DAQ-2024-011089

Sunnyside Cogeneration Associates
P.O. Box 159 ' Sunnyside, Utah 84539 . [phone] . Fax [phone]
July 22,2024 UTAH DEPARTMENT OF
ENVIRONMENTAL OUAUTY
JUL 3 | 'o,)4
ll.i'.'!:i:0N OF A!R QUAt-!l-
Jay Morris
Utah Division of Air Quality
195 North 1950 West
Salt Lake city, utah 84116
Suzanne Bohan
EPA Region I
1595 Wynkoop Street (8ENF-AT)
Denver, CO 80202-1129
Subject: Notification of Quarterly Compliance Report 40 CFR 63 Subpart UUUUU
Sunnyside Cogeneration Associates (SCA)
Dear Mr. Morris:
This letter and attachments pertain to SCA's "Quarterly MATS Compliance Report" to
demonstrate compliance with the 40 CFR 63 Subpart UUUUU, sections 63. 1003 l (cX I )
thru (4), 63. l0(e)(3)(vi), 63.10020(e), 63.10021(e) and 63.9991.
SCA Unit I is reporting hourly SO2 emission rate averages (SO2RH) using its' existing
SO2 and 02 CEMS (Continuous Emission Monitoring Systems). These systems
completed their certification activities on Septernber 3, 2015 and was able to calculate the
first valid 30 boiler operating day average on October 2,2015.
SCA successfully demonstrated Lee status for Mercury emissions following the October
2016,30-day Hg sorbent trap test. On January 30,2017, SCA received an approval letter
from the Utah Department of Air Quality allowing SCA to move forward with annual 30-
day Hg performance testing.
B-2-10096
.Tffieiffi
Sun nyside Cogeneration Associates
. *D-I\/ISION OF AIR QUALITY"Summary Report"
Gaseous Excess Emission and Continuous Monitoring System Performance
Reporting Period January l,2024thru June 30,2OZ4
S63.10(el (31(vi) Summarv Report
(A) The company name and address of the affected source;
Sunnyside Cogeneration Associates (SCA)
One Power Plant Road
Sunnyside, Utah 84539
(B) An identification of each hazardous air pollutant monitored at the affected source;
Taken from Table 2 to Subpart UUUUU of part 53 - Emission Limits
As an existing unit, SCA Unit t has demonstrated compliance with the following emission limits:
SCA is using a SO2 emission rate system, and reporting hourly averages in units of lb./mmBtu, as
a surrogate for acid gases (HCL). We are showing compliance with emission limit or average of
2.0E-1 lb,/MMBtu (0.20 lb./mmBtu) on a 3Gday rolling average.
Using Hg sorbent traps for stack testing to demonstrate Hg LEE status. SCA Successfully
completed the three (3) year demonstration period on October t4,20!6. SCA received an
approval letter dated January 30,2017, from the State of Utah Air euality Division, to move
fonrrard with annual 30-day Hg performance testing.
PM stack tests are being used to demonstrate on-going LEE PM compliance. Demonstration
tests were performed quarterly for a three (3) year period. Demonstration testing began during
the 3'd quarter of 2015 and completed during the 2nd quarter of 2019.
SCA received approval from the State of Utah Air euality Division, to move forward with 3-year
PM compliance testing.
The beginning and ending dates of the reporting period;
This report covers the reporting period from January l,2oz4 thru June 30,2024
It should be noted that the SO2 emission rate system was first able to calculate a valid 30 BOD
rolling average to demonstrate compliance on October 2,ZOIS.
(C) A brief description of the process units;
02 ECOCHEM MC3 153
Probe ECOCHEM s132-0001
(F) The date of the latest CMS certification or audit;
RATA Test- May 23,2024
Cycle Time Test - July 3L,21ls
7-Day Drift Test - September 3, 2015
Linearity Test - June L7, 2024
(G) The total operating time of the affected source during the reporting period;
Total operating time during the reporting period was 3763 Hours.
(H) An emission data summary (or similar summary if the owner or operator monitors control
system parameters), including the total duration of excess emissions during the reporting period
(recorded in minutes for opacity and hours for gases), the total duration of excess emissions
expressed as a percent of the total source operating time during that reporting period, and a
breakdown of the total duration of excess emissions during the reporting period into those that
are due to startup/shutdown, control equipment problems, process problems, other known
causes, and other unknown causes;
The SCA facility had Zero excess emissions during the reporting period. There were no excess
emission events recorded greater than the emission limits listed in item (E).
(l) A CMS performance summary (or similar summary if the owner or operator monitors control
system parameters), including the total CMS downtime during the reporting period (recorded in
minutes for opacity and hours for gases), the total duration of CMS downtime expressed as a
percent of the total source operating time during that reporting period, and a breakdown of the
total CMS downtime during the reporting period into periods that are due to monitoring
equipment malfunctions, non-monitoring equipment malfunctions, quality assurance/quality
control calibrations, other known causes, and other unknown causes;
Below is the CMS downtime during the reporting period:
Channel Downtlme -
x of total
operatint
hours
Total cMs
Downtime
hours
Hours -
monitor
malfunction
Hours -
non-monltor
malfunction
Hours -Q/A
calibrations,
calibratlon
failures
Hours -
other
known
causeS
llours -
unknown
causas
so2 1.51 57 5 0 50 2 0
02 1.1s 57 5 0 50 2 0
Sun nyside Cogeneration Associates
"Semi-AnnuaI Compliance"
Reporting Period January t,Z0}4thru June 30,2024
$63. 10031(c) Compl iance Reoort
The reporting period for this report is hour 00 of January 7,2024 through hour 23 of June 30,
2024.
The compliance report must contain the information required in paragraphs (cX1) through (5) of this
section.
(1) The information required by the summary report located in G3,10 (e) (3Xvi) -
see the separate "summary Report" document prepared for this section.
(2) The total fuel use by each affected source subject to an emission limit, for each calendar month
within the semiannual reporting period, including, but not limited to, a description of the fuel, whether
the fuel has received a non-waste determination by EPA or your basis for concluding that the fuel is not
a waste, and the total fuel usage amount with units of measure.
Only two fuels were combusted during the reporting period. They are sub-bituminous coal and
#2 diesel fuel oil.
The coal amount listed below is not a waste fuel by EPA's definition under these regulations and
the units of measure are tons.
The #2 diesel fuel oil amount listed below is not a waste fuel by EPA's definition under these
regulations and the units of measure are gallons.
(3) lndicate whether you burned new types of fuel during the reporting period. tf you did burn new
types of fuel you must include the date of the performance test where that fuel was in use.
No new types of fuels were combusted during this reporting period.
Januarv February March April May June
Total 38485 40679 38250 8968 40287 43618
Januarv February March April May June
Total 13141 0 14102 22s66 0 4185
lndividualHours 3lL6l24-2 0 0 0
Generator off-
llne
3lL6l24-2
3rd Shut
down Event
Hourly
Quantfi of
Clean Fuel
kphl
Hourly Heat lnput
from Clean Fuel
(MMBtullHr
Hourly Electrical
load {MWs)
Bedn Date &
Hout'
3l2sl24-23
End Date & Hour 3l2sl24-23
lndlvldualHourc 3/2s124-23 0 0 0
Generator off-
line
3125124-23
4th Shut
down Event
Hourly
Quantlty of
Clean Fuel
kph)
Hourly Heat lnput
from Clean Fuel
(MMBtu)/Hr
Hourly Electrlcal
load (MWs)
Begln Date &
Hout'
4/s/24-23
End Date & Hour 4/s/24-23
lndfuidualHourc 415124-23 0 0 0
Generator off-
llne
4/s/24-23
5th Shut
down Event
Hourly
Quantity of
Clean Fuel
Ipohl
Hourly Heat lnput
from Clean Fuel
(MMBtul/Hr
Hourly Electrical
load (MWs)
Begln Date &
Hout'
617124-t7
End Date & Hour 617124-17
2nd Startup
Event
Hourly
Quantlty of
Clean Fuel
kph)
Hourly Heat
lnput from
Clean Fue!
(MMBtu/Hrl
Hourly electrical
load (MWsl
Berin Date & Houf 3/16124-3
End Date & Hours 3lt'l24-3
lndfuldualHours 3/76124-3 550 75 0
Generator on llne 3/16124-3 ss0 75 3.13
3rd Startup Even!Hourly
Quantity of
Clean Fuel
(rph)
Hourly Heat
lnput from
Clean Fuel
lMMBtu/Hrl
Hourly electrlcal
load (MWsl
Bedn Date & Houi 3125124-L
End Date & HouP 3/26124-s
!ndlvldualHourc 312612+7 250 35 0
3126124-2 550 75 0
3126124-3 1200 L66 0
3126124-4 1200 156 0
Generator on line 3/26124-S 1400 185 7.23
4th Startup Even!Hourly
Quantlty of
Clean Fuel
(cohl
Hourly Heat
lnput from
Clean Fuel
(MMBtu/Hrl
Hourly electrlcal
load (MWs)
Bedn Date & Hout'4127124-7
End Date & Hours 4127124-21
lndividualHours 4127124-t 250 35 0
4/27/24-2 550 75 0
4127/24-3 12m 166 0
4127124-4 1200 165 0
4127/24-s 1400 185 0
4/27/24-6 1400 185 0
3 This is the date and hour that the generator was synchronized which triggered the end of the
startup.
(iii) lf you choose to use CEMS for compliance purposes, include hourly average CEMS values and hourly
average flow rates. Use units of milligrams per cubic meter for PM CEMS, micrograms per cubic meter
for Hg CEMS, and ppmv for HCl, HF, or SOz CEMS. Use units of standard cubic meters per hour on a wet
basis for flow rates.
Emissions during shutdown and startup - as per Part 75.11 (e), when a unit is burning or combusting
only natural gas (or a low sulfur fuel), the actual hourly So2 measured value should not be reported, but
a facility should report an hourly value of 2.0 ppm and a method code of 16.
1* Shut down Events so2 (ppm)
Berin Date & Hour 72ltLl24-71
End Date & Hour Lalttl24-t7
lndividualHourc tal7Ll24-77 2.0
Generator off llne t2l1u24-77
2d Shut down Event So2 (ppml
Begln Date & Hour 3lL6l24-2
End Date & Hour 3lt6/24-2
lndlvldualHours 3176124-2 2.O
Generator off line 3l16124-2
3rd Shut down Event SOz (ppm)
Begin Date & Hour 3l2sl24-23
End Date & Hour 3l2sl24-23
lndlvldual Hourc 3125124-23 2.0
Generator off llne 3/2s/24-23
4th Shut down Event So2 (ppm)
Berin Date & Hour 4lsl24-23
lndivldual tlours 3lL6/24-3 2.O
Generator on line 3lL5l24-3
3rd Startup event so2 (ppm)
Begin Date & Hour 3126124-t
End Date & Hour 3126124-s
lndlvidualHourc 3126124-t 2.O
3126/24-2 2.0
3126124-3 2.0
3126124-4 2.0
Generator on llne 3126/24-s
4th Startup event So2 (ppml
Besln Date & Hour 4127124-7
End Date & Hour 4127124-21
!ndlvldualHours 4127/24-1 2.0
4127124-2 2.0
4127124-3 2.O
4127124-4 2.O
4127124-s 2.O
4127/24-6 2.O
4127/24-7 2.0
4/27124-8 2.O
4127124-9 2.O
4127124-10 2.0
4127124-11 2.O
4127124-72 2.0
4127124-t3 2.O
4127124-74 2.O
4127124-7s 2.O
4127124-76 2.0
4127124-17 2.0
4/27124-L8 2.0
4127124-Ls 2.O
4127/24-20 2.0
Generator on line 4127124-21
Su n nyside Cogeneration Associates
"Boiler Tune-Up"
Reporting Period January t,2OZ4 thru June 30,2OZ4
Prevlous boller Tune-Up was during April of 2023 and Subsequent boiler tune-up during Aprll
2024
Next scheduled Tune-Up will be Aprilof 2OZS.
(e) lf you must conduct periodic performance tune-ups of your EGU(s), as specified in paragraphs
(e)(1) through (9) of this section, perform the first tune-up as part of your initial compliance
demonstration. Notwithstanding this requirement, you may delay the first burner inspection until thenext scheduled unit outage provided you meet the requirements of S 63 10005. Subsequenfly, you
must perform an inspection of the burner at least once every 36 calendar months unless youi. eCU
employs neural network combustion optimization during normal operations in which case you mustperform an inspection of the burner and combustion controls at least once every 48 calendar
months.
The 63.'10021(e) ]un9-up specilications relate more to a pulverized coal unit technology and
not to circulatin_g fluidized boiler (CFB). SCA has completed he required boiler tune-up as itrelates to a CFB.
(1) As applicable, inspect the burner and combustion controls, and clean or replace any components
of the burner or combustion controls as necessary upon initiation of the work practice program andat least once every required inspection period. Repair of a burner or combustion control component
requiring specialorder parts may be scheduled as follows:
(i) Burner or combustion control component parts needing replacement that affect the ability tooptimize NOx and CO must be installed within 3 calendar months after the burner inspectioh,(ii) Burner or combustion control component parts that do not affect the ability to optimize NOx andCO may be installed on a schedule determined by the operator;
SCA is a Cirotlating Fluidized Boiler (CFB). SCA is not a pulverized coal unit. There are no
Bumers, mills or pulverized beders used in this technology.
The CFB technology is extremely efbctive in optimizing NOx and CO emissions.
(2) As applicable, inspect the flame pattern and make any adjustments to the burner or combustion
controls necessary to optimize the flame pattern. The adjustment should be consistent with the
manufacturer's specifications, if available, or in accordance with best combustion engineering
practice for that burner type;
SCA is a Ciranlating Fluidized Boiler (CFB). SCA is not a pulverized coal unit. There are no
Bumers, mills or pulverized beders used in this technology.
SCA is a Circulating Fluidized Boiler (CFB). SCA is not a pulverized coal unit. None of the
equipment listed above is related to CFB Technology.
SCA's control system is a DCS, no calibrations are required.
The CFB tecfrnology is extremely effective in optimizing NOx and CO emissions.
SCA does not have a CO monitor. We test for CO annually during our RATA Test. TheMeasured CO in the 2024 compliance test showed a decrease in -CO emissions.
(7) While operating at full load or the predominantly operated load, measure the concentration in theeffluent stream of CO and NOx in ppm, by volume, and oxygen in volume percent, before and afterthe tune-up adjustments are made (measurements may be either on a dry or wet basis, as long as it
is the same basis before and afier the adjustments are made). You may use portable CO, NOx-and
Oe monitors for this measurement. EGU's employing neural network opiimizaiion systems need onlyprovide a single pre- and post-tune-up value rather than continual values before and after eachoptimization adjustment made by the system;
SCA has a NOx analyzer which measures ppm and along with the 02 analyzer (volume %)
calculates lbs/mmbtu. A small decrease was noticed between pre and post outage following theApril2023 and April 2024boiler tune.ups. The change has more to do with fluctuations in the fuet
than calibrations.
Tune-up 2023
02 % volume before boiler tune-up = S.TO o/o
02 7o volume after boiler tun+up = 4.40 o/o
NOx ppm and lb/MMBtu before boiler tune-up = 121.0 ppm / 0.19 tbs/MMBtu
NOx ppm and lb/MMBtu after boiter tune-up = 119.9 ppm / 0.17 tbs/MMBtu
CO ppm and lb/MMBtu before boiter tune-up = 20.9 ppm tO.OZO tbs/MMBtu
CO ppm and lb/MMBtu after boiler tune-up = 1g.4 ppm / O.O1g lbs/MMBtu
Tune-uo 2024
02 % volume before boiler tune-up = 4.4O o/o
02 % volume after boiler tune-up = S.g0 %
NOx ppm and lb/MMBtu before boiler tune-up = 119.9 ppm / 0.17 tbs/MMBtu
NOx ppm and lb/MMBtu after boiter tune-up = .125.g ppm / 0.22 lbs/MMBtu
CO ppm and lb/MMBtu before boiler tune-up = 1g.4 ppm / 0.019 lbs/MMBtu
CO ppm and lb/MMBtu after boiler tune-up = 12.3 ppm / 0.013 tbs/MMBtu
(8) Maintain on-site and submit, if requested by the Adminishator, an annual report containing theinformation in paragraphs (e)(1) through (e)(9) of this section inctuding:
(i) The concentrations of CO and NOx in the effluent stream in ppm by volume, and oxygen in
volume percent, measured before and after an adjustment of the EGU combustion systems;(ii) A description of any corrective actions taken as a part of the combustion adjustment, and
Sunnyside Cogeneration Associates
"Startup or Shutdown Periods"
Reporting Period January t,2024 thru June 30,ZO24
053.10020(el Startup or Shutdown Periods
(e) Additional requirements during startup periods or shutdown periods.
(1) During each period of startup, you must record for each EGU:
(i) The date and time that clean fuels being combusted for the purpose of startup begins;
(ii) The quantity and heat input of clean fuel for each hour of startup;
(iii) The electrical load for each hour of startup;
(iv) The date and time that non-clean fuel combustion begins; and
(v) The date and time that clean fuels being combusted for the purpose of startup ends.
(2) During each period of shutdown, you must record for each EGU:
(i) The date and time that clean fuels being combusted for the purpose of shutdown begins;
(ii) The quantity and heat input of clean fuel for each hour of shutdown;
(iii) The electrical load for each hour of shutdown;
(iv) The date and time that non-clean fuel combustion ends; and
(v) The date and time that clean fuels being combusted for the purpose of shutdown ends.
The information required in (eX1) and (eX2) above is already included in the attached report
"semi-Annual compliance" Report - 863.10031 (c)(1) through (4)" as part of the semiannual
compliance report for the reporting period of January L,2024 thru June 30,2024.
(3) For PM or non-mercury HAP metals work practice monitoring during startup periods, you
must monitor and collect data according to this section and the site-specific monitoring plan
required by 563. 10011(l).
(i) Except for an EGU that uses PM CEMS or PM CPMS to demonstrate compliance with the
PM emissions limit or that has LEE status for filterable PM or total non-Hg HAP metals for
31261244 2L2.3s s037659
s000598
208.41
3126124-s 234.59 208.08
4th Startup event Temperature (F)Flow Rate (scfh)
TotalAir
FD Fan Amperage
4/27124-7 92.21 4090308 209.08
4127124-2 115.73 3898819 208.97
4127124-3 141.61 3841345 208.51
4/27124-4 158.70 3943017 207.94
4127124-s 184.16 4090308 207.57
4/27124-6 192.36 3898819 206.91
4/27124-7 202.52 384134s 209.42
4127124-8 210.68 4090308 209.81
4127124-e 2L3.77 3898819 209.85
4127124-tO 215.85 3841345 209.95
4127124-t1 216.71 39430L7 210.91
4127124-72 217.63 4008545 210.99
4127124-13 218.39 4136026 270.78
4127124-74 2t9.40 4777L98 zLL.t8
4127124-7s 223.06 4236307 217.1
4127124-L6 224.79 4579922 2L7.2s
4127124-17 231.43 478894L 274.48
4/27124-t8 223.20 5m9925 2L3.67
4127124-t9 219.40 4177198 211.18
4127124-20 223.06 4236307 217.L
4/27124-2L 224.79 4s79922 21t.25
sth Startuo event Temperature (F)Flow Rate (scfh)
Total Air
FD Fan Amperage
617/24-27 55.85 3841345 77.24
617124-22 LO7.54 M5TM7 209.28
617124-23 174.62 4579922 215.70
517124-24 208.30 4798941 2L5.49
618124-7 2L8.25 €90308 2L5.47
618124-2 2t4.78 3943017 240.87
618124-3 238.55 4114335 24L.59
618124-4 25t.77 423043r 243.59
6/8/24-s 232.45 rt415361 245.24
4th Startup event Temperature (F)
Stack Temp.
Flow Rate (scfh)
Stack
lD Fan Amperage
4/27124-7 66.99 4188941 155.99
4/27124-2 83.12 4090308 178.50
4/27124-3 103.s0 3898819 173.59
4127124-4 t25.97 3841345 t69.22
4127124-s 150.48 39430L7 155.4s
4127124-6 170.3s 4090308 L62.76
4/27124-7 779.20 3898819 L62.t4
4/27124-8 188.08 3841345 152.33
4/27124-9 195.14 4090308 L62.49
4127124-10 200.97 3898819 151.88
4127124-11 203.76 384134s 167.74
4127124-72 205.35 3943017 151.05
4127124-73 206.31 4008545 160.68
4127124-L4 207.s0 4736026 160.69
4127124-LS 208.59 4L77L98 150.78
4127124-L6 21L.25 4236307 150.80
4lZ7l24-L7 213.98 4579922 161.04
4127124-78 218.81 4788947 160.04
4127/24-ts 215.51 500992s 762.37
4127124-20 213.98 4579922 161.04
4/27124-2t 218.81 4788947 160.04
5th Startup event Temperature (F)
Stack Temo.
Flow Rate (scfh)
Stack
lD Fan Amperage
617124-27 il.94 3841345 L7.29
61il24-22 85.38 4/'5t4/-7 175.46
617124-23 136.04 4579922 L59.94
617124-24 175.04 478894L 163.54
618124-7 195.01 4090308 162.08
618124-2 2L7.26 3943017 150,80
618124-3 213.98 4114336 151.04
6/81244 218.81 423M31 160.04
618124-s 2t6.67 441s361 t62.37
Sunnyside Cogeneration Associates
"Work Practice Standards"
Reporting Period January 1,2024 thru June 30,2OZ4
As stated in $$63.9991, you must comply with the following applicable work practice standards:
SCA Unit 1 Power Plant is classified for MATS reporting purposes as an existing EGU.
lf our EGU is...
1. An existing EGU
You must meet the following...
Conduct a tune-up of the EGU burner and combustion controls at least each 36 calendar months,
or each 48 calendar months if neural network combustion optimization software is employed, as
specified in 963. 1 0021 (e).
SCA facility does not employ neural network combustion optimization software. But does
perform annual boiler tune-ups.
The latest boiler tune-up was during the April 2024 outage. See "Boiler Tune-Up" Report for
the Boiler Tune-Up lnformation,
SCA will perform the next boiler tune-up during the April 2025 outage.
3. A coal-fired, liquid oil-fired (excluding limited-use liquid oil-fired subcategory units), or solid oil-derived
fuel-fired EGU during startup
You have the option of complying using either of the following work practice standards.
(1) lf you choose to comply using paragraph (1) of the definition of "startup" in g63.'10042, you must
operate all CMS during startup. Startup means either the flrst-ever firing of fuel in a boiler for the
purpose of producing electricity, or the firing of fuel in a boiler after a shutdown event for any
purpose. Startup ends when any of the steam from the boiler is used to generate electricity for
sale over the grid or for any other purpose (including on site use). For startup of a unit, you must
use clean fuels as defined in $63.100a2 for ignition. Once you convert to firing coal, residual oil,
or solid oil-derived fuel, you must engage all of the applicable control technologies except dry
scrubber and SCR. You must start your dry scrubber and SCR systems, if present, appropriately
to comply with relevant standards applicable during normal operation. You must comply with all
applicable emissions limits at all times except for periods that meet the applicable definitions of
startup and shutdown in this subpart. You must keep records during startup periods. You must