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HomeMy WebLinkAboutDAQ-2024-007957 DAQE-AN161960001-24 {{$d1 }} Mark Montgomery Logan City Power 530 North 800 West Logan, UT 84321 mark.montgomery@loganutah.org Dear Mr. Montgomery: Re: Approval Order: New Natural Gas Power Plant Project Number: N161960001 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on January 18, 2024. Logan City Power must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Dungan Adams, who can be contacted at (385) 290-2474 or dunganadams@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:DA:jg cc: Bear River Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 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 29, 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")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN161960001-24 New Natural Gas Power Plant Prepared By Dungan Adams, Engineer (385) 290-2474 dunganadams@utah.gov Issued to Logan City Power - Logan Natural Gas Power Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality April 29, 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 ..................................................................................... 5 PERMIT HISTORY ..................................................................................................................... 7 ACRONYMS ................................................................................................................................. 8 DAQE-AN161960001-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Logan City Power Logan City Power - Logan Natural Gas Power Plant Mailing Address Physical Address 530 North 800 West Logan, UT 84321 Southeast Corner of West 1800 South and South 1000 West Logan, UT Source Contact UTM Coordinates Name: Mark Montgomery 428,472 m Easting Phone: (435) 716-9744 4,616,772 m Northing Email: mark.montgomery@loganutah.org Datum NAD83 UTM Zone 12 SIC code 4911 (Electric Services) SOURCE INFORMATION General Description Logan City Power is a utility company that has requested to operate four (4) 3,427 horsepower (hp) (2,558 kilowatt (kW)) natural gas-fired generator engines to generate electricity for the city of Logan in Cache County. Each generator engine will be equipped with a selective catalytic reduction (SCR) device and an oxidation catalyst (OC). The facility is classified as a peaking power plant. NSR Classification New Minor Source Source Classification Located in Attainment Area Cache County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark 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-AN161960001-24 Page 4 Project Description Logan City Power is a utility company that supplies electricity to the city of Logan, in Cache County. Logan City Power has requested to install four (4) 3,427 hp (2,558 kW) natural gas-fired generators that will operate continuously (8,760 hours per year). The engines are equipped with SCR and OC to reduce exhaust emissions. 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 54842.00 Carbon Monoxide 12.23 Nitrogen Oxides 9.27 Particulate Matter - PM10 3.49 Particulate Matter - PM2.5 3.49 Sulfur Dioxide 0.21 Volatile Organic Compounds 11.91 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acetaldehyde (CAS #75070) 2920 Acrolein (CAS #107028) 1796 Formaldehyde (CAS #50000) 13240 Generic HAPs (CAS #GHAPS) 802 Hexane (CAS #110543) 388 Methanol (CAS #67561) 874 Change (TPY) Total (TPY) Total HAPs 10.01 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] 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] DAQE-AN161960001-24 Page 5 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 Logan Natural Gas Power Plant 10.2 MW Facility II.A.2 Four (4) Generator Engines Model: Caterpillar G3520H Rating: 3,427 hp (2,558 kW) each Fuel: Natural Gas Control: SCR and OC NSPS/MACT Applicability: 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Facility-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from any source on site to exceed 10% opacity. [R307-401-8] DAQE-AN161960001-24 Page 6 II.B.1.a.1 Opacity observations of visible emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Natural Gas Generator Engine Requirements II.B.2.a The owner/operator shall equip each natural gas-fired engine with a SCR device and an OC to control emissions. [R307-401-8] II.B.2.b The owner/operator shall use only natural gas as fuel in all internal combustion engine generators. [R307-401-8] II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from each 2,558 kW Generator: Pollutant g/hp-hr NOx 0.07 CO 0.092 VOC 0.09 [R307-401-8] II.B.3.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.3.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] II.B.3.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.3.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.b.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.b.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.b.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.b.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] DAQE-AN161960001-24 Page 7 II.B.3.b.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.b.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.c 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.c.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.c.2 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.3.c.3 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated January 18, 2024 Incorporates Additional Information dated February 15, 2024 DAQE-AN161960001-24 Page 8 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-IN161960001-24 March 21, 2024 Mark Montgomery Logan City Power 530 North 800 West Logan, UT 84321 mark.montgomery@loganutah.org Dear Mr. Montgomery: Re: Intent to Approve: New Natural Gas Power Plant Project Number: N161960001 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, Dungan Adams, as well as the DAQE number as shown on the upper right-hand corner of this letter. Dungan Adams, can be reached at (385) 290-2474 or dunganadams@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:DA:jg cc: Bear River Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN161960001-24 New Natural Gas Power Plant Prepared By Dungan Adams, Engineer (385) 290-2474 dunganadams@utah.gov Issued to Logan City Power - Logan Natural Gas Power Plant Issued On March 21, 2024 {{$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 .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 6 PERMIT HISTORY ..................................................................................................................... 8 ACRONYMS ................................................................................................................................. 9 DAQE-IN161960001-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Logan City Power Logan City Power - Logan Natural Gas Power Plant Mailing Address Physical Address 530 North 800 West Logan, UT 84321 Southeast Corner of West 1800 South and South 1000 West Logan, UT Source Contact UTM Coordinates Name: Mark Montgomery 428,472 m Easting Phone: (435) 716-9744 4,616,772 m Northing Email: mark.montgomery@loganutah.org Datum NAD83 UTM Zone 12 SIC code 4911 (Electric Services) SOURCE INFORMATION General Description Logan City Power is a utility company that has requested to operate four (4) 3,427 horsepower (hp) (2,558 kilowatt (kW)) natural gas-fired generator engines to generate electricity for the city of Logan in Cache County. Each generator engine will be equipped with a selective catalytic reduction (SCR) device and an oxidation catalyst (OC). The facility is classified as a peaking power plant. NSR Classification New Minor Source Source Classification Located in Attainment Area Cache County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark 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-IN161960001-24 Page 4 Project Description Logan City Power is a utility company that supplies electricity to the city of Logan, in Cache County. Logan City Power has requested to install four (4) 3,427 hp (2,558 kW) natural gas-fired generators that will operate continuously (8,760 hours per year). The engines are equipped with Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) to reduce exhaust emissions. 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 54842.00 Carbon Monoxide 12.23 Nitrogen Oxides 9.27 Particulate Matter - PM10 3.49 Particulate Matter - PM2.5 3.49 Sulfur Dioxide 0.21 Volatile Organic Compounds 11.91 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acetaldehyde (CAS #75070) 2920 Acrolein (CAS #107028) 1796 Formaldehyde (CAS #50000) 13240 Generic HAPs (CAS #GHAPS) 802 Hexane (CAS #110543) 388 Methanol (CAS #67561) 874 Change (TPY) Total (TPY) Total HAPs 10.01 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 Herald Journal on March 23, 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 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. DAQE-IN161960001-24 Page 5 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] 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 Logan Natural Gas Power Plant 10.2 MW Facility DAQE-IN161960001-24 Page 6 II.A.2 Four (4) Generator Engines Model: Caterpillar G3520H Rating: 3,427 hp (2,558 kW) each Fuel: Natural Gas Control: Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) NSPS/MACT Applicability: 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ 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 Facility-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from any source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of visible emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Natural Gas Generator Engine Requirements II.B.2.a The owner/operator shall equip each natural gas-fired engine with a selective catalytic reduction (SCR) device and an oxidation catalyst (OC) to control emissions. [R307-401-8] II.B.2.b The owner/operator shall use only natural gas as fuel in all internal combustion engine generators. [R307-401-8] II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from each 2,558 kW Generator: Pollutant g/hp-hr NOx 0.07 CO 0.092 VOC 0.09 [R307-401-8] II.B.3.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.3.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] II.B.3.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] DAQE-IN161960001-24 Page 7 II.B.3.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.b.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.b.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.b.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.b.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.b.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.b.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.c 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.c.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.c.2 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.3.c.3 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] DAQE-IN161960001-24 Page 8 PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated January 18, 2024 Incorporates Additional Information dated February 15, 2024 DAQE-IN161960001-24 Page 9 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 494055 APG West Payment Processing PO Box 1570 Pocatello, ID 83204 Ph. 435-514-1830 ADVERTISING INVOICE Discount: $0.00 Surcharge: $0.00 Credits: $0.00 We Appreciate Your Business! Gross:$98.22 Paid Amount:$0.00 Amount Due:$98.22 Payments: Date Method Card Type Last 4 Digits Check Amount LINDA GOULDUTAH STATE DEPT. OF ENVIRONMENTAL QUALIT P.O. BOX 144820 SALT LAKE CITY, UT 84114 BILLING DATE: ACCOUNT NO: 03/21/24 5350 AD #DESCRIPTION START STOP TIMES AMOUNT 03/23/24 03/23/24 2 $98.22NOTICE A Notice of I494055 AD# 494055AD# NOTICE A Notice of Intent for the following project submitted in accor- dance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Logan City PowerLocation: Logan City Power - Logan Natural Gas Power Plant – Southeast Corner of West 1800 South and South 1000 West, Logan, UTProject Description: Logan City Power is a utility company that supplies electricity to the city of Logan, in Cache County. Logan City Power has requested to install four (4) 3,427 hp (2,558 kW) natural gas-fired generators that will operate con- tinuously (8,760 hours per year). The facility is classified as a peaking power plant. The engines are equipped with Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) to re- duce exhaust emissions. 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 avail- able 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 ad- dress on or before April 22, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at dunganad- ams@utah.gov. 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 com- ment period and was supported with sufficient information or documentation to enable the Director to fully consider the sub- stance and significance of the issue.Published: March 23rd, 2024 (HJ5350-494055) DAQE-NN161960001-24 March 21, 2024 The Herald Journal Legal Advertising Dept 1068 W 130 S Logan, UT 84321 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in The Herald Journal on March 23, 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 (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Bear River Association of Governments cc: Cache County 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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-NN161960001-24 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: Logan City Power Location: Logan City Power - Logan Natural Gas Power Plant – Southeast Corner of West 1800 South and South 1000 West, Logan, UT Project Description: Logan City Power is a utility company that supplies electricity to the city of Logan, in Cache County. Logan City Power has requested to install four (4) 3,427 hp (2,558 kW) natural gas-fired generators that will operate continuously (8,760 hours per year). The facility is classified as a peaking power plant. The engines are equipped with Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) to reduce exhaust emissions. 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 22, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at dunganadams@utah.gov. 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 23, 2024 {{#s=Sig_es_:signer1:signature}} Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N161960001 Owner Name Logan City Power Mailing Address 530 North 800 West Logan, UT, 84321 Source Name Logan City Power- Logan Natural Gas Power Plant Source Location Southeast Corner of W 1800 S and S 1000 W Logan, UT UTM Projection 428,472 m Easting, 4,616,772 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4911 (Electric Services) Source Contact Mark Montgomery Phone Number (435) 716-9744 Email mark.montgomery@loganutah.org Billing Contact Mark Montgomery Phone Number (435) 716-9744 Email mark.montgomery@loganutah.org Project Engineer Dungan Adams, Engineer Phone Number (385) 290-2474 Email dunganadams@utah.gov Notice of Intent (NOI) Submitted January 18, 2024 Date of Accepted Application February 21, 2024 Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 2 SOURCE DESCRIPTION General Description Logan City Power is a utility company that has requested to operate 4 (four) 3,427 horsepower (hp) (2,558 kilowatt (kW)) natural gas-fired generator engines to generate electricity for the city of Logan, in Cache County. Each generator engine will be equipped with a selective catalytic reduction (SCR) device and an oxidation catalyst (OC). The facility is classified as a peaking power plant. NSR Classification: New Minor Source Source Classification Located in Attainment Area Cache County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark 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 New Natural Gas Power Plant Project Description Logan City Power is a utility company that supplies electricity to the city of Logan, in Cache County. Logan City Power has requested to install four (4) 3,427 hp (2,558 kW) natural gas-fired generators which will operate continuously (8,760 hours per year). The engines are equipped with Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) to reduce exhaust emissions. EMISSION IMPACT ANALYSIS The source's criteria pollutant emission increases do not trigger the requirement for Logan City Power to conduct modeling for NOx under Utah Administrative Code R307-410-4. However, the source has elected to model for NO2 to demonstrate compliance with the NAAQS. The source is exempt from modeling for Hazardous Air Pollutants outlined in R307-410-5 because the source is subject to a MACT standard for HAP emissions. The UDAQ conducted l-hour NO2 modeling analysis. The results indicate the highest NO2 impact would be 93.51% of the NAAQS levels. No additional conditions or limitations are recommended. See Modeling Memorandum DAQE-MN161960001-24, dated February 7, 2024, for additional details. [Last updated March 11, 2024] Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 3 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 54842.00 Carbon Monoxide 12.23 Nitrogen Oxides 9.27 Particulate Matter - PM10 3.49 Particulate Matter - PM2.5 3.49 Sulfur Dioxide 0.21 Volatile Organic Compounds 11.91 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acetaldehyde (CAS #75070) 2920 Acrolein (CAS #107028) 1796 Formaldehyde (CAS #50000) 13240 Generic HAPs (CAS #GHAPS) 802 Hexane (CAS #110543) 388 Methanol (CAS #67561) 874 Change (TPY) Total (TPY) Total HAPs 10.01 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding Four (4) New Natural Gas-Fired Engines Logan City Power has proposed to install four (4) Caterpillar G3520H 4-stroke lean-burn engines that will be rated at 2,558 kW (3,427 hp) each. Nitrogen Oxides (NOx) NOx emissions from natural gas-fired engines occurs primarily through the formation of thermal NOx. Thermal NOx is created by the thermal dissociation and subsequent reaction of nitrogen (N2) and oxygen (O2) molecules in the combustion air. Factors affecting the generation of NOx include flame temperature, residence time, quantity of excess air, and nitrogen content of the fuel. Available pre-combustion controls include air-to-fuel ratio control and ignition system controls. According to EPA AP-42, Vol. I, 3.2 (Natural Gas-fired Reciprocating Engines), available post- combustion catalytic technologies include selective catalytic reduction (SCR) for lean-burn engines and nonselective catalytic reduction (NSCR) for rich-burn engines. All engines will be lean-burn engines. Therefore, only use of SCR was considered. The SCR process is based on chemical reduction of the NOx molecule. A nitrogen-based reducing agent (reagent), such as ammonia or urea, is injected into the post combustion flue gas. The reagent reacts selectively with the flue gas NOx within a specific temperature range and in the presence of the catalyst and oxygen to reduce the NOx to molecular nitrogen (N2) and water vapor (H2 O). SCR catalysts are composed of active metals or ceramics with a highly porous structure. Within the pores of the catalyst are activated sites. These sites have an acid group on the end of the compound structure where the reduction reaction occurs. Control for an SCR system is typically 70-90% reduction of NOx. The proposed engines will be equipped with an SCR. As per manufacturer's specifications, the SCR system will limit NOx emission rates to 0.07 g/bhp-hr in each engine. This emission rate is below the limit of 1.0 g/hp-hr of NOx specified in 40 CFR 60 Subpart JJJJ. DAQ is unaware of any other add-on control technologies that can further reduce NOx emissions and agrees that this emission rate is considered BACT for the proposed engines. Carbon Monoxide (CO) CO emissions from natural gas combustion occur due to incomplete combustion. CO is generated when there is insufficient time at high temperature to complete the final step in hydrocarbon oxidation. Available pre-combustion modifications include air-to-fuel ratio control and ignition system controls. Available post-combustion control options for CO emissions include SCR and oxidation catalysts. Oxidation catalysts are best suited for lean burn engines and were therefore considered for controlling CO emissions. Catalytic oxidation is a control technology which employs a module containing an oxidation catalyst that is located in the exhaust path of the burner system. In the catalyst module, CO diffuses through the surfaces of a ceramic honeycomb structure coated with noble metal catalyst particles. Oxidation reactions on the catalyst surface forms carbon dioxide and water. Vendor indications are that 93% reduction in CO emissions can be achieved based on the engine's exhaust temperature. Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 5 Therefore, the proposed engines will each be equipped with an oxidation catalyst. As per manufacturer's specifications, the oxidation catalyst system will limit CO emission rates to 0.092 g/hp-hr in each engine. These emission rates are below the limit of 2.0 g/hp-hr specified in 40 CFR 60 Subpart JJJJ. DAQ is unaware of any other add-on control technologies that can further reduce CO emissions and agrees that these emission rates are considered BACT for the proposed natural gas-fired engines. [Last updated March 12, 2024] 2. BACT review regarding Four (4) New Natural Gas-Fired Engines (Continued) VOCs/HAPs VOC emissions from natural gas combustion also occur due to incomplete combustion and can be controlled by the oxidation catalysts. The oxidation catalysts for the proposed engines are anticipated to reduce VOC concentrations by approximately 50%. As per manufacturer's specifications, the VOCs emission rates will be limited to 0.09 g/bhp-hr in each engine. These emission rates are below the limit of 0.7 g/hp-hr specified in 40 CFR 60 Subpart JJJJ. Many HAP components are emitted through the same process as VOCs and the control technologies for VOCs also control HAPs. Formaldehyde is the predominant HAP component emitted from natural gas combustion. The oxidation catalysts for the proposed engines are anticipated to reduce Formaldehyde concentrations by approximately 75%. Formaldehyde and other HAPs emissions will be controlled by the SCR and oxidation catalyst systems for the proposed engines. This is considered BACT. DAQ is unaware of any other add-on control technologies that can further reduce VOCs/HAPs emissions and agrees that the above-mentioned emission rates are considered BACT for the proposed engines. Particulates (PM10 /PM2.5) The combustion of natural gas in the engines will result in minor PM10 /PM2.5 emissions. NSPS 40 CFR 60 Subpart JJJJ does not set PM emission limits for these types of engines. Available control options for PM emissions include conducting proper maintenance and good combustion practices. Therefore, BACT to control particulate emissions from the natural gas-fired is best operating practices Sulfur Dioxide (SO2) Sulfur dioxide emissions are a result of sulfur present in the natural gas. The only economic control option identified for reducing SO2 is the use of good combustion practices. BACT Determination Based on information provided above, DAQ recommends the following measures as BACT for the natural gas-fired engines: 1. Use of selective catalytic reduction (SCR) technology and an oxidation catalyst (OC) with air/fuel ratio and lean burn design. 2. Limit exhaust concentrations, in g/bhp-hr, in the 2,558 kW (3,427 hp) engines to 0.07 of NOx, 0.092 of CO, and 0.09 of VOCs. 3. Conduct manufacturer recommended maintenance and testing. 4. Limit visible emissions to 10% opacity. Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 6 [Last updated March 12, 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] 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] Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 7 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 NEW Logan Natural Gas Power Plant 10.2 MW Facility II.A.2 NEW Four (4) Generator Engines Model: Caterpillar G3520H Rating: 3,427 hp (2,558 kW) each Fuel: Natural Gas Control: Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) NSPS/MACT Applicability: 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ 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 Facility-Wide Requirements II.B.1.a NEW The owner/operator shall not allow visible emissions from any source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 NEW Opacity observations of visible emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 NEW Natural Gas Generator Engine Requirements II.B.2.a NEW The owner/operator shall equip each natural gas-fired engine with a selective catalytic reduction (SCR) device and an oxidation catalyst (OC) to control emissions. [R307-401-8] II.B.2.b NEW The owner/operator shall use only natural gas as fuel in all internal combustion engine generators. [R307-401-8] II.B.3 NEW Stack Testing Requirements Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 8 II.B.3.a NEW The owner/operator shall not emit more than the following rates and concentrations from each 2,558 kW Generator: Pollutant g/hp-hr NOx 0.07 CO 0.092 VOC 0.09. [R307-401-8] II.B.3.a.1 NEW Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.3.a.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] II.B.3.a.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.3.b NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.b.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.b.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.b.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.b.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.b.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] Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 9 II.B.3.b.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] II.B.3.c 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.c.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.c.2 NEW VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.3.c.3 NEW CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 10 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated January 18, 2024 Incorporates Additional Information dated February 15, 2024 REVIEWER COMMENTS 1. Comment regarding Source Emission Estimates: Emission estimates are based on manufacturer data and EPA guidance as published in Compilation of Air Pollution Emission Factors, Volume I: Stationary Point and Area Sources or AP-42, Section 3.2, Natural Gas-fired Reciprocating Engines Tables 3.2-1, 3.2-2, and 3.2-3. The manufacturer provided a NOx emission concentration of 1.0 g/hp-hr at the catalyst inlet and guaranteed a NOx emission concentration of 0.07 g/hp-hr at the catalyst outlet. The manufacturer provided a CO emission concentration of 1.32 g/hp-hr at the catalyst inlet. The catalyst results in a 93% reduction in CO emissions, resulting in a CO emission concentration of 0.092 g/hp-hr at the catalyst outlet. The manufacturer provided a VOC emission concentration of 0.18 g/hp-hr at the catalyst inlet. The catalyst results in a 50% reduction of VOC emissions, resulting in a VOC emission concentration of 0.09 g/hp-hr at the catalyst outlet. The manufacturer provided a Formaldehyde emission concentration of 0.20 g/hp-hr at the catalyst inlet. The catalyst results in a 75% reduction of Formaldehyde emissions, resulting in a Formaldehyde emission concentration of 0.05 g/hp-hr at the catalyst outlet. Each engine is assumed to run 8,760 hours per year. [Last updated March 12, 2024] 2. Comment regarding Federal Subpart Applicability: NSPS 40 CFR 60 Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines) applies to engines that were ordered after June 12, 2006, and manufactured on or after July 1, 2007, for engines with maximum power greater than or equal to 500 hp (§60.4230(a) (4)(i)). Thus, NSPS Subpart JJJJ applies to the Logan City Power Plant as the four (4) 2.56 MW (3,427 hp) generator engines were ordered after June 12, 2006, and manufactured after July 1, 2007. MACT 40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) is applicable to owners/operators of stationary RICE at a major or area sources of HAP emissions. MACT Subpart ZZZZ applies to the Logan City Power Plant as the engine generators are new RICE. Thus, MACT Subpart ZZZZ applies to the source as the Logan City Power Plant is an area source of HAP emissions. The generator engines will meet 40 CFR 63 Subpart ZZZZ by meeting 40 CFR Part 60, Subpart JJJJ. [Last updated February 23, 2024] Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 11 3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a Title IV source or a major source. The facility is not subject to 40 CFR 61 (NESHAP) regulations. The facility is subject to 40 CFR 60 (NSPS) Subpart JJJJ and to 40 CFR 63 (MACT) Subpart ZZZZ. NSPS Subpart JJJJ and MACT Subpart ZZZZ each specifically except sources from the requirement to obtain a Title V permit provided that the source is not required to obtain the permit for any other reason. No such reasons exist for this source. Therefore, Title V does not apply to the source. [Last updated February 23, 2024] Engineer Review N161960001: Logan City Power- Logan Natural Gas Power Plant March 12, 2024 Page 12 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 DAQE-MN161960001-24 M E M O R A N D U M TO: Dungan Adams, NSR Engineer FROM: Jason Krebs, Air Quality Modeler DATE: February 7, 2024 SUBJECT: Modeling Analysis Review for the Notice of Intent for Logan City Power – Logan Natural Gas Power Plant, Cache County, Utah _____________________________________________________________________________________ This is not a Major Prevention of Significant Deterioration (PSD) Source. I. OBJECTIVE Logan City Power (Applicant) is seeking an approval order for their Logan Natural Gas Power Plant located in Cache County, Utah. 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 new 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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- MN161960001-24 Page 2 B. Assumptions 1. Topography/Terrain The Plant is at an elevation 4480 feet with terrain features that have an affect on concentration predictions. a. Zone: 12 b. Approximate Location: UTM (NAD83): 428462 meters East 4616796 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 – Logan-Cache Airport, UT NWS: 2016 - 2020 Upper Air – Salt Lake Airport, UT NWS: 2016 - 2020 6. Background The background concentrations were based on concentrations measured in Logan- Smithfield, Utah. 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- MN161960001-24 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 Logan City Power Source UTM Coordinates Modeled Emission Rates Easting Northing NOx (m) (m) (lb/hr) (tons/yr) hrs/year LCPENG1 428457 4616789 1.35 5.91 8760 LCPENG2 428464 4616789 1.35 5.91 8760 LCPENG3 428472 4616789 1.35 5.91 8760 LCPENG4 428480 4616789 1.35 5.91 8760 Total 5.40 23.65 Hyrum City Power Source UTM Coordinates Modeled Emission Rates Easting Northing NOx (m) (m) (lb/hr) (tons/yr) hrs/year ENGINE1 427891 4611026 1.43 6.26 8760 ENGINE2 427897 4611026 1.43 6.26 8760 ENGINE3 427903 4611026 1.43 6.26 8760 ENGINE4 427909 4611026 1.43 6.26 8760 ENGINE5 427915 4611026 1.43 6.26 8760 GENSET 427922 4611001 1.75 7.67 8760 Total 8.90 38.98 Swift Beef Source UTM Coordinates Modeled Emission Rates Easting Northing NOx (m) (m) (lb/hr) (tons/yr) hrs/year BEEF 428402 4610505 14.95 65.50 8760 Total 14.95 65.50 DAQE- MN161960001-24 Page 4 10. Source Location and Parameters Source Type Source Parameters Elev, Ht Temp Flow Dia (ft) (m) (ft) (K) (m/s) (ft) LCPENG1 POINT 4479.8 11.3 37.0 685 24.77 0.61 LCPENG2 POINT 4479.9 11.3 37.0 685 24.77 0.61 LCPENG3 POINT 4480.0 11.3 37.0 685 24.77 0.61 LCPENG4 POINT 4480.2 11.3 37.0 685 24.77 0.61 ENGINE1 POINT 4571.9 13.7 45.0 725 30.90 0.61 ENGINE2 POINT 4571.9 13.7 45.0 725 30.90 0.61 ENGINE3 POINT 4572.0 13.7 45.0 725 30.90 0.61 ENGINE4 POINT 4572.1 13.7 45.0 725 30.90 0.61 ENGINE5 POINT 4572.2 13.7 45.0 725 30.90 0.61 BEEF POINT 4616.2 11.9 39.0 500 15.00 0.61 GENSET POINT 4572.0 1.5 5.0 782 17.87 0.20 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. 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 129.1 7.5 39.3 7.4 175.8 188 93.51% JK:jg 1/23/24, 2:59 PM State of Utah Mail - Fwd: Logan City Power NOI Submittal https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1788906585504952976&simpl=msg-f:1788906585504952976 1/2 Dungan Adams <dunganadams@utah.gov> Fwd: Logan City Power NOI Submittal 1 message Alan Humpherys <ahumpherys@utah.gov>Tue, Jan 23, 2024 at 11:22 AM To: Dungan Adams <dunganadams@utah.gov> Dungan, Can you please process this permit application? Site ID: 16196 Peer: Christine Thanks, Alan ---------- Forwarded message --------- From: Clark, Eric <eric.clark@stantec.com> Date: Fri, Jan 19, 2024 at 10:30 AM Subject: Logan City Power NOI Submittal To: Alan Humpherys <ahumpherys@utah.gov> Cc: Mark Montgomery <mark.montgomery@loganutah.org>, Dave Prey <dprey@utah.gov> Mr. Humphreys: On behalf of Logan City Power, Stantec is submitting an electronic copy of a NOI application for a new Approval Order. The link below includes a full NOI with appendices, an emissions inventory and 1-hr NO2 modeling files. The appropriately signed Form 2 is in Appendix A of the NOI. Logan has not paid the application and new minor source review fees, but will do so when the appropriate invoice is received. Lastly, please let me know if you have any issues with accessing the link below. Note that only the people on this email currently have access. Thank you Logan NOI Submittal Eric Clark P.E. Project Engineer Direct: 208 388-4324 Mobile: 208 861-7182 eric.clark@stantec.com Stantec 1/23/24, 2:59 PM State of Utah Mail - Fwd: Logan City Power NOI Submittal https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1788906585504952976&simpl=msg-f:1788906585504952976 2/2 The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. 2 attachments Logan NOI FINAL 01-18-24.pdf 5875K Logan Engines.xlsx 25K 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…1/10 Dungan Adams <dunganadams@utah.gov> NOI Received for Logan City Power 17 messages Dungan Adams <dunganadams@utah.gov>Thu, Jan 25, 2024 at 3:46 PM To: eric.clark@stantec.com Cc: mark.montgomery@loganutah.org Hi Eric, The Utah Division of Air Quality (DAQ) has received Logan City Power's NOI for a new natural gas power plant. I will be reviewing the NOI and will let you know if I have any questions. Is it possible to allow me access to the Logan NOI Submittal link that was sent to Alan Humphreys? Thanks, Dungan -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Clark, Eric <eric.clark@stantec.com>Thu, Jan 25, 2024 at 3:54 PM To: Dungan Adams <dunganadams@utah.gov> Cc: "mark.montgomery@loganutah.org" <mark.montgomery@loganutah.org> Dungan – Please try this link below. You should have access now. If you have any questions/issues let me know. Thanks Logan NOI Submittal Eric Clark, P.E. Project Engineer 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…2/10 You don't often get email from dunganadams@utah.gov. Learn why this is important Eric.Clark@stantec.com From: Dungan Adams <dunganadams@utah.gov> Sent: Thursday, January 25, 2024 3:47 PM To: Clark, Eric <eric.clark@stantec.com> Cc: mark.montgomery@loganutah.org Subject: NOI Received for Logan City Power [Quoted text hidden] Caution: This email originated from outside of Stantec. Please take extra precaution. Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires. Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales. Dungan Adams <dunganadams@utah.gov>Thu, Jan 25, 2024 at 4:13 PM To: "Clark, Eric" <eric.clark@stantec.com> Hi Eric, Great, I can access everything. Could you also please send Jason Krebs (jkrebs@utah.gov) the link and allow him access? Jason is one of the modelers that works with Dave Prey. Thanks, Dungan [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Thu, Jan 25, 2024 at 4:18 PM To: Jason Krebs <jkrebs@utah.gov> Cc: Dungan Adams <dunganadams@utah.gov> Jason – Please see the link below to accessed Logan Power modeling files. [Quoted text hidden] Jason Krebs <jkrebs@utah.gov>Thu, Jan 25, 2024 at 4:30 PM To: "Clark, Eric" <eric.clark@stantec.com>, Dave Prey <dprey@utah.gov> Cc: Dungan Adams <dunganadams@utah.gov> Thank you Eric. I was able to download the files. Jason Krebs | Environmental Scientist | Utah Division of Air Quality Phone: 385.306.6531 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…3/10 195 North 1950 West, Salt Lake City, UT 84116 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Jan 31, 2024 at 11:46 AM To: eric.clark@stantec.com Cc: mark.montgomery@loganutah.org Hi Eric, I have finished reviewing the NOI Application for Logan City Power's new natural gas power plant. The only small concern I have is with BACT analysis. BACT is determined on a case-by-case basis, so stating emission rates from the proposed engines are lower than other BACT determinations is enough of a justification for BACT selection. The emission rates which are proposed in the NOI are low compared to other BACT determinations, but there is nothing in the analysis that suggests adding greater control is infeasible. The BACT analysis is also missing sections for PM, SO2, and HAP control. Please update the BACT analysis section to include all technically and economically feasible control options for all criteria pollutants (including PM and SO2) and HAPs. Then evaluate these options taking into consideration energy, environmental, and economic impacts and justify the control selection. The strongest argument to show a control option is infeasible is to provide the cost per ton removed of the pollutant. Let me know if you have any questions. I can provide BACT guidance documentation or try to find a complete BACT analysis from a similar project if that would be helpful. Thanks, Dungan [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Wed, Jan 31, 2024 at 11:57 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "mark.montgomery@loganutah.org" <mark.montgomery@loganutah.org> Dungan – I will update the BACT section per your request. I will plan to get this back to you by the end of the week. For my own understanding, the expected SO2 and PM tpy are 0.21 and 3.49, respectively. Both of those values are less than the Small Source Exemption of 5 tpy. Is that an appropriate justification for BACT? Eric Clark, P.E. Project Engineer Eric.Clark@stantec.com From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 31, 2024 11:46 AM To: Clark, Eric <eric.clark@stantec.com> Cc: mark.montgomery@loganutah.org Subject: Re: NOI Received for Logan City Power Hi Eric, 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…4/10 You don't often get email from dunganadams@utah.gov. Learn why this is important [Quoted text hidden] [Quoted text hidden] Caution: This email originated from outside of Stantec. Please take extra precaution. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Jan 31, 2024 at 1:37 PM To: "Clark, Eric" <eric.clark@stantec.com> Eric, No, this would not be an appropriate justification for BACT. Once a single emission is above the 5 TPY threshold then all criteria pollutants and HAPs need to be evaluated. For these smaller emissions, the analysis can be short and does not need to include any cost per ton removed justification. If there is no effective add-on control technology for the pollutant (as is often the case with SO2) then combustion practices and the use of clean burning fuels will be selected as BACT. Thanks, Dungan [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Wed, Jan 31, 2024 at 3:45 PM To: Dungan Adams <dunganadams@utah.gov> Dungan – If you do have BACT examples for NG engines for PM and SO2 that would be great. Thanks Eric Clark, P.E. Project Engineer Eric.Clark@stantec.com From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 31, 2024 1:37 PM To: Clark, Eric <eric.clark@stantec.com> [Quoted text hidden] [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Feb 1, 2024 at 9:27 AM To: "Clark, Eric" <eric.clark@stantec.com> Hi Eric, I've gone through several older projects for natural gas power plants and the BACT determinations for PM and SO2 are very uniform. BACT for PM will be proper maintenance and good combustion practices. BACT for SO2 will be the 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…5/10 combustion of low sulfur fuel (natural gas). From these BACT determinations, it looks like the DAQ is not aware of any greater control (outside of SCR and OC) that can further reduce NOx, CO, VOC, and HAP emissions. Based on these determinations, you do not need to update the BACT analysis for this project. I'm sorry if this has created any extra work for you and your team. For future NOIs, I would suggest Stantec briefly mention BACT for PM and SO2 and state Stantec is unaware of any feasible control outside of SCRs and OCs which further limit NOx, CO, VOCs, and HAPs. This will make the BACT analysis more complete and streamline the process for permit engineers. Again, sorry for any hassle my initial request caused. Please let me know if you have any questions. Thanks, Dungan [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Thu, Feb 1, 2024 at 9:32 AM To: Dungan Adams <dunganadams@utah.gov> Dungan – Noted. Unfortunately, I did spend extra time. That said, I have a good background for next time and can add to any subsequent NOIs. I appreciate your clarification. Please let me know if you have any other questions regarding the NOI. Also, do you have any feel for when the modeling review might be completed so I can give the city an approximate timeline for next steps. Thanks again. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Feb 1, 2024 at 11:24 AM To: "Clark, Eric" <eric.clark@stantec.com> Eric, Modeling estimates the review will be completed in roughly five weeks. For a recent project with slightly more complicated modeling, I submitted modeling info on December 5th, 2023 and the modeling review memo was completed today. Hopefully that gives you a reference. Let me know if you have any other questions. Thanks, Dungan [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Thu, Feb 1, 2024 at 11:25 AM To: Dungan Adams <dunganadams@utah.gov> Dungan – Thank you! [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…6/10 [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] Thanks, Dungan -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…7/10 Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Caution: This email originated from outside of Stantec. Please take extra precaution. Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires. Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales. -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Caution: This email originated from outside of Stantec. Please take extra precaution. Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires. Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales. 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…8/10 -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Caution: This email originated from outside of Stantec. Please take extra precaution. Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires. Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales. -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r8752044579138…9/10 airquality.utah.gov [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Feb 15, 2024 at 12:24 PM To: "Clark, Eric" <eric.clark@stantec.com> Hi Eric, Can you please confirm the proposed Logan Natural Gas Power Plant will not have any emergency generators on site. Thanks, Dungan [Quoted text hidden] -- [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Thu, Feb 15, 2024 at 1:00 PM To: Dungan Adams <dunganadams@utah.gov> Dungan – I don’t believe so, but I am checking with the vendor/facility? When I have an answer I will let you know. Thanks Eric Clark, P.E. Senior Engineer Eric.Clark@stantec.com [Quoted text hidden] Clark, Eric <eric.clark@stantec.com>Thu, Feb 15, 2024 at 7:23 PM To: Dungan Adams <dunganadams@utah.gov> Dungan - I confirmed that there no emergency engine. Thanks Sent from my iPhone. Sorry for any potential typographical errors. From: Clark, Eric Sent: Thursday, February 15, 2024 1:00:15 PM 2/21/24, 1:10 PM State of Utah Mail - NOI Received for Logan City Power https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-8514858377921959152&simpl=msg-a:r875204457913…10/10 To: Dungan Adams <dunganadams@utah.gov> Subject: RE: NOI Received for Logan City Power [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Fri, Feb 16, 2024 at 8:07 AM To: "Clark, Eric" <eric.clark@stantec.com> Great, thank you for confirming. Dungan [Quoted text hidden] Logan City Power NOx CO PM10 PM2.5 VOC SO2 HAP CO2e 10 Engine SCR/OC Control 2.12 2.79 0.80 0.80 2.72 0.05 2.28 12,521 NOx CO PM10 PM2.5 VOC SO2 HAP CO2e 10 Engine SCR/OC Control 9.27 12.23 3.49 3.49 11.91 0.21 10.01 54,842 Configuration Configuration Project Summary Emissions Estimates Pounds Per Hour Tons Per Year 1 of 2 Logan City Power Rating (hp)3427 hp Operational Hours 8760 hr/yr Engine Type Number of Units 4 Engine Fuel Consumption 5822 Btu/bhp-hr Criteria Pollutants g/hp-hr lb/MMBtu lb/hr Tons/yr Reference NOx*0.07 2.12 9.27 CO*0.092 2.79 12.23 PM10**9.99E-03 0.80 3.49 PM2.5**9.99E-03 0.80 3.49 VOC***0.09 2.72 11.91 SO2 5.88E-04 0.05 0.21 HAP 2.28 10.01 See Below * NOx is controlled to 0.07 g/bhp-hr with the SCR included. CO is 93% controlled with OC and SCR ** PM2.5/10 AP_42, Section 3.2 *** VOC and HAPs are controlled by 50% per CAT OC/SCR, respectively. All HAP/TAPs are trace organic compounds Hazard Pollutant lb/hr Tons/yr Reference 1,1,2,2-Tetrachloroethane 4.00E-05 1.60E-03 6.99E-03 1,1,2-Trichloroethane 3.18E-05 1.27E-03 5.56E-03 1,3-Butadiene 2.67E-04 1.07E-02 4.67E-02 1,3-Dichloropropane 2.64E-05 1.05E-03 4.61E-03 2,2,4-Trimethylpentane 2.50E-04 9.98E-03 4.37E-02 2-Methylnaphthalene 3.32E-05 1.32E-03 5.80E-03 Acenaphthene 1.25E-06 4.99E-05 2.18E-04 Acenaphthylene 5.53E-06 2.21E-04 9.67E-04 Acetaldehyde 8.36E-03 3.34E-01 1.46E+00 Acrolein 5.14E-03 2.05E-01 8.98E-01 Benzene 4.40E-04 1.76E-02 7.69E-02 Benzo(b)fluoranthene 1.66E-07 6.62E-06 2.90E-05 Benzo(e)pyrene 4.15E-07 1.66E-05 7.25E-05 Benzo(g,h,i)perylene 4.14E-07 1.65E-05 7.24E-05 Biphenyl 2.12E-04 8.46E-03 3.71E-02 Carbon Tetrachloride 3.67E-05 1.46E-03 6.41E-03 Chlorobenzene 3.04E-05 1.21E-03 5.31E-03 Chloroform 2.85E-05 1.14E-03 4.98E-03 Chrysene 6.93E-07 2.77E-05 1.21E-04 Ethylbenzene 3.97E-05 1.58E-03 6.94E-03 Ethylene Dibromide 4.43E-05 1.77E-03 7.74E-03 Fluoranthene 1.11E-06 4.43E-05 1.94E-04 Fluorene 5.67E-06 2.26E-04 9.91E-04 Formaldehyde 2.00E-01 1.51E+00 6.62E+00 Methanol 2.50E-03 9.98E-02 4.37E-01 Methylene Chloride 2.00E-05 7.98E-04 3.50E-03 Hexane 1.11E-03 4.43E-02 1.94E-01 Naphthalene 7.44E-05 2.97E-03 1.30E-02 PAH 2.69E-05 1.07E-03 4.70E-03 Phenanthrene 1.04E-05 4.15E-04 1.82E-03 Phenol 2.40E-05 9.58E-04 4.19E-03 Pyrene 1.36E-06 5.43E-05 2.38E-04 Styrene 2.36E-05 9.42E-04 4.12E-03 Tetrachloroethane 2.48E-06 9.90E-05 4.33E-04 Toluene 4.08E-04 1.63E-02 7.13E-02 Vinyl Chloride 1.49E-05 5.95E-04 2.60E-03 Xylene 1.84E-04 7.34E-03 3.22E-02 * Formaldehyde is from Safety Power (75%); also EF is in g/hp-hr GHG Pollutant g/MMBtu lb/hr Tons/yr GWP Reference* CO2 414 12,511 54,799 1 CH4 1 1.76E-01 7.71E-01 25 N2O 0.1 1.76E-02 7.71E-02 298 CO2e 12,521 54,842 *https://www.epa.gov/system/files/documents/2023-03/ghg_emission_factors_hub.pdf; CO2 is 414 g/hp-hr EPA GHG Emission Factors * CAT data Proposed Natural Gas Engines (Controlled) 4-Stroke lean burn Manufacturer Data or AP-42 Table 3.2-2 lb/MMBtu Manufacturer Data or AP-42 Table 3.2-2 2 of 2 Form 1 Date __________________ Notice of Intent (NOI) Application Checklist Company __________________ Utah Division of Air Quality New Source Review Section Source Identification Information [R307-401-5] 1. Company name, mailing address, physical address and telephone number 2. Company contact (Name, mailing address, and telephone number) 3. Name and contact of person submitting NOI application (if different than 2) 4. Source Universal Transverse Mercator (UTM) coordinates 5. Source Standard Industrial Classification (SIC) code 6. Area designation (attainment, maintenance, or nonattainment) 7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.) 8. Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers NOI Application Information:[R307-401] N/A N/A A. Air quality analysis (air model, met data, background data, source impact analysis) N/A Detailed description of the project and source process Discussion of fuels, raw materials, and products consumed/produced Description of equipment used in the process and operating schedule Description of changes to the process, production rates, etc. Site plan of source with building dimensions, stack parameters, etc. Best Available Control Technology (BACT) Analysis [R307-401-8] BACT analysis for all new and modified equipment Emissions Related Information: [R307-401-2(b)] Emission calculations for each new/modified unit and site-wide (Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs) References/assumptions, SDS, for each calculation and pollutant All speciated HAP emissions (list in lbs/hr) Emissions Impact Analysis – Approved Modeling Protocol [R307-410] Composition and physical characteristics of effluent (emission rates, temperature, volume, pollutant types and concentrations) Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403] NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements Alternative site analysis, Major source ownership compliance certification Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] Visibility impact analysis, Class I area impact N/A Note: The Division of Air Quality will not accept documents containing confidential information or data. Documents containing confidential information will be returned to the Source submitting the application. 1/9/2024 Logan City Power 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 (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal 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: 1/9/2024 Logan City Power 530 North 800 West Logan, Utah 84321 (435) 716-9700 Mark Montgomery (435) 716-9744 mark.montgomery@loganutah.org SE corner of W 1800 S and S 1000 W Logan, Utah 84321 (435) 716-9700 Cache 12 428461.67 m 4616796.43 m 4911 N/A This a new natural gas power plant with 4 CAT 3520H engines Power & Light Director Mark Montgomery (435) 716-9744 mark.montgomery@loganutah.org 1/9/24 Page 1 of 1 Company___________________________ _____________________________ Form Emissions Information Criteria/GHGs/ Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Logan City Power Logan City Generation 0.00 3.49 3.49 0.00 0.00 0.00 0.00 3.49 3.49 0.00 9.27 9.27 0.00 0.21 0.21 0.00 12.23 12.23 0.00 11.91 11.91 0.00 0.00 0.00 0.00 0.00 54,799.00 54,799.00 0.00 0.77 0.77 0.00 0.08 0.08 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 See Appendix C 0.00 10.01 10.01 2.28 Utah Division of Air Quality New Source Review Section Form 11 Internal Combustion Engines Equipment Information Gas Firing Oil Firing Logan City Power Logan Power Generation 1/9/2024 Caterpillar (4 units) G3520H 24 24 7 7 2024 52 52 3427 3427 685.4 for 4 engines total 19.95 per engine Internal Combustion Engine Form 11 (Continued) Operation Emissions Data Method of Emission Control: Additional Information X 0.07 0.092 0.09 0.05 IN T E R N A L C O M B U S T I O N E N G I N E FO R M 1 1 ( c o n t i n u e d ) EM I S S I O N S O U R C E S HIGH ALTITUDE/AMBIENT CAT LOW PRESSURE WITH AIR FUEL RATIO CONTROL Gas Analysis 2.0-5.0 76.7 961 4491 85 3457 bhp@1500rpm 1.0 4160-13800 RATING STRATEGY: FUEL SYSTEM: SITE CONDITIONS: FUEL: FUEL PRESSURE RANGE(psig): (See note 1) FUEL METHANE NUMBER: FUEL LHV (Btu/scf): ALTITUDE(ft): INLET AIR TEMPERATURE(°F): STANDARD RATED POWER: POWER FACTOR: VOLTAGE(V): ENGINE SPEED (rpm): 1500 COMPRESSION RATIO: 12.1 AFTERCOOLER TYPE: SCAC AFTERCOOLER - STAGE 2 INLET (°F): 118 AFTERCOOLER - STAGE 1 INLET (°F): 192 JACKET WATER OUTLET (°F): 210 ASPIRATION: TA COOLING SYSTEM: JW+OC+1AC, 2AC+GB CONTROL SYSTEM:ADEM4 W/ IM EXHAUST MANIFOLD: DRY COMBUSTION: LOW EMISSION NOx EMISSION LEVEL (g/bhp-hr NOx): 1.0 SET POINT TIMING: 17 RATING NOTES LOAD 100%100%75%50% GENSET POWER (WITH GEARBOX, WITHOUT FAN)(2)(3) ekW 2473 2471 1853 1235 GENSET POWER (WITH GEARBOX, WITHOUT FAN)(2)(3) kVA 2474 2471 1853 1235 ENGINE POWER (WITHOUT GEARBOX, WITHOUT FAN)(3) bhp 3431 3427 2582 1736 INLET AIR TEMPERATURE °F 77 85 85 85 GENERATOR EFFICIENCY (2) % 97.4 97.4 97.0 96.2 GENSET EFFICIENCY (ISO 3046/1)(4)(5) % 43.7 43.7 42.6 40.4 THERMAL EFFICIENCY (4)(6) % 42.1 42.1 43.3 46.1 TOTAL EFFICIENCY (4)(7) % 85.8 85.8 85.9 86.5 MAXIMUM RATING SITE RATING AT MAXIMUM INLET AIR TEMPERATURE ENGINE DATA GENSET FUEL CONSUMPTION (ISO 3046/1)(8) Btu/ekW-hr 7806 7807 8003 8454 GENSET FUEL CONSUMPTION (NOMINAL)(8) Btu/ekW-hr 8075 8076 8279 8746 ENGINE FUEL CONSUMPTION (NOMINAL)(8) Btu/bhp-hr 5822 5822 5941 6224 AIR FLOW (@inlet air temp, 14.7 psia)(WET)(9) ft3/min 6209 6294 4687 3141 AIR FLOW (WET)(9) lb/hr 27526 27497 20478 13724 FUEL FLOW (60°F, 14.7 psia) scfm 346 346 266 187 INLET MANIFOLD PRESSURE (10) in Hg(abs) 134.4 134.3 100.8 68.7 EXHAUST TEMPERATURE - ENGINE OUTLET (11) °F 773 774 837 945 EXHAUST GAS FLOW (@engine outlet temp, 14.5 psia)(WET)(12) ft3/min 15330 15317 12013 8752 EXHAUST GAS MASS FLOW (WET)(12) lb/hr 28492 28461 21219 14246 MAX INLET RESTRICTION (13) in H2O 14.28 14.26 9.89 7.09 MAX EXHAUST RESTRICTION (13) in H2O 20.71 20.67 11.90 5.90 EMISSIONS DATA - ENGINE OUT NOx (as NO2) (14)(15) g/bhp-hr 1.00 1.00 1.00 1.00 CO (14)(15) g/bhp-hr 1.32 1.32 1.26 1.23 THC (mol. wt. of 15.84) (14)(15) g/bhp-hr 1.65 1.65 1.72 1.66 NMHC (mol. wt. of 15.84) (14)(15) g/bhp-hr 0.25 0.25 0.26 0.26 NMNEHC (VOCs) (mol. wt. of 15.84) (14)(15)(16) g/bhp-hr 0.18 0.18 0.19 0.18 HCHO (Formaldehyde) (14)(15) g/bhp-hr 0.20 0.20 0.20 0.21 CO2 (14)(15) g/bhp-hr 414 414 421 431 EXHAUST OXYGEN (14)(17) % DRY 9.4 9.4 9.1 8.7 HEAT REJECTION LHV INPUT (18) Btu/min 332903 332584 255700 180078 HEAT REJ. TO JACKET WATER (JW) (19) Btu/min 34374 34359 29227 24150 HEAT REJ. TO ATMOSPHERE (INCLUDES GENERATOR)(19) Btu/min 7984 7980 6885 5734 HEAT REJ. TO LUBE OIL (OC) (19) Btu/min 12556 12551 11279 9705 HEAT REJECTION TO EXHAUST (LHV TO 248°F) (19) Btu/min 66401 66362 55322 44258 HEAT REJ. TO A/C - STAGE 1 (1AC) (19)(21) Btu/min 27945 27886 15686 5559 HEAT REJ. TO A/C - STAGE 2 (2AC) (19)(21) Btu/min 16757 16736 12006 6804 HEAT REJECTION FROM GEARBOX (GB) (19) Btu/min 1149 1148 865 582 PUMP POWER (20) Btu/min 859 859 859 859 COOLING SYSTEM SIZING CRITERIA TOTAL JACKET WATER CIRCUIT (JW+OC+1AC) (22) Btu/min 87484 89030 TOTAL STAGE 2 AFTERCOOLER CIRCUIT (2AC+GB)(22) Btu/min 20360 20813 HEAT REJECTION TO EXHAUST (LHV TO 248°F) (22) Btu/min 73041 72998 A cooling system safety factor of 0% has been added to the cooling system sizing criteria. MINIMUM HEAT RECOVERY TOTAL JACKET WATER CIRCUIT (JW+OC+1AC) (23) Btu/min 67529 67455 TOTAL STAGE 2 AFTERCOOLER CIRCUIT (2AC+GB)(23) Btu/min 17012 16990 HEAT REJECTION TO EXHAUST (LHV TO 248°F) (23) Btu/min 54256 52455 CONDITIONS AND DEFINITIONS Engine rating obtained and presented in accordance with ISO 3046/1, adjusted for fuel, site altitude and site inlet air temperature. 100% rating at maximum inlet air temperature is the maximum engine capability for the specified fuel at site altitude and maximum site inlet air temperature. Maximum rating is the maximum capability at the specified aftercooler inlet temperature for the specified fuel at site altitude and reduced inlet air temperature. Refer to product O&M manual for details on additional lower load capability. No overload permitted at rating shown. For notes information consult page three. GENSET - WITHOUT RADIATOR Page 1 of 4Data generated by GERP Web Version 2.7.0.14 Ref. Dta Set EM2181-01-001, Printed 22Jun2023 PREPARED BY: Shane Minor, Wheeler Machinery Co. GAS ENGINE SITE SPECIFIC TECHNICAL DATAG3520HLogan w Gas Analysis Safety Power Inc 26-5155 Spectrum Way Mississauga, On L4W 5A1 Canada www.safetypower.com Page 5 of 24 Confidential 99002010 Rev12.2 clean essential energy DESIGN PARAMETERS The design of the Safety Power emissions reduction system is based on the following conditions. Note: NOx is calculated as NO2. Table 1 Engine Data Engine Type: CAT G3520H Application Stand-by Engine Power 2471 ekW Exhaust Temperature 774 °F Design Exhaust Flow Rate 15317 (CFM) Fuel Type Pipe Line NG Table 2 Emissions Data at Full Engine Load Engine Option Emissions Catalyst Inlet Emissions Requirement Catalyst Outlet CAT G3520H NOx (g/bhp-h) 1.00 0.07 0.07 CO 1.32 (g/bhp-h) 93 (% reduction) 93 (% reduction) VOC 0.18 (g/bhp-h) 50 (% reduction) 50 (% reduction) HCHO 0.20 (g/bhp-h) 75 (% reduction) 75 (% reduction) eady state using SCAQMD method 100.1 for NOx and SCAQMD/EPA methods 25.1/25.3 -hr is to be assumed (unless otherwise stated). Table 3 SCR System Data Engine Option CAT G3520H Max. Ammonia Slip @ 15% O2 8 ppm Urea Consumption - 32.5% solution (+/- 15%) 1.6 USG/hr System Pressure Loss 11.0" WC System Inlet/Outlet ANSI Flange Inches 22/22