DAQ-2024-011249

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-1071-24
Site ID 12825 (B5)

Dave Gammell, Plant Manager
Utah Associated Municipal Power Systems
1265 North Bamberger Road
Payson, UT 84651

Dear Mr. Gammell:

Re: Utah Associated Municipal Power Systems (Nebo Power Generating Station) – Pretest
Protocol for Carbon Monoxide (CO), Nitrogen Oxides (NOx), and Oxygen (O2) Relative
Accuracy Test – Utah County

The Utah Division of Air Quality (DAQ) reviewed Nebo Power Generating Station’s pretest
protocol submitted October 10, 2024. The proposed test shall be performed under the following
conditions:

Nebo Power Generating Station’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
HSRG
EU#2
CO Teledyne T200MO2 2125
NOx Teledyne T300 6545
O2 Teledyne T300 6545

Montrose Air Quality Services, LLC will conduct a relative accuracy/performance specification
test on Nebo Power Generating Station’s continuous monitoring system.

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour.

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
December 3, 2024 HSRG EU#2 CO, NOx, and O2 Method 3A, 7E, 10, and 19
1 , " / Û Ü Û Ù Û Ý
DAQC-1071-24
Page 2

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide Concentrations
in Emissions from Stationary Point Sources – (Instrumental Analyzer Procedure) as
outlined in 40 CFR 60 Appendix A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix
A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from Stationary
Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 19 - Determination of Sulfur Dioxide Removal Efficiency and
Particulate Matter, Sulfur Dioxide, and Nitrogen Oxides Emission Rates as outlined in
40 CFR 60 Appendix A.

• Deviations - The Director or the representative of the Director must be notified of and
approve deviations of the Reference Method test. Any deviation from these conditions
without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing contractor
from strict adherence to all applicable EPA methods, DAQ policies, Utah Air Quality
Rules (UAQR), and methods approved by the Director. Any deviation from EPA
methods, DAQ policies, UAQR, and methods approved by the Director must be
addressed separately and express written consent given prior to commencement of
testing.

• Field data (Point Source emission data and test data) shall be turned over to the DAQ
in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based on
Point Source continuous emission monitoring data and test data acquired by the staff
member of the DAQ during the test.

• All test reports must be submitted to the Director not later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with date
and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

DAQC-1071-24
Page 3

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and
maintained process conditions representative of normal operations, and operated
under such other relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements
and information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL:jl

cc: Utah County Health Department
Montrose Air Quality Services, LLC
* $ . # ( ) - — / A @ v A ? A C ? H w C H ˜
Rob Leishman Jr