Optional Equipment
Engine
Air Cleaner
❑Single element
❑Dual element
❑Heavy duty
Muffler
❑Industrial grade (15 dB)
Starting
❑Standard batteries
❑Oversized batteries
❑Standard electric starter(s)
❑Dual electric starter(s)
❑Air starter(s)
❑Jacket water heater
Alternator
Output voltage
❑380V ❑6300V
❑416V ❑6600V
❑440V ❑6900V
❑480V ❑12470V
❑600V ❑13200V
❑4160V ❑ 13800V
Temperature Rise
(over 40°C ambient)
❑150°C
❑125°C/130°C
❑105°C
❑80°C
Winding type
❑Random wound
❑Form wound
Excitation
❑Internal excitation (IE)
❑Permanent magnet (PM)
Attachments
❑Anti-condensation heater
❑ Stator and bearing temperature
monitoring and protection
Power Termination
Type
❑Bus bar
❑Circuit breaker
❑1600A ❑ 2000A
❑2500A ❑ 3000A
❑3200A
❑UL ❑IEC
❑3-pole ❑ 4-pole
❑Manually operated
❑Electrically operated
Trip Unit
❑LSI ❑LSI-G
❑LSIG-P
Control System
Controller
❑EMCP 4.2B
Attachments
❑Local annunciator module
❑Remote annunciator module
❑Expansion I/O module
❑Remote monitoring software
Charging
❑Battery charger – 10A
❑Battery charger – 20A
❑Battery charger – 35A
Vibration Isolators
❑ Rubber
❑ Spring
❑Seismic rated
Cat Connect
Connectivity
❑Ethernet
❑Cellular
❑ Satellite
Extended Service Options
Terms
❑2 year (prime)
❑3 year
❑5 year
❑10 year
Coverage
❑Silver
❑Gold
❑Platinum
❑Platinum Plus
Ancillary Equipment
❑ Automatic transfer switch
(ATS)
❑ Uninterruptible power supply
(UPS)
❑Paralleling switchgear
❑Paralleling controls
Certifications
❑UL 2200 Listed
❑CSA
❑IBC seismic certification
❑ OSHPD pre-approval

Note: Some options may not be available on all models. Certifi cations may not be
available with all model confi gurations. Consult factory for availability.
3512 Diesel Generator Sets
Electric Power
LEHE1246-03 Page 3 of 5
Performance Standby Mission Critical Prime Continuous
Frequency 60 Hz 60 Hz 60 Hz 60 Hz
Gen set power rating with fan 1100 ekW 1100 ekW 1000 ekW 890 ekW
Gen set power rating with fan @
0.8 power factor 1375 kVA 1375 kVA 1250 kVA 1113 kVA
Emissions Low Fuel Low Fuel Low Fuel Low Fuel
Performance number DM8224-02 EM0831-00 DM8225-03 DM8226-02
Fuel Consumption
100% load with fan – L/hr (gal/hr)305.3 (80.7) 305.3 (80.7) 271.6 (71.7) 244.2 (64.5)
75% load with fan – L/hr (gal/hr)232.7 (61.5) 232.7 (61.5) 210.3 (55.5) 190.5 (50.3)
50% load with fan – L/hr (gal/hr)167.0 (44.1) 167.0 (44.1) 151.1 (39.9) 138.3 (36.5)
25% load with fan – L/hr (gal/hr)102.7 (27.1) 102.7 (27.1) 93.6 (24.7) 87.3 (23.1)
Cooling System
Radiator air flow restriction (system) –
kPa (in. water)0.12 (0.48) 0.12 (0.48) 0.12 (0.48) 0.12 (0.48)
Radiator air flow – m3/min (cfm)1133 (40011) 1133 (40011) 1133 (40011) 1133 (40011)
Engine coolant capacity – L (gal)156.8 (41.4) 156.8 (41.4) 156.8 (41.4) 156.8 (41.4)
Radiator coolant capacity – L (gal)130.0 (34.0)
Total coolant capacity – L (gal)286.8 (75.4) 286.8 (75.4) 286.8 (75.4) 286.8 (75.4)
Inlet Air
Combustion air inlet flow rate – m3/min (cfm)92.3 (3259.0) 92.3 (3259.0) 93.2 (3291.0) 85.2 (3008.5)
Exhaust System
Exhaust stack gas temperature – °C (°F)524.0 (975.2) 524.0 (975.2) 457.5 (855.5) 452.1 (845.8)
Exhaust gas flow rate – m3/min (cfm)258.9 (9141.4) 258.9 (9141.4) 238.1 (8407.6) 215.7 (7616.5)
Exhaust system backpressure (maximum
allowable) – kPa (in. water)6.7 (27.0) 6.7 (27.0) 6.7 (27.0) 6.7 (27.0)
Heat Rejection
Heat rejection to jacket water – kW (Btu/min)729 (41455) 729 (41455) 647 (36795) 580 (32984)
Heat rejection to exhaust (total) – kW (Btu/min) 1202 (68352) 1202 (68352) 1038 (59031) 933 (53058)
Heat rejection to aftercooler – kW (Btu/min) 134 (7619) 134 (7619) 139 (7905) 104 (5914)
Heat rejection to atmosphere from engine –
kW (Btu/min)122 (6938) 122 (6938) 118 (6711) 114 (6483)
Heat rejection from alternator – kW (Btu/min) 63 (3586) 63 (3586) 55 (3131) 48 (2732)
Emissions* (Nominal)
NOx mg/Nm3 (g/hp-h)4083.4 (8.92) 4083.4 (8.92) 4744.9 (9.39) 4809.7 (9.40)
CO mg/Nm3 (g/hp-h)593.6 (1.30) 593.6 (1.30) 469.4 (0.93) 427.6 (0.84)
HC mg/Nm3 (g/hp-h)74.1 (1.16) 74.1 (1.16) 140.4 (0.28) 177.8 (0.35)
PM mg/Nm3 (g/hp-h)108.2 (0.24) 108.2 (0.24) 71.9 (0.14) 69.0 (0.13)
Emissions* (Potential Site Variation)
NOx mg/Nm3 (g/hp-h)4900.1 (10.70) 4900.1 (10.70) 5693.9 (11.27) 5771.6 (11.29)
CO mg/Nm3 (g/hp-h)1068.4 (2.33) 1068.4 (2.33) 844.9 (1.67) 769.7 (1.50)
HC mg/Nm3 (g/hp-h)98.6 (0.22) 98.6 (0.22) 186.7 (0.37) 236.5 (0.46)
PM mg/Nm3 (g/hp-h)151.5 (0.33) 151.5 (0.33) 100.7 (0.20) 96.6 (0.19)
Package Performance
*mg/Nm3 levels are corrected to 5% O2. Contact your local Cat dealer for further information.
130.0 (34.0) 130.0 (34.0) 130.0 (34.0)
3512 Diesel Generator Sets
Electric Power
LEHE1246-03 Page 4 of 5
Performance Standby Mission Critical Prime Continuous
Frequency 60 Hz 60 Hz 60 Hz 60 Hz
Gen set power rating with fan 1250 ekW 1250 ekW 1135 ekW 1010 ekW
Gen set power rating with fan @
0.8 power factor 1563 kVA 1563 kVA 1419 kVA 1263 kVA
Emissions Low Fuel Low Fuel Low Fuel Low Fuel
Performance number DM8227-04 EM0831-00 DM8228-02 DM8229-02
Fuel Consumption
100% load with fan – L/hr (gal/hr)354.0 (93.5) 354.0 (93.5) 321.3 (84.9) 275.4 (72.8)
75% load with fan – L/hr (gal/hr)259.4 (68.5) 259.4 (68.5) 239.4 (63.2) 214.0 (56.5)
50% load with fan – L/hr (gal/hr)184.9 (48.9) 184.9 (48.9) 171.9 (45.4) 154.7 (40.9)
25% load with fan – L/hr (gal/hr)112.0 (29.6) 112.0 (29.6) 105.7 (27.9) 96.7 (25.6)
Cooling System
Radiator air flow restriction (system) –
kPa (in. water)0.12 (0.48) 0.12 (0.48) 0.12 (0.48) 0.12 (0.48)
Radiator air flow – m3/min (cfm)1614 (56997) 1614 (56997) 1614 (56997) 1614 (56997)
Engine coolant capacity – L (gal)156.8 (41.4) 156.8 (41.4) 156.8 (41.4) 156.8 (41.4)
Radiator coolant capacity – L (gal)
Total coolant capacity – L (gal)286.8 (75.4) 286.8 (75.4) 286.8 (75.4) 286.8 (75.4)
Inlet Air
Combustion air inlet flow rate – m3/min (cfm)106.0 (3742.9) 106.0 (3742.9) 104.7 (3697.0) 94.5 (3336.8)
Exhaust System
Exhaust stack gas temperature – °C (°F)541.7 (1007.0) 541.7 (1007.0) 507.7 (945.9) 457.8 (856.0)
Exhaust gas flow rate – m3/min (cfm)305.8 (10797.8) 305.8 (10797.8) 283.3 (10003.4) 241.6 (8530.9)
Exhaust system backpressure (maximum
allowable) – kPa (in. water)6.7 (27.0) 6.7 (27.0) 6.7 (27.0) 6.7 (27.0)
Heat Rejection
Heat rejection to jacket water – kW (Btu/min)845 (48053) 845 (48053) 763 (43390) 656 (37305)
Heat rejection to exhaust (total) – kW (Btu/min) 1432 (81434) 1432 (81434) 1275 (72506) 1053 (59882)
Heat rejection to aftercooler – kW (Btu/min) 227 (12909) 227 (12909) 192 (10918) 145 (8246)
Heat rejection to atmosphere from engine –
kW (Btu/min)126 (7165) 126 (7165) 123 (6995) 118 (6710)
Heat rejection from alternator – kW (Btu/min) 64 (3643) 64 (3643) 57 (3244) 48 (2732)
Emissions* (Nominal)
NOx mg/Nm3 (g/hp-h)5447.4 (9.93) 5447.4 (9.93) 5028.4 (9.81) 4727.0 (9.40)
CO mg/Nm3 (g/hp-h)709.8 (1.29) 709.8 (1.29) 581.6 (1.13) 474.9 (0.94)
HC mg/Nm3 (g/hp-h)54.3 (0.10) 54.3 (0.10) 95.1 (0.19) 134.9 (0.27)
PM mg/Nm3 (g/hp-h)105.8 (0.19) 105.8 (0.19) 88.7 (0.17) 72.6 (0.14)
Emissions* (Potential Site Variation)
NOx mg/Nm3 (g/hp-h)6536.9 (11.92) 6536.9 (11.92) 6034.1 (11.77) 5672.4 (11.27)
CO mg/Nm3 (g/hp-h)1277.6 (2.33) 1277.6 (2.33) 1046.9 (2.04) 854.8 (1.70)
HC mg/Nm3 (g/hp-h)72.2 (0.13) 72.2 (0.13) 126.5 (0.25) 179.4. (0.36)
PM mg/Nm3 (g/hp-h)148.1 (0.27) 148.1 (0.27) 124.2 (0.24) 101.6 (0.20)
Package Performance
*mg/Nm3 levels are corrected to 5% O2. Contact your local Cat dealer for further information.
130.0 (34.0) 130.0 (34.0) 130.0 (34.0) 130.0 (34.0)
3512 Diesel Generator Sets
Electric Power
Weights and Dimensions
Standby
60 Hz
ekW (kVA)
Mission Critical
60 Hz
ekW (kVA)
Prime
60 Hz
ekW (kVA)
Continuous
60 Hz
ekW (kVA)
Dim “A”
mm (in)
Dim “B”
mm (in)
Dim “C”
mm (in)
Dry Weight
kg (lb)
1100 (1375)1100 (1375)1000 (1250)890 (1113)5456 (214.8)1975 (77.8) 2367 (93.2)10 080 (22,210)
1250 (1563)1250 (1563)1135 (1419)1010 (1263)5556 (218.8)1975 (77.8) 2367 (93.2)10 270 (22,650)
Note: For reference only. Do not use for installation design. Contact your local Cat dealer for precise weights and dimensions.
Ratings Defi nitions
Standby
Output available with varying load for the duration of
the interruption of the normal source power. Average
power output is 70% of the standby power rating. Typical
operation is 200 hours per year, with maximum expected
usage of 500 hours per year.
Mission Critical
Output available with varying load for the duration of
the interruption of the normal source power. Average
power output is 85% of the mission critical power rating.
Typical peak demand up to 100% of rated power for
up to 5% of the operating time. Typical operation is
200 hours per year, with maximum expected usage of
500 hours per year.
Prime
Output available with varying load for an unlimited time.
Average power output is 70% of the prime power rating.
Typical peak demand is 100% of prime rated ekW
with 10% overload capability for emergency use for a
maximum of 1 hour in 12. Overload operation cannot
exceed 25 hours per year.
Continuous
Output available with non-varying load for an unlimited
time. Average power output is 70-100% of the
continuous power rating. Typical peak demand is 100%
of continuous rated kW for 100% of the operating hours.www.cat.com/electricpower
©2019 Caterpillar
All rights reserved.
Materials and specifications are subject to change without notice.
The International System of Units (SI) is used in this publication.
3512 PGFL
LEHE1246-03 (10/19)
A B
C
CAT, CATERPILLAR, LET'S DO THE WORK, their respective logos, “Caterpillar Yellow”,
the “Power Edge” and Cat “Modern Hex” trade dress as well as corporate and product
identity used herein, are trademarks of Caterpillar and may not be used without permission.
Applicable Codes and Standards
AS 1359, CSA C22.2 No. 100-04, UL 142, UL 489,
UL 869, UL 2200, NFPA 37, NFPA 70, NFPA 99,
NFPA 110, IBC, IEC 60034-1, ISO 3046, ISO 8528,
NEMA MG1-22, NEMA MG1-33, 2014/35/EU,
2006/42/EC, 2014/30/EU.
Note: Codes may not be available in all model
configurations. Please consult your local Cat dealer
for availability.
Data Center Applications• ISO 8528-1 Data Center Power (DCP)
compliant per DCP application of Cat diesel
generator set prime power rating.• All ratings Tier III/Tier IV compliant per Uptime
Institute requirements.• All ratings ANSI/TIA-942 compliant for Rated-1
through Rated-4 data centers.
Fuel Rates
Fuel rates are based on fuel oil of 35º API [16°C (60ºF)]
gravity having an LHV of 42,780 kJ/kg (18,390 Btu/lb)
when used at 29ºC (85ºF) and weighing 838.9 g/liter
(7.001 lbs/U.S. gal.)