HomeMy WebLinkAboutDAQ-2024-0109851
DAQC-CI133530001-24
Site ID 13353 (B1)
MEMORANDUM
TO: FILE – SANTA CLARA CITY POWER – Power Generation Facility
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Jared James, Environmental Scientist
DATE: September 12, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County
INSPECTION DATE: August 15, 2024
SOURCE LOCATION: 3979 Santa Clara Drive
Santa Clara, UT 84765
DIRECTIONS: Office is located on the south side at the west end of the
generator building.
SOURCE CONTACTS: Erik Campbell, Operator
435-705-6109, ecampbell@sccity.org
OPERATING STATUS: Operating normally.
PROCESS DESCRIPTION: Santa Clara City Power maintains and operates four (permit
capacity for five) Caterpillar natural gas-fired internal
combustion generator engines. They provide electrical power to
the city during peak hours (Noon - 10:00 pm) mostly during
June, July, and August.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN133530004-21, dated
September 15, 2021
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Santa Clara City Power
Power Generation Facility
2603 Santa Clara Drive 3979 Santa Clara Drive
Santa Clara, UT 84765 Santa Clara, UT 84765
0 0
2
SIC Code: 4911: (Electric Services)
Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: In Compliance. No limits appear to have been exceeded. No modifications have
been made to equipment or process. Records are maintained and were provided for review
at the time of inspection. Equipment is regularly maintained. No reportable breakdowns
have occurred since the previous inspection. No emission inventory is required at this time.
Out of Compliance with I.8, the source has installed two 2,707 kW generators with plans to
install the third in the next couple of years. No notification was made for the installation of
the two generators. No further action is recommended.
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Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Power Generation Plant
Source Wide
II.A.2 Two (2) Internal Combustion Engines
Fuel: Natural Gas
Rating: 2154 kW (2889 hp) each
Required Minimum Stack Height: 39 feet above ground level each
Controls: Oxidation Catalyst
Federal Applicability: MACT Subpart ZZZZ
II.A.3 Three (3) Internal Combustion Engines
Fuel: Natural Gas
Rating: 2,707 kW (3630 hp) each
Required Minimum Stack Height: 39 feet above ground level each
Controls: Oxidation Catalyst
Federal Applicability: NSPS JJJJ and MACT ZZZZ
Status: In Compliance. No unapproved equipment was observed. There are two 2,154
kW and two 2,707 kW generator engines currently on-site.
II.B Requirements and Limitations
II.B.1 Power Generation Plant.
II.B.1.a The owner/operator shall not allow visible emissions from all internal combustion engines on site
to exceed 10% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions shall be conducted in accordance with 40 CFR 60, Appendix
A, Method 9. [R307-201-3]
Status: In Compliance. No visible emissions were observed at the time of inspection.
II.B.1.b The owner/operator shall not operate each internal combustion engine for more than 4,000 hours
per rolling 12-month period. [R307-401-8]
II.B.1.b.1 The owner/operator shall:
A. Determine hours of operation by maintaining an operations log
B. Record hours of operation each day
C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months
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D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]
Status: In Compliance. Records are maintained in accordance with A – D. Records
provided at the time of inspection reported the following run times for the engines during
the corresponding 12-month period:
Engine 1 - 144 hours
Engine 2 - 210 hours
Engine 3 - 812 hours
Engine 4 - 860 hours
II.B.1.c The owner/operator shall only use natural gas as fuel in the internal combustion engines.
[R307-401-8]
Status: In Compliance. Only natural gas is used as fuel.
II.B.1.d The owner/operator shall comply with all requirements in 40 CFR 63, Subpart ZZZZ applicable
to the 2154 kW Internal Combustion Engines. [40 CFR 63 Subpart ZZZZ]
Status: In Compliance. Stack tests have been conducted. Regular maintenance is
conducted according to manufacturer's recommendations. The engines operate on natural
gas. The engines are equipped with non-resettable hour meters.
II.B.2 Stack Testing.
II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from the
2154 kW Engines:
Pollutant lb/hr ppmdv
NOx 3.18 108.72
CO 1.36 76.07
The owner/operator shall not emit more than the following rates and concentrations from the
2707 kW Engines:
Pollutant lb/hr ppmdv
NOx 4.00 136.75
CO 0.73 40.83
VOC 0.60 61.78. [R307-401-8]
II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]
II.B.2.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]
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II.B.2.a.3 Test Frequency The owner/operator shall conduct subsequent stack tests for the following emissions units
according to the following schedule. The owner/operator must complete subsequent emission
tests within the indicated time after the date of the most recent stack test. The Director may require the owner/operator to perform a stack test at any time.
A. The 2154 kW Engines - Test every five (5) years
B. The 2707 kW Engines - Test every three (3) years or 8760 hours of operation after the
date of the most recent stack test, whichever comes first. [40 CFR 60 Subpart JJJJ, R307-165-2, R307-401-8]
II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]
II.B.2.b.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]
II.B.2.b.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.2.b.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]
II.B.2.b.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]
II.B.2.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.2.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]
II.B.2.c.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
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II.B.2.c.2 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]
II.B.2.c.3 VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A,
Method 320; or other EPA-approved testing method as acceptable to the Director.
[R307-401-8]
II.B.2.c.4 CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]
Status: In Compliance. Stack tests were conducted on September 20 and 21, 2022. All
emission rates were within limits. Acceptance of test protocol is documented in
DAQC-975-22, and test result acceptance is documented in DAQC-203-23. The results are
as follows:
Source Test
Date
Test
Method Pollutant Tester Results DAQ Results Limits
Unit 1
2154 kW
Engine
Sept, 21,
2022
7E NOx 2.389 lb/hr
77.65 ppmdv
2.394 lb/hr
41.905 ppmdv@15%O2
3.18 lb/hr
108.72
ppmdv@15%O2
10 CO 0.199 lb/hr
10.57 ppmdv
0.198 lb/hr
5.649 ppmdv@15%O2
1.36 lb/hr
76.07 ppmdv@15%O2
Unit 2
2154 kW
Engine
Sept, 21,
2022
7E NOx 2.635 lb/hr
92.84 ppmdv
2.635 lb/hr
49.627 ppmdv@15%O2
3.18 lb/hr
108.72
ppmdv@15%O2
10 CO 0.388 lb/hr
22.44 ppmdv
0.387 lb/hr
11.970 ppmdv@15%O2
1.36 lb/hr
76.07 ppmdv@15%O2
Unit 3
2707 kW
Engine
Sept, 20,
2022
7E NOx 3.864 lb/hr
83.20 ppmdv
3.868 lb/hr
45.885 ppmdv@15%O2
0.522 g/hp-hr
4.00 lb/hr
136.75
ppmdv@15%O2
1.0 g/hp-hr
10 CO 0.423 lb/hr
14.93 ppmdv
0.422 lb/hr
8.218 ppmdv@15%O2
0.057 g/hp-hr
0.73 lb/hr
40.83 ppmdv@15%O2
2.0 g/hp-hr
25A VOC 0.427 lb/hr
8.37 ppmdv
0.426 lb/hr
5.273 ppmdv@15%O2
0.058 g/hp-hr
0.60 lb/hr
61.78 ppmdv@15%O2
0.7 g/hp-hr
Unit 4
2707 kW
Engine
Sept, 20,
2022
7E NOx 3.823 lb/hr
82.11 ppmdv
3.834 lb/hr
47.017 ppmdv@15%O2
0.523 g/hp-hr
4.00 lb/hr
136.75
ppmdv@15%O2
1.0 g/hp-hr
10 CO 0.327 lb/hr
11.51 ppmdv
0.322 lb/hr
6.481 ppmdv@15%O2
0.044 g/hp-hr
0.73 lb/hr
40.83 ppmdv@15%O2
2.0 g/hp-hr
25A VOC 0.324 lb/hr
6.25 ppmdv
0.350 lb/hr
4.488 ppmdv@15%O2
0.048 g/hp-hr
0.60 lb/hr
61.78 ppmdv@15%O2
0.7 g/hp-hr
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Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including
UAC R307.
NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
Status: In Compliance. The engines operate on natural gas. Regular maintenance is conducted
according to the manufacturer's recommendations following a PM schedule.
MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: In Compliance. See condition II.B.1.d.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]
Status: In Compliance. No visible emissions were observed from any point during the inspection.
Stationary Sources [R307-210]
Status: In Compliance. See status for JJJJ.
National Emission Standards for Hazardous Air Pollutants [R307-214]
Status: In Compliance. See status for ZZZZ.
EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Santa Clara City
Power – Power Generation Facility on the Approval Order (AO) DAQE-AN133530004-21, dated
September 15, 2021. PTE are supplied for supplemental purposes only.
Criteria Pollutant PTE tons/yr
Carbon Monoxide 12.58
Nitrogen Oxides 43.10
Particulate Matter - PM10 2.59
Particulate Matter - PM2.5 2.59
Sulfur Dioxide 0.15
Volatile Organic Compounds 6.74
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Hazardous Air Pollutant PTE lbs/yr
1,3-Butadiene (CAS #106990) 46
2,2,4-Trimethylpentane (CAS #540841) 44
Acetaldehyde (CAS #75070) 1440
Acrolein (CAS #107028) 886
Benzene (Including Benzene From Gasoline) (CAS #71432) 76
Biphenyl (CAS #92524) 36
Formaldehyde (CAS #50000) 8000
Generic HAPs (CAS #GHAPS) 90
Hexane (CAS #110543) 192
Methanol (CAS #67561) 431
Toluene (CAS #108883) 70
Xylenes (Isomers And Mixture) (CAS #1330207) 32
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN133530004-21,
dated September 15, 2021, the overall status is: In Compliance.
The source appeared to be well maintained and operated
properly. Records were provided at the time of inspection for
review.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal
NSR RECOMMENDATIONS: None at this time.
ATTACHMENTS: VEO Form.