DAQ-2024-010860

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DAQC-981-24
Site ID 10892 (B1)

MEMORANDUM

TO: FILE – ST. GEORGE CITY POWER (Millcreek, Red Rock, and Bloomington
Power Stations)

THROUGH: Harold Burge, Major Source Compliance Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: September 30, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Washington County,
FRS ID# UT0000004905300011
INSPECTION DATE: September 25, 2024

SOURCE ADDRESS: Millcreek Power Plant
3232 East 170 North
St. George, Utah 84790

MAILING ADDRESS: City Hall
St. George City Power
175 East 200 North
St. George, UT 84770

SOURCE CONTACT: Brad Burner, Generation Superintendent: 435-703-0910

OPERATING STATUS: Millcreek Power Station (Turbines 1 and 2) – (Not operating)
Red Rock Power Station – On Hot Standby (Not operating)
Bloomington Power Station – (Not Operating)

PROCESS DESCRIPTION: St. George City Power operates two diesel powered and two natural gas
turbine co-generation facilities in St. George. Electricity demands
fluctuate from day to day, and from hour to hour. The St. George
co-generation facilities are used to supply power to the main power grid
during periods of excess power use by the consumers (Peaker Plant).
When power demands are higher than can be accommodated, by the grid,
the engines are brought to 24-hour standby and operated until electricity
consumption is brought back to normal. The diesel engines use low
sulfur diesel fuel that is stored in on-site tanks. Low sulfur diesel fuel is
used in these engines to minimize sulfur dioxide emissions. The natural
gas turbines have operating parameters, which are monitored to ensure
efficient use.

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2
APPLICABLE
REGULATIONS: Title V operating permit 5300011006 issued April 24, 2024
NSPS (Part 60), A: General Provisions
NSPS (Part 60), GG: Standards of Performance for Stationary Gas
Turbines
NSPS (Part 60), KKKK: Standards of Performance for Stationary
Combustion
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous
Air pollutants for Stationary Reciprocating Internal Combustions
Engines

SOURCE INSPECTION
EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

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

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

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

Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

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

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

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

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I.C.4

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

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

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

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

I.D.4

Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))
Status: The permit expires April 24, 2029. Application for renewal is due October 24, 2028.

I.E Application Shield.

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

Status: The permit expires April 24, 2029. Application for renewal is due October 24, 2028.

I.F Severability.

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

Status: This is a statement of fact and not an inspection item.

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In I.G Permit Fee.

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

I.G.2

The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))
Status: In compliance – The annual emission fee was paid as invoiced.

I.H No Property Rights.

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

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

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

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

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

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

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

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

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

I.J.2

Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))
Status: In compliance – Inspection was facilitated. Required records were made available and no
claims of confidentially were made at time of the inspection.
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I.K Certification.

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

Status: In compliance – Reports and certifications submitted by St. George City Power appeared to
have certification statements and were signed by the responsible officials.

I.L Compliance Certification.

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

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

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

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

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

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I.L.2

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

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

Status: In compliance – The annual compliance certification was received September 18, 2023 (due
October 1, 2023). It was reviewed under a separate memo and found to meet requirements.

I.M Permit Shield.

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

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

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

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

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

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

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

I.M.2.d

The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))
Status: N/A – See section III of this permit.

I.N Reserved

I.O Operational Flexibility.

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

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).
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I.Q Administrative Permit Amendments.

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

I.R

Permit Modifications.

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

Status: These are statements of facts and not inspection items (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))
I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

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

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

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

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

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

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

I.S.1.c

Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

Status:

In compliance – Required records were provided at time of the inspection.

I.S.2 Reports.

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

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

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

I.S.3 Notification Addresses.

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

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

I.S.3.b

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

For annual compliance certifications:

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

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

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance – The six-month monitoring reports were received in the past year and can be
found in the source’s file.

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I.T Reopening for Cause.

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

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

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

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

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

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

I.T.3

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

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

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

Status: In compliance – The 2023 Emission Inventory was received on April 9, 2024. See the
SLEIS database.

I.V Title IV and Other, More Stringent Requirements

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

Status: This is a statement of fact and not an inspection item.

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SECTION II: SPECIAL PROVISIONS

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

II.A.1 Permitted Source
Source-wide

II.A.2 Diesel Fuel Internal Combustion Engines (Red Rock)
Two 9,750 HP diesel engines with an oxidation catalyst, located at Red Rock facility and were
manufactured in 1975. 40 CFR 63 Subpart ZZZZ applies to both units.

II.A.3 Emergency Diesel Generators/Engines (Bloomington)
Six Caterpillar 3516 emergency diesel generators/engines without an oxidation catalyst, located at
Bloomington facility, each with design rating of 1,750 kW and were manufactured in 1982. 40
CFR 63 Subpart ZZZZ applies to each unit.

II.A.4 Above Ground Storage Tanks (Bloomington)
Three above ground diesel fuel storage tanks, with capacity of 10, 000 gallons each. Non-unit
specific applicable requirements.

II.A.5 Millcreek Natural Gas Turbine (MC-1)
One GE LM6000-PD Dry Low NOx (DLP) natural gas-fired turbine generator set with a nominal
output of 39.1 MW, equipped with SPRINT technology, turbine stack 45 feet high measured from
the ground level, NSPS GG

II.A.6 Millcreek New Natural Gas Turbine (MC-2)
One GE LM6000-PD Dry Low Emission (DLE) natural gas-fired turbine generator set with a
nominal output of 39.1 MW, equipped with SPRINT technology and SCR, installed post-2008,
NSPS Subpart KKKK

II.A.7 Emergency Generator (Millcreek)
Caterpillar 3516 diesel emergency generator/engine located at the Millcreek facility, with design
rating of 1,750 kW and was manufactured in 1982. 40 CFR 63 Subpart ZZZZ applies to this unit.

II.A.8 Fuel Storage Tanks (Redrock)
Four miscellaneous fuel storage tanks. Non-unit specific applicable requirements.

Status: In compliance – No unapproved equipment was noted or discussed at time of the inspection. It
should be noted that the Millcreek emergency generator (item II.A.7) is no longer at any site. St.
George City Power is currently looking for electrical storage backup to replace item II.A.7.

II.B Requirements and Limitations

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

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II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

Sulfur content of the fuel oil combusted shall be no greater than 0.0015 % by weight unless otherwise
specified in this permit. [DAQE -AN108920018-18]. [R307-203-1, R307-401-8]

II.B.1.a.1 Monitoring:

For each delivery of oil, the permittee shall either:

(a) Determine the fuel sulfur content expressed as wt% in accordance with the methods of the
American Society for Testing Materials (ASTM);

(b) Inspect the fuel sulfur content expressed as wt% determined by the vendor using methods of
the ASTM; or

(c) Inspect documentation provided by the vendor that indirectly demonstrates compliance with
this provision.

II.B.1.a.2 Recordkeeping:

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

II.B.1.a.3 Reporting:

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

Status: In compliance – The city has a contract with Overland Petroleum for fuel delivery. The contract is
for ultra-low sulfur diesel (ULSD). Review of records indicated that ULSD is delivered to the
facilities. The city also conducts independent sulfur analysis of fuel used on-site.

II.B.1.b Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, including associated air pollution
control equipment, in a manner consistent with good air pollution control practice for minimizing
emissions. Determination of whether acceptable operating and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to,
monitoring results, opacity observations, review of operating and maintenance procedures, and inspection
of the source. [DAQE -AN108920018-18]. [R307-401-8(2)]

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

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II.B.1.b.2 Recordkeeping:

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

II.B.1.b.3 Reporting:

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

Status: In compliance – Maintenance is generally focused on the Millcreek Power Station, since the Red
Rock and Bloomington Stations are usually not in operation. Maintenance is usually conducted
when the facilities are off-line, which is about six months out of the year. General Electric (GE)
conducts the six-month maintenance and provides the monitoring reports. Hard copies of
maintenance records are maintained on-site. The Redrock and Bloomington station maintenance is
done by city workers, with both preventative and as needed maintenance done.

II.B.1.c Condition:

Emergency generators shall be used for electricity producing operation only during the periods when
electric power from the public utilities is interrupted, or for regular maintenance of the generators.
[DAQE -AN108920018-18]. [R307-401-8]

II.B.1.c.1 Monitoring:

All operation log shall be used to record the following information for each usage: dates(s), total
hours used, and reason for usage.

II.B.1.c.2 Recordkeeping:

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

II.B.1.c.3 Reporting:

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

Status: In compliance. The Millcreek emergency generator has been removed. The Bloomington site is now
backup generators only and do not operate on hot standby. They are used for backup power if all
other sources are offline. See status of condition II.A.

II.B.2 Conditions on Diesel Fuel Internal Combustion Engines (Red Rock).

II.B.2.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [DAQ - AN108920018-18]. [R307-401-8]

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II.B.2.a.1 Monitoring:

Opacity observations of emissions shall be conducted semi-annually in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.2.a.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.a.3 Reporting:

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

Status: In compliance – The two diesel engines are not operated on a regular basis. According to the
records the last VEOs were conducted July 31, 2024, and April 2, 2024, on both engines during
maintenance firings.

II.B.2.b Condition:

Emissions of NOx shall be no greater than 10 gm/hp-hr for each engine. [DAQE-AN108920018-18].
[R307-401-8]

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every 8,760 hours of operation or once every three years,
whichever comes first. The source may also be tested at any time if directed by the Director.

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

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR
60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA)
approved access shall be provided to the test location.

(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E shall be used to determine
the pollutant emission rate.

(3) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.

(d) Calculations. To determine mass emission rates (g/HP-hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and
any necessary conversion factors determined by the Director to give the results in the specified
units of the emission limitation.
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(e) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.

II.B.2.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: In compliance – NOx stack testing for both diesel engines were conducted on December 14, 2021.
The stack tests are conducted triennially. The next stack test will be due in December of 2024.
Results of the stack test are as follows: (DAQC-170-22)

Stack Test Summary
Engine Stacks NOx Limit NOx Results
Engine 1 10 gm/hp-hr 8.30 gm/hp-hr
Engine 2 10 gm/hp-hr 7.90 gm/hp-hr

Testing company has been notified to submit a protocol for testing in December of this year.

II.B.2.c Condition:

Total emissions of NOx shall be no greater than 424 tons per rolling 12-month period.
[DAQE-AN108920018-18]. [R307-401-8]

II.B.2.c.1 Monitoring:

The emissions shall be determined on a rolling 12-month total. Within the first 10 days of each
month a new 12-month total shall be calculated using data from the previous 12 months.

The following equation shall be used to calculate each month emissions in order to get rolling 12-
month emissions from each engine:

Emissions (tons/month period) = (Power production in total kW-hrs for previous month) x (Most
Recent Emission factor in gm/hp-hr) x (1 hp/0.7457 kW) x (1 lb/453.59 gm) x (1 ton/2000 lbs)

Total emissions shall be the sum of emissions from each internal combustion engine.

The number of kilowatt-hours generated by each engine shall be monitored continuously by a
kilowatt-hour meter and recorded on a daily basis. Emission factors shall be derived from the
most recent emission test results.

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II.B.2.c.2 Recordkeeping:

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

II.B.2.c.3 Reporting:

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

Status: In compliance – Records of the kilowatt-hours generated for each engine is monitored continuously
by non-resettable kilowatt-hour meters and is recorded daily. The total of NOx emissions for the
12-month period ending August 31, 2024, was 19.97 tons Engine 1, and 0.65 tons Engine 2.

II.B.2.d Condition:

Emissions of CO shall be no greater than 2.4 gm/hp-hr for each engine. [DAQE - AN108920018-18].
[R307-401-8]

II.B.2.d.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Emissions shall be tested every 8,760 hours of operation or once every three years,
whichever comes first. Tests may also be required at the direction of the Director at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest
conference if determined necessary by the Director.
(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1. In addition, Occupational Safety and Health Administration (OSHA)
approved access shall be provided to the test location.

(d) Methods.

(1) 40 CFR 60, Appendix A, Method 10 shall be used to determine CO emissions;

(2) 40 CFR 60, Appendix A, Method 2 shall be used to determine stack gas velocity and
volumetric flow rate.

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

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

16
II.B.2.d.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.d.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: In compliance – CO stack testing for both diesel engines was conducted on December 14, 2021. The
stack tests are conducted triennially. The next stack test will be due in December of 2024. Results of
the stack test are as follows: (DAQC-170-22)

Stack Test Summary
Engine Stacks CO Limit CO Results
Engine 1 2.4 gm/hp-hr 0.11 gm/hp-hr
Engine 2 2.4 gm/hp-hr 0.16 gm/hp-hr

Testing company has been notified to submit a protocol for testing in December of this year.

II.B.2.e Condition:

Total emissions of CO shall be no greater than 101.8 tons per rolling 12-month period.
[DAQE -AN108920018-18]. [R307-401-8]

II.B.2.e.1 Monitoring:

The emissions shall be determined on a rolling 12-month total. Within the first 10 days of each
month a new 12-month total shall be calculated using data from the previous 12 months.
The following equation shall be used to calculate each month emissions in order to get rolling 12-
month emissions from each engine:

Emissions (tons/month period) = (Power production in total kW-hrs for previous month) x (Most
Recent Emission factor in gm/hp-hr) x (1 hp/0.7457 kW) x (1 lb/453.59 gm) x (1 ton/2000 lbs)

Total emissions shall be the sum of emissions from each internal combustion engine.

The number of kilowatt-hours generated by each engine shall be monitored continuously by a
kilowatt-hour meter and recorded on a daily basis. Emission factors shall be derived from the
most recent emission test results.

II.B.2.e.2 Recordkeeping:

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

17
II.B.2.e.3 Reporting:

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

Status: In compliance – Records of the kilowatt-hours generated for each engine is monitored continuously
by nonresectable kilowatt-hour meters and is recorded daily. The total of CO emissions for the
12-month period ending August 31, 2024, was 0.01 tons Engine 1, and 0.01 tons Engine 2.

II.B.2.f Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)].
[40 CFR 63 Subpart ZZZZ]

II.B.2.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.f.2 Recordkeeping:

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

II.B.2.f.3 Reporting:

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

Status: In compliance – Maintenance is generally focused on the Millcreek Power Station, since the Red
Rock and Bloomington Stations are usually not in operation. Maintenance is usually conducted
when the facilities are taken off-line, which is about six months out of the year. These units have
selective catalyst and the pressure and temperature is monitored as required. Oil monitoring and
maintenance is done yearly and is tracked electronically. Hard copies of maintenance records are
maintained on-site. See status of condition II.B.1.b.

II.B.2.g Condition:

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

(2) Except during startup, CO emissions shall not exceed 23 ppmvd at 15% O2 or reduce CO emission by
70% or more. [40 CFR 63.6603(a) & Table 2d(3)]
18
(3) During periods of startup the permittee must minimize the engine's time spent at idle and minimize the
engine's startup time at startup to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitation applies. [40 CFR 63.6603(a)]

(4) The permittee shall comply with any operating limits approved by the Director [40 CFR 63.6603(a) &
Table 2b(2)].

[40 CFR 63.6603(a), 40 CFR 63 Subpart ZZZZ Table 2b(2), 40 CFR 63 Subpart ZZZZ Table 8, 40 CFR
63 Subpart ZZZZ Table 2d(3), 40 CFR 63.6665]. [40 CFR 63 Subpart ZZZZ]

II.B.2.g.1 Monitoring:

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

(b) The CO compliance test shall be conducted in accordance with 40 CFR 63.7(a)(2) and as
specified here:

(1) Frequency - Emissions shall be tested every 8760 hours of operation or once every three
years, whichever comes first. [40 CFR 63.6612 & 40 CFR 63.6615]

(2) Notification - At least 60 days before the test, the permittee shall notify the Director of the
date, time, and place of testing and provide a copy of the test protocol. The permittee shall attend
a pretest conference if determined necessary by the Director. Test protocol shall be approved by
the Director. [40 CFR 63.6645(g)]

(3) Methods:

(i) Sample port location and number of traverse points - Method 1 or 1A, 40 CFR 60, Appendix
A or other EPA-approved testing method, as acceptable to the Director. [Table 4(3)(a)(i)]

(ii) CO Concentration - Method 10, 40 CFR 60, Appendix A or other EPA-approved testing
method, as acceptable to the Director. Concentration to be reported at 15% O2, dry basis. Results
of this test consist of the average of the three 1-hour long runs. [Table 4(3)(a)(v)]

(4) Engine percent load during test must be determined and documented in accord with 40 CFR
63.6620(i).

(c) During the initial performance test, the permittee must establish each operating limitation
approved by the Director. The permittee shall petition the Director for operating limitations to be
established during the initial performance test and continuously monitored thereafter; or for
approval of no operating limitation. Initial performance tests shall not be conducted until the
petition is approved. The petition shall contain information required in 40 CFR 63.6620(g) or 40
CFR 63.6620(h). [40 CFR 63.6620(f)]

(d) The permittee shall demonstrate continuous compliance by:

(1) Collecting the approved operating parameter (if any) data according to 40 CFR 63.6625(b);
and

19
(2) Reducing these data to 4-hour rolling averages; and

(3) Maintaining the 4-hour rolling averages within the operating limitations for the operating
parameters established during the performance test. [40 CFR 63.6640(a) and Table 6 (11)].

II.B.2.g.2 Recordkeeping:

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

(b) Results of testing shall be maintained in accordance with Provision I.S.1 of this permit.
Records shall also comply with the applicable sections of 40 CFR 63.6660 and 63.6655 (a) and
(d).

II.B.2.g.3 Reporting:

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63, Subpart ZZZZ [40 CFR 63.6665]. The permittee shall also report each
instance in which it did not meet the applicable requirements in Table 8. [40 CFR 63.6640(e)]

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

The permittee shall submit the Notification of Compliance Status containing the results of the
initial compliance demonstration according to the requirements in 40 CFR 63.6645. [40 CFR
63.6630(c)]

The permittee shall report each instance in which the emission limitation or operating limitation
is not met. The permittee shall report each instance in which the applicable requirements of Table
8 are not met. [40 CFR 63.6640 (b) & (e)]
Notifications meeting the requirements of 40 CFR 63.6645(h); 40 CFR 63.7(b) and (c);
63.9(b)(2); 63.9(c), (d), (e), and (h) shall be submitted as specified and applicable. [40 CFR
63.6645 (a) & (h)]

Compliance reports meeting the requirements of 40 CFR 63.6650 shall be submitted as
applicable.

Status: In compliance – The engines are kept at hot stand by status. Therefore, it only requires 10 minutes
to start the engines to full load. Subpart ZZZZ CO stack testing for both diesel engines was
conducted on December 14, 2021. The stack tests are conducted triennially. The next stack test will
be due in December of 2024. Results of the stack test are as follows:

Stack Test Summary
Engine Stacks CO Limit CO Results
Engine 1 23 ppmvd @ 15% O2 13.5 ppmvd @ 15% O2
Engine 2 23 ppmvd @ 15% O2 20.5 ppmvd @ 15% O2

Testing company has been notified to submit a protocol for testing in December of this year.

20
II.B.2.h Condition:

The diesel fuel burned shall meet the requirements of 40 CFR 1090.305 for non-road engines.
[40 CFR 63.6604]. [40 CFR 63 Subpart ZZZZ]

II.B.2.h.1 Monitoring:

For each delivery of diesel fuel, the permittee shall inspect documentation provided by the vendor
that demonstrates compliance with this provision.

II.B.2.h.2 Recordkeeping:

The permittee shall maintain documentation demonstrating compliance with the condition.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.h.3 Reporting:

Reporting requirements shall be in accordance with Section I of this permit. The permittee shall
report each instance a delivery did not meet this condition.

Status: In compliance – Only ULS fuel is purchased.

II.B.2.i Condition:

If the engine is not equipped with a closed crankcase ventilation system, the permittee shall comply with
either paragraph (g)(1) or paragraph (g)(2) of 40 CFR 63.6625(g). The permittee shall follow the
manufacturer's specified maintenance requirements for operating and maintaining the open or closed
crankcase ventilation systems and replacing the crankcase filters, or can request the Administrator to
approve different maintenance requirements that are as protective as manufacturer requirements.
[40 CFR 63.6625(g)]. [40 CFR 63 Subpart ZZZZ]

II.B.2.i.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.i.2 Recordkeeping:

Operating and maintenance records shall be maintained to demonstrate compliance and in
accordance with Section I.S.1 of this permit.

II.B.2.i.3 Reporting:

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

Status: In compliance – The units have a closed crankcase system. Oil breakthrough is checked as part of
the maintenance procedures. The above listed maintenance schedules are as stringent as the
manufacture’s recommendations. Fans are checked to see if system is operating.

21
II.B.3 Conditions on Emergency Diesel Generators/Engines (Bloomington)

II.B.3.a Condition:

The minimum stack height shall be no less than 21 feet above ground level for each engine.
[DAQE -AN108920018-18]. [R307-401-8]

II.B.3.a.1 Monitoring:

The annual certification required for this permit condition will serve as monitoring.

II.B.3.a.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit.

II.B.3.a.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee
should certify with each annual certification report that each engine and stack compliance with
the permit condition during the reporting year.

Status: In compliance – The stack heights were determined during initial testing and have not been
modified. According to the annual compliance certification (ACC) all stacks are no less than 21 feet
above ground level.

II.B.3.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [40 CFR 63.6595(a), 40 CFR 63.6605(b)].
[40 CFR 63 Subpart ZZZZ]

II.B.3.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.b.2 Recordkeeping:

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

22
II.B.3.b.3 Reporting:

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

Status: In compliance – These units are in emergency service for the waste plants. They have
non-resettable hour meters and are used only if power is offline. Maintenance is conducted in
accordance with the manufacturer’s recommendations. Engines ran (as of August 31, 2024):
Engine 1 - 1.7 hours, Engine 2 - 1.8 hours, Engine 3 - 1.7 hours, Engine 4 - 3.4 hours,
Engine 5 - 1.7 hours, and Engine 6 - 1.7 hours. Engine 7 is on site but has been dismantled and used
for parts.

II.B.3.c Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
affected emission unit:

(1) The permittee shall operate the affected emission unit according to the requirements in 40 CFR
63.6640(f)(1) through (4). Any operation other than emergency operation, maintenance and testing,
emergency demand response, and operation in non-emergency situations for 50 hours per year,
paragraphs 40 CFR 63.6640(f)(1) through (4), is prohibited. If the engine is not operated in accordance
with paragraphs 40 CFR 63.6640(f)(1) through (4), it will not be considered an emergency engine and
shall meet all requirements for non-emergency engines

(2) The permittee shall meet the following requirements at all times, except during periods of startup:

(a) Change oil and filter every 500 hours of operation or annually, whichever comes first, except as
otherwise provided under (3) of this permit condition;

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;
(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.

(3) The permittee have the option to utilize an oil analysis program as described in 40 CFR 63.6625(i) in
order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

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

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

[40 CFR 63.6595(a)(1), 40 CFR 63.6603(a), 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f),
40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d, 40 CFR 63 Subpart ZZZZ Table 8, 40 CFR 63
Subpart ZZZZ Table 2d(footnote 1)]. [40 CFR 63 Subpart ZZZZ]

II.B.3.c.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)]
23
If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the work practice requirements on the required schedule, or if
performing the work practice on the required schedule would otherwise pose an unacceptable risk
under Federal, State, or local law, the work practice can be delayed until the emergency is over or
the unacceptable risk under Federal, State, or local law has abated. The work practice shall be
performed as soon as practicable after the emergency has ended or the unacceptable risk under
Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ Table 2c Footnote 1]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.3.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation, including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for demand response
operation, the permittee shall keep records of the notification of the emergency situation, and the
time the engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

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

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

24
II.B.3.c.3 Reporting:

The permittee shall report any failure to perform the work practice on the schedule required and
the Federal, State or local law under which the risk was deemed unacceptable. [40 CFR 63
Subpart ZZZZ Table 2c Footnote 1]

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

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

The permittee shall submit an annual report as specified in 40 CFR 63.6650(h) if the emergency
stationary RICE with a site rating of more than 100 hp that operates for the purpose specified in
40 CFR 63.6640(f)(4)(ii).

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

Status: In compliance – Maintenance is conducted in accordance with the manufacturer’s
recommendations. An operations log is maintained. Maintenance is done by St. George staff based
on the maintenance control system which has preventative and as needed maintenance activities
logged.

II.B.4 Conditions on Millcreek Natural Gas Turbine (MC-1)

II.B.4.a Condition:

Emissions of CO shall be no greater than 25 ppmv @ 15% O2 and 20.37 lb/hr.
[DAQE -AN108920018-18]. [R307-401-8]

II.B.4.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Emissions shall be tested annually. Tests may also be required at the direction of
the Director at any time.

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

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

(d) Methods.

(1) 40 CFR 60, Appendix A, Method 10 shall be used to determine CO emissions;

25
(2) 40 CFR 60, Appendix A, Method 2 shall be used to determine stack gas velocity and
volumetric flow rate.

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

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

II.B.4.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.4.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: In compliance – Annual CO stack testing for the Turbine (MC-1) was conducted on June 15, 2023.
Results of the stack test are as follows (see DAQC-805-23):

MC-1 6/15/23 RM10/CO 15.2 ppmvd* 15.3 ppmvd* 25 ppmvd*
12.95 lb/hr 12.94 lb/hr 20.37 lb/hr
*@15% O2

Testing was done April 19, 2024, with results pending.

II.B.4.b Condition:

Emissions of NOx shall be no greater than 25 ppmv @ 15% O2 and 33.5 lb/hr based on 30-day rolling
average. [DAQE -AN108920018-18]. [R307-401-8]

II.B.4.b.1 Monitoring:

(a) Stack testing shall be performed as specified here:

(1) Frequency. Emissions shall be tested annually. In addition, source shall be tested at any other
time if directed by the Director.

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

26
(3) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1. In addition, Occupational Safety and Health Administration (OSHA)
approved access shall be provided to the test location.

(4) Methods

(i) 40 CFR 60, Appendix A, Method 20 specified in NSPS subpart GG, shall be used to determine
the nitrogen oxides;

(ii) 40 CFR 60, Appendix A, Method 2 shall be used to determine stack gas velocity and
volumetric flow rate;

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

(6) Production Rate During Testing. The operational rate during initial compliance testing shall
be at the peak load, as an EPA-approved alternative to multiload testing specified in NSPS
subpart GG, and shall be corrected to ISO conditions using the appropriate equations supplied by
the manufacture.

(b) The permittee shall continuously monitor the appropriate parameters to determine whether the
affected unit is operating in the lean premixed (low-NOx) combustion mode. These parameters
may include percentage of full load, turbine exhaust temperature, combustion reference
temperature, compressor discharge pressure, fuel and air valve positions, dynamic pressure
pulsations, internal guide vane (IGV) position, and flame detection or flame scanner condition.
The acceptable values and ranges for all parameters monitored shall be specified in the
monitoring plan required under 40 CFR 75.19 for the unit, and parameters shall be monitored
during each subsequent operating hour.

(c) The daily average of NOx emissions shall be calculated according to the monitoring plan
required under 40 CFR 75.19 once for each day and the 30-day rolling average shall be calculated
by adding previous 30 days data on a daily basis.

II.B.4.b.2 Recordkeeping:

(a) Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

(b) The permittee shall keep all the records that include the name of all parameters monitored, the
acceptable values and ranges for all parameters, and the values of all parameters. Additionally,
the permittee shall keep records indicating whether the unit is operating in the premix mode for
each given operating hour.

27
II.B.4.b.3 Reporting:

(a) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except
those specified in Section I of this permit.

(b) The permittee shall submit reports of excess emissions and monitor downtime in
accordance with 40 CFR 60.7(c). An excess emission shall be any 4-hour rolling unit
operating hour average in which any monitored parameter does not achieve the target value
or is outside the acceptable range defined in the parameter monitoring plan for the unit. A
period of monitor downtime shall be any unit operating hour in which any of the required
parametric data are either not recorded or are invalid.

Status: In compliance – Annual NOx stack testing for the Turbine (MC-1) was conducted on June 15, 2023.
Results of the stack test are as follows (see DAQC-805-23):

MC-1 6/15/23 RM7/NOx 16.4 ppmvd* 16.4 ppmvd* 25 ppmvd*
22.9 lb/hr 22.9 lb/hr 33.5 lb/hr
*@15% O2

Testing was done April 19, 2024, with results pending.

II.B.4.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [DAQE -AN108920018-18]. [R307-401-8]

II.B.4.c.1 Monitoring:

In lieu of opacity monitoring, the report required for this permit condition will serve as
monitoring.

II.B.4.c.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit

II.B.4.c.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee
should certify each annual certification report that only pipeline quality natural gas is used as fuel
during the reporting year.

Status: In compliance – According to the ACC only pipeline quality natural gas is used as fuel for the
MC-1.

28
II.B.4.d Condition:

Hours of operation shall be no greater than 2,000 hours (including startups and shutdowns) per rolling
12-month period. [DAQE -AN108920018-18]. [R307-401-8]

II.B.4.d.1 Monitoring:

Operating hours shall be recorded using a meter or operations log. Hours shall be recorded at
least once a day when the equipment operates. Monthly hours of operation shall be determined
within the first 20 calendar days of each month, for the previous month, using operations logs or
records. The total shall then be added to the previous 11 months total for a 12-month rolling total.
Any adjustments to the total shall be fully explained and justified.

II.B.4.d.2 Recordkeeping:

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

II.B.4.d.3 Reporting:

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

Status: In compliance – According to the MC-1 operations log the turbine has operated for 1,537.90 hours
for the 12-month period ending August 31, 2024.

II.B.4.e Condition:

Sulfur content of the fuel combusted shall be no greater than 0.8 percent by weight. [40 CFR 60.333(b)].
[40 CFR 60 Subpart GG]

II.B.4.e.1 Monitoring:

In lieu of monitoring the total sulfur content of gaseous fuel combusted in the turbines, the
permittee should use one of the following sources of information to demonstrate that the gaseous
fuel meets the definition of natural gas in 40 CFR 60.331(u):

(a) The gas quality characteristics in a current, valid purchase contract, tariff sheet or
transportation contract for the gaseous fuel, specifying that the maximum total sulfur content of
the fuel is 20.0 grains/100 scf or less; or

(b) Representative fuel sampling data which show that the sulfur content of the gaseous fuel does
not exceed 20 grains/100 scf. At a minimum, the amount of fuel sampling data specified in
section 2.3.1.4 or 2.3.2.4 of appendix D to 40 CFR Part 75 is required.

II.B.4.e.2 Recordkeeping:

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

29
II.B.4.e.3 Reporting:

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

Status: In compliance - According to the ACC only pipeline quality natural gas is used as fuel for the
MC-1. The NG tariff sheet shows that fuel is certified for less than 15 gr/100 scf. See status of
condition II.B.4.c.

II.B.5 Conditions on Millcreek New Natural Gas Turbine (MC-2)

II.B.5.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [DAQE- AN108920018-18]. [R307-401-8]

II.B.5.a.1 Monitoring:

In lieu of opacity monitoring, the report required for this permit condition will serve as
monitoring.

II.B.5.a.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit.

II.B.5.a.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee
should certify each annual certification report that only pipeline quality natural gas is used as fuel
during the reporting year.

Status: In compliance – According to the ACC only pipeline quality natural gas is used as fuel for the
MC-2.

II.B.5.b Condition:

Emissions of NOx shall be no greater than 2.5 ppmv @ 15% O2 and 3.6 lb/hr based on 30-day rolling
average for normal operations. Emission of NOx during startup and shutdown periods shall not exceed 46
lb/hr. Normal operations shall exclude those periods of startup and shutdown.
[DAQE -AN108920018-18]. [40 CFR 60 Subpart KKKK, R307-401-8]

II.B.5.b.1 Monitoring:

(a) The permittee should install, certify, maintain, operate, and quality-assure a continuous
emissions monitoring systems (CEMS) to determine compliance with the applicable NOx
limitations as specified below:

30
(1) Each NOx and diluent CEMS must be installed and certified according to Performance
Specification 2 (PS 2) in appendix B of 40 CFR 60, except the 7-day calibration drift is based on
unit operating days, not calendar days. Procedure 1 in appendix F of 40 CFR 60 is not required.
Alternatively, a NOx diluent CEMS that is installed and certified according to appendix A of 40
CFR 75 should be acceptable for use. The relative accuracy test audit (RATA) of the CEMS shall
be performed on a lb/MMBtu basis.

(2) As specified in 40 CFR 60.13(e)(2), during each full unit operating hours, both the NOx
monitor and the diluent monitor must complete a minimum of one cycle of operation (sampling,
analyzing, and data recording) for each 15-minute quadrant of the hour. For partial unit operating
hours, at least one valid data point must be obtained with each monitor for each quadrant of the
hour in which the unit operates. For unit operating hours in which required quality assurance and
maintenance activities are performed on the CEMS, a minimum of two valid data points (one in
each of two quadrants) are required for each monitor to validate the NOx emission rate for the
hour.

(3) Each fuel flowmeter shall be installed, calibrated, maintained, and operated according to the
manufacturer's instructions. Alternatively, fuel flowmeters that meet the installation, certification,
and quality assurance requirements of appendix D of 40 CFR 75 should be acceptable for use.

(4) Each watt meter, steam flow meter, and each pressure or temperature measurement device
shall be installed, calibrated, maintained, and operated according to manufacturer's instructions.

(5) The permittee shall develop and keep on-site quality assurance (QA) plan for all of the
continuous monitoring equipment described in paragraphs above. For the CEMS and fuel flow
meters, the permittee may satisfy the requirements of this paragraph by implementing the QA
program and plan described in section 1 of appendix B to 40 CFR Part 75.

(6) For purposes of identifying excess emissions, CEMS data must be reduced to hourly averages
as specified in 40 CFR 60.13(h).

(i) For each unit operating hour in which a valid hourly average, as described in paragraph (a)(2)
of this section, is obtained for both NOx and diluent, the data acquisition and handling system
must calculate and record the hourly NOx emission rate in units of lb/MMBtu, using the
appropriate equation from method 19 in appendix A of 40 CFR 60. For any hour in which the
hourly average O2 concentration exceeds 19.0 percent O2, a diluent cap value of 19.0 percent O2
or 1.0 percent CO2 (as applicable) may be used in the emission calculation.

(ii) Correction of measured NOx concentrations to 15 percent O2 should not be allowed.

(iii) If the permittee has installed a NOx CEMS to meet the requirements of 40 CFR Part 75, only
quality assured data from EMMS should be bused to identify excess emission. Periods where the
missing data substitution procedures in subpart D of 40 CFR 75 are applied should be reported as
monitor downtime in the excess emissions and monitoring performance report required under 40
CFR60.7(c).
(iv) All required fuel flow rate, temperature, pressure, and megawatt data should be reduced to
hourly average. The calculated hourly average emission rates should be used to assess excess
emissions on a 4-hour rolling average basis.

(b) Each continuous emission monitoring system shall meet the Specifications and Test
Procedures required by 40 CFR Part 75, Appendix A.
31
(c) The permittee shall implement Quality Assurance and Quality Control Procedures required by
40 CFR Part 75, Appendix B.

(d) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, shall be used in addition to 40 CFR Part 75 procedures to fulfill data quality assurance
requirements.

(e) The permittee should calculate the 30-day rolling average be by averaging all hourly emission
data obtained from previous 30 days on a daily basis.

II.B.5.b.2 Recordkeeping:

Results of NOx monitoring shall be recorded and maintained as required in R307-170, 40 CFR 60
subpart KKKK, 40 CFR 75 subpart F, and as described in Provision I.S.1 of this permit.

II.B.5.b.3 Reporting:

(a) The permittee shall comply with the reporting provisions in R307-170-9, 40 CFR 75 Subpart
G, 40 CFR Subpart KKKK and all the reporting provisions contained in Section I of this permit.

(b) The permittee shall submit reports of excess emissions and monitor downtime, in accordance
with 40 CFR 60.7(c). Excess emissions shall be reported for all periods of unit operation,
including startup, shutdown and malfunction. For the purpose of reports required under 40 CFR
60.7(c), periods of excess emissions and monitor downtime that shall be reported are defined as
follows:

(1) An hour of excess emissions shall be any unit operating period in which the 4-hour or 30-day
rolling average NOx concentration exceeds applicable NSPS emission standard of 25 ppm (15%
O2) or 1.2 lb/MWh. A "4-hour rolling average NOx emission rate'' is the arithmetic average of the
average NOx emission rate in ppm or lb/MWH measured by the CEMS for a given hour and the
three unit operating hour average NOx emission rates immediately preceding that unit operating
hour. The permittee should calculate the rolling average if a valid NOx emission rate is obtained
for at least 3 of the 4 hours. A "30-day rolling average NOx emission rate'' is the arithmetic
average of all hourly NOx emission data in ppm or lb/MWh measured by the CEMS for a given
day and the twenty-nine unit operating days average NOx emission rates immediately preceding
that unit operating day. A new 30-day average is calculated each unit operating day as the
average of all hourly NOx emissions rates for the preceding 30 unit operating days if a valid NOx
emission rate is obtained for at least 75 percent of all operating hours.

(2) A period of monitor downtime shall be any unit operating hour in which the data for any of
the following parameters are either missing or invalid: NOx concentration, CO2 or O2
concentration, fuel flow rate, or megawatts.

(3) For operating periods during which multiple emissions standards apply, the applicable
standard is the average of the applicable standards during each hour. For hours with multiple
emissions standards, the applicable limit for that hour is determined based on the condition that
corresponded to the highest emissions standard.

32
(4) All reports of excess emissions and monitor downtime shall be postmarked by the 30th day
following the end of each calendar quarter.

(c) The quarterly reports required in R307-170-9 and 40 CFR 75 Subpart G are considered
prompt notification of permit deviations required in Provision I.S.2.c of this permit if all
information required by Provision I.S.2.c is included in the report.

Status: Not Evaluated – A CEM system that monitors real time NOx emissions has been installed and
operated. The CEM requirements are overseen by DAQ’s CEM specialist. The company is
required to submit quarterly state electronic data reports (SEDR) and perform a periodic relative
accuracy test audit. Readings during the inspection were 2.4 lb/hr and 1.5 ppm as 30-day averages
as unit was offline.

II.B.5.c Condition:

Total emissions of CO shall be no greater than 6 ppmv at 15% O2 and 5.21 lb/hr during normal operations
and should be no greater than 37 lb/hr during startup and shutdown. [DAQE-AN108920018-18].
[R307-401-8]

II.B.5.c.1 Monitoring:

The emission of CO shall be monitored by continuous emission monitoring system (CEMS). The
permittee shall calibrate, maintain, and operate a CEMS as required by R307-170 to determine
compliance with CO concentration (ppmv) and CO mass emission rate (lb/hr). The emission rate
(lb/hr) shall be calculated by multiplying the CO concentration and the volumetric flow rate and
any necessary conversion factors determined by the Director to give the results in the specified
units of the emission limitation. The CO concentration shall be determined from data generated
by the CEMS. The quality assurance requirements of R307-170, Continuous Emission
Monitoring Systems Program shall be used to fulfill data quality assurance requirements.

II.B.5.c.2 Recordkeeping:

Results of CO monitoring shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.

II.B.5.c.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and all the reporting
provisions contained in Section I of this permit. The quarterly reports required in R307-170-9 is
considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if
all information required by Provision I.S.2.c is included in the report.

Status: Not Evaluated – A CEM system that monitors real time CO emissions has been installed and
operated. The CEM requirements are overseen by DAQ’s CEM specialist. The company is
required to submit quarterly SEDRs and perform a periodic relative accuracy test audit. Readings
during the inspection were not done as unit was offline.

33
II.B.5.d Condition:

Combined 12- month rolling emissions from the natural gas turbine shall not exceed 16.65 tons for NOx
and 17.15 tons for CO. [DAQE-AN108920018-18]. [R307-401-8]

II.B.5.d.1 Monitoring:

The emissions shall be determined on a rolling 12-month total. Within the first 10 days of each
month, the total shall be calculated for each calendar month and added to the previous 11 months
data.

Monthly emissions shall be calculated using the following equation:

Monthly emissions (tons) turbine heat input [MMBtu/month] x emission factor [lb/MMBtu) x (1
ton/2000 lbs)

Fuel consumption shall be determined by a fuel meter provided for the turbine or from CEMs
data. Emission factors shall be as follows:

(a) NOx monthly average emission factor in lb/MMBtu shall be calculated from CEM-recorded
data (ppmdv) based on 40 CFR Part 60 App. A. Method 19;

(b) CO monthly average emission factor in lb/MMBtu shall be calculated from CEM-recorded
data (ppmv) based on 40 CFR Part 60 App. A. Method 19.

II.B.5.d.2 Recordkeeping:

Records such as gas meter readings, or CEMs data shall be kept on a continuous basis. Records
shall be maintained as described in Provision I.S of this permit.

II.B.5.d.3 Reporting:

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

Status: In compliance – The NOx and CO 12-month rolling emissions regarding MC-2 for the 12 month
period ending August 31, 2023, was:

Pollutants Limits (Tons) Results (Tons)
NOx 16.65 4.1
CO 17.15 5.2

II.B.5.e

Condition:

Fuel combusted shall not exceed potential sulfur emissions of 0.060 lb SO2/MMBtu heat input. [DAQE -
AN108920018-18]. [40 CFR 60 Subpart KKKK]

34
II.B.5.e.1 Monitoring:

In lieu of monitoring the total sulfur content of gaseous fuel combusted in the turbine, the
permittee should use one of the following sources of information to demonstrate that the gaseous
fuel meets the definition of natural gas in 40 CFR 60.331(u):

(a) The gas quality characteristics in a current, valid purchase contract, tariff sheet or
transportation contract for the gaseous fuel, specifying that the maximum total sulfur content of
the fuel is 20.0 grains/100 scf or less; or

(b) Representative fuel sampling data which show that the sulfur content of the gaseous fuel does
not exceed 20 grains/100 scf. At a minimum, the amount of fuel sampling data specified in
section 2.3.1.4 or 2.3.2.4 of appendix D to 40 CFR Part 75 is required.

II.B.5.e.2 Recordkeeping:

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

II.B.5.e.3 Reporting:

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

Status: In compliance - According to the ACC only pipeline quality natural gas is used as fuel for the
MC-2. The NG tariff sheet shows that fuel is certified for less than 15 gr/100 scf.

II.B.6 Conditions on Emergency Generator (Millcreek)

II.B.6.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [DAQE -AN108920018-18]. [R307-401-8]

II.B.6.a.1 Monitoring:

Opacity observations of emissions shall be conducted semi-annually in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.6.a.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.6.a.3 Reporting:

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

Status: N/A – The Millcreek emergency generator has been removed from the facility. See status of
condition II.A.

35
Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)].
[40 CFR 63 Subpart ZZZZ]

II.B.6.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.b.2 Recordkeeping:

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

II.B.6.b.3 Reporting:

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

Status: N/A – See status of condition II.B.6.a.

II.B.6.c Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
affected emission unit:

(1) The permittee shall operate the affected emission unit according to the requirements in 40 CFR
63.6640(f)(1) through (4). Any operation other than emergency operation, maintenance and testing,
emergency demand response, and operation in non-emergency situations for 50 hours per year,
paragraphs 40 CFR 63.6640(f)(1) through (4), is
prohibited. If the engine is not operated in accordance with paragraphs 40 CFR 63.6640(f)(1) through (4),
it will not be considered an emergency engine and shall meet all requirements for non-emergency
engines.

(2) The permittee shall meet the following requirements at all times, except during periods of startup:

(a) Change oil and filter every 500 hours of operation or annually, whichever comes first, except as
otherwise provided under (3) of this permit condition;

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

36
(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.

(3) The permittee has the option to utilize an oil analysis program as described in 40 CFR 63.6625(i) in
order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

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

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

[40 CFR 63.6595(a)(1), 40 CFR 636603(a), 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f),
40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d(4), 40 CFR 63 Subpart ZZZZ Table 8, 40 CFR 63
Subpart ZZZZ Table 2d(footnote 1)]. [40 CFR 63 Subpart ZZZZ]

II.B.6.c.1 Monitoring:

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

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under Federal, State, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
the unacceptable risk under Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

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

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

37
II.B.6.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation, including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for demand response
operation, the permittee shall keep records of the notification of the emergency situation, and the
time the engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

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

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

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

II.B.6.c.3 Reporting:

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

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified
in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also report each
instance in which it did not meet the applicable requirements in Table 8. [40 CFR 63.6640(e)]

The permittee shall submit an annual report as specified in 40 CFR 63.6650(h) if the emergency
stationary RICE with a site rating of more than 100 hp that operates for the purpose specified in
40 CFR 63.6640(f)(4)(ii).

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

Status: N/A – See status of condition II.B.6.a.

38
II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

II.E Source-specific Definitions.

Not applicable to this source.
SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

IV.A Utah Acid Rain Program Authority.

Authority to implement the Acid Rain Program is contained in R307-417, Permits:
Acid Rain Sources, and R307-415-6a(4), Standard permit requirements [for operating
permits].

IV.B Permit Requirements.

IV.B.1 The designated representative of the source and each affected unit at the source shall:

IV.B.1.a Submit a complete Acid Rain permit application (including a compliance
plan) under R307-417 and 40 CFR Part 72 in accordance with the deadlines
specified in 40 CFR 72.30; and

IV.B.1.b Submit in a timely manner any supplemental information that the Director
determines is necessary in order to review an Acid Rain permit application
and issue or deny an Acid Rain permit;

IV.B.2 The owners and operators shall:

IV.B.2.a Operate each affected unit at the source in compliance with a complete Acid
Rain permit application or a superseding Acid Rain permit issued by the
Director; and

IV.B.2.b Have an Acid Rain Permit.

Status: In compliance – The acid rain application was submitted with the operating permit
application. No changes have occurred. The permit is on site and operations appear to
be in accordance with the permit.

39
IV.C Sulfur Dioxide Requirements.

IV.C.1 The owners and operators of each affected unit at the source shall:

IV.C.1.a Hold allowances, as of the allowance transfer deadline, in the unit's
compliance subaccount (after deductions under 40 CFR 73.34(c)) not less
than the total annual emissions of sulfur dioxide for the previous calendar year
from the unit; and

IV.C.1.b Comply with the applicable Acid Rain emissions limitations for sulfur
dioxide.

IV.C.2 Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for
sulfur dioxide shall constitute a separate violation of the Act.

IV.C.3 An affected unit shall be subject to the requirements under Provision IV.C.1. of the
sulfur dioxide requirements as follows:

IV.C.3.a Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or

IV.C.3.b Starting on the later of January 1, 2000 or the deadline for monitor
certification under 40 CFR Part 75, an affected unit under 40 CFR 72.6(a)(3).

IV.C.4 Allowances shall be held in, deducted from, or transferred among Allowance Tracking
System accounts in accordance with the Acid Rain Program.

IV.C.5 An allowance shall not be deducted in order to comply with the requirements under
Provision IV.C.1.a. of the sulfur dioxide requirements prior to the calendar year for
which the allowance was allocated.

IV.C.6 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain
Program. No provision of the Acid Rain Program, the Acid Rain permit application,
the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no
provision of law shall be construed to limit the authority of the United States to
terminate or limit such authorization.

IV.C.7 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
does not constitute a property right.

Status: N/A – The company does not hold allowances.

IV.D Nitrogen Oxides Requirements.

The owners and operators of the source and each affected unit at the source shall
comply with the applicable Acid Rain emissions limitation for nitrogen oxide.

Status: In compliance - All applicable Acid Rain emission limitations for nitrogen oxide appear
in Section II of the permit.

40
IV.E Monitoring Requirements.

IV.E.1 The owners and operators and, to the extent applicable, designated representative of
each affected unit at the source shall comply with the monitoring requirements as
provided in 40 CFR Parts 74, 75, and 76.

IV.E.2 The emissions measurements recorded and reported in accordance with 40 CFR Part
75 shall be used to determine compliance by the unit with the Acid Rain emissions
limitations and emissions reduction requirements for sulfur dioxide and nitrogen
oxides under the Acid Rain Program.

IV.E.3 The requirements of 40 CFR Parts 74 and 75 shall not affect the responsibility of the
owners and operators to monitor emissions of other pollutants or other emissions
characteristics at the unit under other applicable requirements of the Act and other
provisions of the operating permit for the source.

Status: In compliance - These are included in the permit conditions above.

IV.F Recordkeeping and Reporting Requirements.

IV.F.1 Unless otherwise provided, the owners and operators for each affected unit at the
source shall keep on site at the source each of the following documents for a period of
5 years from the date the document is created. This period may be extended for cause,
at any time prior to the end of 5 years, in writing by the Administrator, USEPA, or
Director:

IV.F.1.a The certificate of representation for the designated representative for the
source and each affected unit at the source and all documents that demonstrate
the truth of the statements in the certificate of representation, in accordance
with 40 CFR 72.24; provided that the certificate and documents shall be
retained on site at the source beyond such 5-year period until such documents
are superseded because of the submission of a new certificate of
representation changing the designated representative;

IV.F.1.b All emissions monitoring information, in accordance with 40 CFR Part 75;

IV.F.1.c Copies of all reports, compliance certifications, and other submissions and all
records made or required under the Acid Rain Program; and,

IV.F.1.d Copies of all documents used to complete an Acid Rain permit application
and any other submission under the Acid Rain Program or to demonstrate
compliance with the requirements of the Acid Rain Program.

IV.F.2 The designated representative of each affected unit at the source shall submit the
reports and compliance certifications required under the Acid Rain Program, including
those under 40 CFR Part 72 Subpart I and 40 CFR Part 75.

Status: In compliance - All required records are on site and all data is kept.

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IV.G Excess Emissions Requirements.

IV.G.1 The designated representative of an affected unit that has excess emissions in any
calendar year shall submit a proposed offset plan to the Administrator, USEPA, as
required under 40 CFR Part 77.

IV.G.2 The owners and operators of an affected unit that has excess emissions in any calendar
year shall:

IV.G.2.a Pay without demand the penalty required, and pay upon demand the interest
on that penalty, to the Administrator, USEPA, as required by 40 CFR Part 77;
and

IV.G.2.b Comply with the terms of an approved offset plan, as required by 40 CFR Part
77.

Status: In compliance - No excess emissions under this regulation have occurred.

IV.H Liability.

IV.H.1 Any person who knowingly violates any requirement or prohibition of the Acid Rain
Program, a complete Acid Rain permit application, an Acid Rain permit, or a written
exemption under R307-417, 40 CFR 72.7 or 40 CFR 72.8, including any requirement
for the payment of any penalty owed to the United States, shall be subject to
enforcement pursuant to section 113(c) of the Act.

IV.H.2 Any person who knowingly makes a false, material statement in any record,
submission, or report under the Acid Rain Program shall be subject to criminal
enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001.

IV.H.3 No permit revision shall excuse any violation of the requirements of the Acid Rain
Program that occurs prior to the date that the revision takes effect.

IV.H.4 Each affected source and each affected unit shall meet the requirements of the Acid
Rain Program.

IV.H.5 Any provision of the Acid Rain Program that applies to an affected source (including
a provision applicable to the designated representative of an affected source) shall also
apply to the owners and operators of such source and of the affected units at the
source.

IV.H.6 Any provision of the Acid Rain Program that applies to an affected unit (including a
provision applicable to the designated representative of an affected unit) shall also
apply to the owners and operators of such unit. Except as provided under 40 CFR
72.44 (Phase II repowering extension plans) and 40 CFR 76.11 (NOx averaging
plans), and except with regard to the requirements applicable to units with a common
stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners
and operators and the designated representative of one affected unit shall not be liable
for any violation by any other affected unit of which they are not owners or operators
or the designated representative and that is located at a source of which they are not
the owners and operators, owners or operators, or the designated representative.
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IV.H.7 Each violation of a provision of 40 CFR Parts 72, 73, 74, 75, 76, 77, and 78 by an
affected source or affected unit, or by an owner or operator or designated
representative of such source or unit, shall be a separate violation of the Act.

IV.H.8 The owners and operators of a unit governed by an approved early election plan shall
be liable for any violation of the plan or 40 CFR 76.8 at that unit. The owners and
operators shall be liable, beginning January 1, 2000, for fulfilling the obligations
specified in 40 CFR Part 77.

Status: In compliance - Liabilities are handled under the compliance actions system. No
violations exist for this inspection period.

IV.I Effect on Other Authorities.

No provision of the Acid Rain Program, an Acid Rain permit application, an Acid
Rain permit, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as:

IV.I.1 Except as expressly provided in Title IV of the Act, exempting or excluding the
owners and operators and, to the extent applicable, the designated representative from
compliance with any other provision of the Act, including the provisions of Title I of
the Act relating to applicable National Ambient Air Quality Standards or the Utah
State Implementation Plan;

IV.I.2 Limiting the number of allowances, a unit can hold; provided, that the number of
allowances held by the unit shall not affect the source's obligation to comply with any
other provisions of the Act;

IV.I.3 Requiring a change of any kind in any State law regulating electric utility rates and
charges, affecting any State law regarding such State regulation, or limiting such State
regulation, including any prudence review requirements under such State law;

IV.I.4 Modifying the Federal Power Act or affecting the authority of the Federal Energy
Regulatory Commission under the Federal Power Act; or,

IV.I.5 Interfering with or impairing any program for competitive bidding for power supply in
a State in which such program is established.

Status: This is a statement of fact and not an inspection item.

EMISSIONS INVENTORY: The 2023 Emission Inventory was submitted on April 9, 2024.

St. George City Power’s 2023 Total Emission Inventory Summary:

Pollutants Tons/Year
PM10 4.20
PM2.5 4.20
SO2 0.35
NOX 30.77
VOC 1.61
CO 11.39

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PREVIOUS ENFORCEMENT
ACTIONS: None within the previous five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: St. George Power should be found in compliance with the Title V permit
at the time of this inspection. No further action is recommended.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: None

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Contact source prior to inspection to ensure access to the
sites.

ATTACHMENT: VEO Form