Loading...
HomeMy WebLinkAboutDAQ-2024-0116421 DAQC-1146-24 Site ID 16121 (B1) MEMORANDUM TO: FILE – CRUSOE ENERGY SYSTEMS THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Joseph Randolph, Environmental Scientist DATE: November 14, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Major, Duchesne County, FRS ID #UT0000004901300215 INSPECTION DATE: October 23, 2024 SOURCE ADDRESS: 1 mile NE of Upalco MAIL ADDRESS: 1641 California Street, Suite 400, Denver, CO 80202 SOURCE CONTACT(S): Michael Duplantis (Denver), 832-754-3833 JD Herbert, local contact - 435-828-2665 Chase Hadden – supervisor – 435-828-6589 OPERATING STATUS: Operating, All IC engines; Turbine off line. PROCESS DESCRIPTION: The data center power station will contain two (2) compressor engines, ten (10) generator engines, and one (1) turbine; all this equipment will be fueled by gas that would otherwise be flared. The gas comes from the adjacent facility to the north and other nearby locations. Natural gas will be routed to compressor engines to increase the pressure of the gas prior to the mechanical refrigeration unit (MRU). The MRU strips out natural gas liquids (NGLs), creating a leaner gas to be fed to the turbine. Part of the MRU process includes the ethylene glycol (EG) dehydration units that remove water from the fluid stream. The gas is then directed to the generator engines and turbine. The generators and turbine use the gas as fuel to generate electricity for small data centers that will also be located onsite. The NGLs will be stored in pressurized storage tanks before being loaded offsite. Two (2) diesel-fuel emergency engine generators will be on site to power the data centers should the compressor engines, generator engines, turbine, and dehydrators go down or if there is a loss of utility electrical power. To date, none of the process equipment or back up engines have been installed. 0 ( 8 2 APPLICABLE REGULATIONS: AO DAQE-AN131210003-24 Dated September 18, 2024. NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines NSPS (Part 60), KKKK: Standards of Performance for Stationary Combustion Turbines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Major Source SOURCE INSPECTION EVALUATION: 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] Status: This is statement of fact and not an inspection item. I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: No specific operational limits are in this permit. 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] Status: In compliance. No unapproved equipment or modifications were noted during this inspection. 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] Status: In compliance. All records are kept at main offices in Denver and can be reviewed upon request. 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] Status: In compliance. All equipment seemed to be in good operational condition. The company has a preventive maintenance program. 3 I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In compliance. The company is aware of the breakdown rules. No breakdowns have been reported since start-up in June 2023. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In compliance. The inventory section does not show any outstanding inventories. Source start-up was June 2023. SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Duchesne Data Center Power Station II.A.2 Two (2) Compressor Engines Rating: 530 HP, each Fuel: Natural Gas Control: Non-selective catalytic reduction (NSCR) NSPS/MACT Applicability: 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ II.A.3 Ten (10) Generator Engines Rating: 2,500 HP, each Fuel: Natural Gas Control: Non-selective catalytic reduction (NSCR) NSPS/MACT Applicability: 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ II.A.4 Two (2) Emergency Engine Generator Sets Rating: 2,944 HP (2,000 kW), each Fuel: Diesel Control: Tier 4 Final (4f) NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ 4 II.A.5 One (1) Turbine Rating: 13,364 kW (133.1 MMBtu/hr) Fuel: Natural Gas Control: SoLoNOx (low NOx burners) NSPS Applicability: 40 CFR 60 Subpart KKKK Status: In compliance. All the listed equipment above has been installed with the exception of: II.B.4 the emergency engines have not been installed. All installed engines/turbine are 2021 or 2022 model year engines purchased new. Waukesha Engines Unit Number Serial Number 1251 1457259 1254 1453999 1283 1469776 1318 1632554 1358 1650541 1361 1650560 1362 1650569 1363 1650576 1364 1650581 1365 1658729 Turbine Unit Number Serial Number KG14856 KG14856 Fuel Gas Compressors for the Turbine Unit Number Serial Number 1663358 1663358 3221509 3221509 II.B REQUIREMENTS AND LIMITATIONS II.B.1 Natural Gas-Fired Engine and Turbine Requirements II.B.1.a The owner/operator shall not allow visible emissions from the natural gas-fired engines and turbine to exceed 10% opacity. [R307-401-8] 5 II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Method 9. [R307-401-8] Status: In Compliance. Observations during the inspection showed no visible emissions from any of the engines. VEOs were done of one each 2500 hp engines with zero percent readings. II.B.1.b The owner/operator shall use only natural gas as fuel for the 13,364 kW turbine, the 530 HP engines, and the 2,500 HP engines. [R307-401-8] Status: In Compliance. All fuel is natural gas from the adjoining property with no other connections noted. II.B.1.c The owner/operator shall equip all natural-gas fired engines with a non-selective catalytic reduction (NSCR) device to control emissions. [R307-401-8] Status: In compliance. All engines have catalyst and this is reviewed during stack testing. II.B.2 Stack Test Conditions II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from each of the indicated sources: Source Pollutant (g/bhp-hr) (lb/hr) 530 HP Compressor Engines NOx 0.15 0.18 CO 0.3 0.35 VOC 0.02 0.02 2,500 HP Generator Engines NOx 0.15 0.83 CO 0.3 1.65 VOC 0.03 0.17 13,634 kW Turbine NOx 0.33 13.33 CO 0.20 8.11 VOC 0.12 4.65 [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] 6 II.B.2.a.3 Test Frequency To demonstrate compliance with the NOx limits, the owner/operator shall conduct stack testing to verify the NOx emissions. The owner/operator shall conduct a stack test on each emission unit within one (1) year after the date of the most recent stack test of each emission unit. Upon demonstration through at least three (3) annual tests that the NOx limits are not being exceeded, the owner/operator may request approval to conduct stack testing less frequently than annually. To demonstrate compliance with the CO and VOC limits, the owner/operator shall conduct a stack test on each emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/ operator to perform a stack test at any time. [R307-401-8] Status: Testing was done in October, November, and December 2023 on all engines and turbine. See DAQC results, as attachments below. Testing was being done on the 10-2500 hp ICE engines during the inspection. The Turbine and two 530 hp ICE engines are scheduled to be tested in December 2024. The company plans to submit protocols 30 days in advance of testing. In compliance. 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] Status: Testing was done in October, November, and December 2023 on all engines. See DAQC results, as attachments below. Testing was being done on the 10-2500 hp ICE engines during the inspection. The Turbine and two 530 hp ICE engines are scheduled to be tested in December 2024. The company plans to submit protocols 30 days in advance of testing. Stack testing and protocol requirements are done by the stack testing person and contained in main source files. In compliance. 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] 7 II.B.2.c.1 Standard Conditions A. Temperature - 68oF (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.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: Stack testing and protocol requirements are done by the stack testing person and contained in main source files. In compliance. II.B.3 Diesel-Fired Emergency Engine Generator Set Requirements II.B.3.a The owner/operator shall not allow visible emissions from the diesel-fired emergency engines to exceed 20% opacity. [R307-401-8] Status: The two listed diesel engines have not been installed. No determination made. II.B.3.b The owner/operator shall not operate each 2,944 HP (2,000 kW) emergency generator engine on site for more than 100 hours per calendar year for maintenance checks and readiness testing. Each 2,944 HP (2,000 kW) emergency generator engine on site may be operated for up to 50 hours per calendrer year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar year for maintenance and testing. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.1 To determine compliance with the annual operation limitation, records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: The two listed diesel engines have not been installed. No determination made. II.B.3.c To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: The two listed diesel engines have not been installed. No determination made. 8 II.B.3.d The owner/operator shall install a 2,944 HP (2,000 kW) emergency engine that is certified to meet a controlled NOx emission rate of no greater than 0.50 g/hp-hr. [R307-401-8] II.B.3.d.1 To demonstrate compliance with the above condition, the owner/operator shall either: A. Own/operate a stationary internal combustion engine which has obtained Tier 4 certification as defined in 40 CFR 1039.801; or B. Conduct an initial performance test according to 40 CFR part 1039; or C. Maintain the manufacturer's emissions guarantee for the installed engine model. [R307-401-8] II.B.3.d.2 For each 2,944 HP (2,000 kW) engine generator on site, the owner/operator shall maintain records of engine certification, the initial performance test, or the manufacturer's emissions guarantee. [R307-401-8] Status: The two listed diesel engines have not been installed. No determination made. II.B.3.e The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the stationary diesel engine. [R307-401-8] Status: The two listed diesel engines have not been installed. No determination made. II.B.3.f The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD) as found in 40 CFR 1090.305. [R307-401-8] II.B.3.f.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: The two listed diesel engines have not been installed. No determination made. 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart JJJJ. All 12 Rice Engines are new (2021 or 2022) engines over 500 Hp. Subpart ZZZZ requires meeting Subpart JJJJ regulation. Subpart JJJJ requires certified engines and meeting manufacturers recommendations and no changes to AFR or catalyst use. Status: In compliance. All engines have emissions guarantees and certification from manufacturer as submitted with NOI. Company has maintenance program which follows manufacturers requirements. Units have tri catalyst and no control changes have been made according to company rep. 9 40 CFR 60 Subpart KKKK. Source has new (2022) NG turbine unit and is subject to Subpart KKKK. Subpart KKKK requires NOx emissions listed in Table 1 with annual testing or use of NOX CEM. SO2 emissions require use of tariff, testing or CEM. General good operational and maintenance are also required. Status: In compliance. The NOx limit is set in the AO with yearly testing frequency. Subpart requires 14 months or sooner. The Company has not installed CEMS for NOx or SOx. The company uses NG from consumer gas lines which meets the tariff requirements. The source has operated over one year. The source has a maintenance program which has preventative maintenance applications and all equipment appear to be in good operational order. EMISSION INVENTORY: The 2023 emission inventory shows: PM10: 3.09 PM2.5: 3.09 SO2: 1.07 NOx: 10.7 CO: 14.02 VOC: 3.36 PREVIOUS ENFORCEMENT ACTIONS: None. This is sources second inspection. COMPLIANCE STATUS & RECOMMENDATIONS: The source should be considered in compliance with conditions above. HPV STATUS: No. COMPLIANCE ASSISTANCE: Discussions with company rep on testing questions and subpart ZZZZ and KKKK requirements. RECOMMENDATION FOR NEXT INSPECTION: Call to schedule inspection. Site is not manned. ATTACHMENTS: VEO forms, DAQC-305-24 (stack test memo) and DAQC-125-24 (stack test memo). 1 DAQC-305-24 Site ID 16121 (B4) MEMORANDUM TO: STACK TEST FILE – CRUSOE ENERGY SYSTEMS – Duchesne Data Center Power Station THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Robert Sirrine, Environmental Scientist DATE: March 28, 2024 SUBJECT: Location: 1-mile northeast of Upalco, Duchesne County, Utah Contact: Ken Parker 720-495-3656, Pinyon ES-Kaitlin Meszaros 631-245-0308 Tester: Encino Environmental Services (EES) 281-201-3544 Tester: Great Plains Analytical Services (GAS), Macie McClellan 580-225-0403 Source: Engines GE-1251, 1254, 1283, 1318, 1358, 1361, 1362, 1363, 1364, and 1365. FRS Site ID#: UT0000004901300215 Permit #: AO DAQE-AN161210002-23 Dated February 13, 2023 Action Code: 3A Subject: Review of stack test report dated, December 6, 2023 On December 11, 2023, the Utah Division of Air Quality (DAQ) received a stack test report for emissions testing of the Crusoe Energy Systems Duchesne Data Center Power Plant’s, Ten Waukesha 2,500 hp Generator Engine Units 1251, 1254, 1283, 1318, tested by EES, and Engine Units 1358, 1361, 1362, 1363, 1364, and 1365 tested by GAS. All located in the Crusoe Energy Duchesne Data Center 1-mile northeast of Upalco, Duchesne County, Utah. Testing was performed October 24-27, 2023, by EES, and November 13-21, 2023, by GAS, to determine compliance with AO Condition II.B.2.a, and NSPS 40 CFR 60, Subpart JJJJ for NOX, CO, and VOC emissions. The DAQ calculated results are: Source Test Date RM/Pollutant DAQ Result Tester Result Limit GE 1283 10/24/23 */NOX 0.12 lb/hr 0.12 lb/hr 0.83 lb/hr 0.025 g/BHP-H 0.025 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.46 lb/hr 0.46 lb/hr 1.65 lb/hr 0.093 g/BHP-Hr 0.093 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.02 lb/hr 0.02 lb/hr 0.17 lb/hr 0.004 g/BHP-Hr 0.004 g/BHP-Hr 0.03 g/BHP-Hr GE 1251 10/25/23 */NOX 0.16 lb/hr 0.16 lb/hr 0.83 lb/hr 0.0.32 g/BHP-Hr 0.16 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.46 lb/hr 0.46 lb/hr 1.65 lb/hr 0.09 g/BHP-Hr 0.09 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.15 lb/hr 0.15 lb/hr 0.17 lb/hr 0.03 g/BHP-Hr 0.03 g/BHP-Hr 0.03 g/BHP-Hr 2 GE 1318 10/26/23 */NOX 0.00 lb/hr 0.00 lb/hr 0.83 lb/hr 0.00 g/BHP-Hr 0.00 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.52 lb/hr 0.52 lb/hr 1.65 lb/hr 0.11 g/BHP-Hr 0.11 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.00 lb/hr 0.00 lb/hr 0.17 lb/hr 0.00 g/BHP-Hr 0.00 g/BHP-Hr 0.03 g/BHP-Hr GE 1254 10/27/23 */NOX 0.05 lb/hr 0.05 lb/hr 0.83 lb/hr 0.01 g/BHP-Hr 0.01 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.51 lb/hr 0.51 lb/hr 1.65 lb/hr 0.10 g/BHP-Hr 0.10 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.15 lb/hr 0.15 lb/hr 0.17 lb/hr 0.03 g/BHP-Hr 0.03 g/BHP-Hr 0.03 g/BHP-Hr GE 1362 11/13/23 */NOX 0.15 lb/hr 0.15 lb/hr 0.83 lb/hr 0.03 g/BHP-Hr 0.03 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.40 lb/hr 0.40 lb/hr 1.65 lb/hr 0.08 g/BHP-Hr 0.08 g/BHP-Hr 0.3 g/BHP-Hr */VOC 0.02 lb/hr 0.02 lb/hr 0.17 lb/hr 0.004 g/BHP-Hr 0.004 g/BHP-Hr 0.03 g/BHP-Hr GE 1361 11/14/23 */NOX 0.33 lb/hr 0.33 lb/hr 0.83 lb/hr 0.06 g/BHP-Hr 0.06 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.795 lb/hr 0.795 lb/hr 1.65 lb/hr 0.15 g/BHP-Hr 0.15 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.023 lb/hr 0.023 lb/hr 0.17 lb/hr 0.004 g/BHP-Hr 0.004 g/BHP-Hr 0.03 g/BHP-Hr GE 1358 11/15/23 */NOX 0.15 lb/hr 0.15 lb/hr 0.83 lb/hr 0.03 g/BHP-Hr 0.03 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.80 lb/hr 0.80 lb/hr 1.65 lb/hr 0.16 g/BHP-Hr 0.16 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.03 lb/hr 0.03 lb/hr 0.17 lb/hr 0.01 g/BHP-Hr 0.01 g/BHP-Hr 0.03 g/BHP-Hr GE 1364 11/16/23 */NOX 0.075 lb/hr 0.075 lb/hr 0.83 lb/hr 0.015 g/BHP-Hr 0.015 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.48 lb/hr 0.48 lb/hr 1.65 lb/hr 0.10 g/BHP-Hr 0.10 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.025 lb/hr 0.025 lb/hr 0.17 lb/hr 0.01 g/BHP-Hr 0.005 g/BHP-Hr 0.03 g/BHP-Hr 3 GE 1363 11/20/23 */NOX 0.15 lb/hr 0.147 lb/hr 0.83 lb/hr 0.03 g/BHP-Hr 0.029 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.71 lb/hr 0.711 lb/hr 1.65 lb/hr 0.14 g/BHP-Hr 0.139 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.03 lb/hr 0.027 lb/hr 0.17 lb/hr 0.01 g/BHP-Hr 0.005 g/BHP-Hr 0.03 g/BHP-Hr GE 1365 11/21/23 */NOX 0.07 lb/hr 0.067 lb/hr 0.83 lb/hr 0.01 g/BHP-Hr 0.014 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.08 lb/hr 0.085 lb/hr 1.65 lb/hr 0.02 g/BHP-Hr 0.017 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.02 lb/hr 0.02 lb/hr 0.17 lb/hr 0.004 g/BHP-Hr 0.004 g/BHP-Hr 0.03 g/BHP-Hr *ASTM D6348-03 DEVIATIONS: No deviations were noted. CONCLUSION: The stack test report appears to be acceptable with the additional Technical Response information received March 22, 2024, and March 28, 2024, regarding the four engines tested by EES. These reports added missing and clarifying information to the ASTM 6348 QA/QC data in the initial test reports. RECOMMENDATION: GE Engines 1251, 1254, 1283, 1318, 1358, 1361, 1362, 1363, 1364, and 1365 should be considered to have been in compliance with the NOx, CO, and VOC applicable emissions limits at the time of testing. HPV: No. ATTACHMENT: Crusoe Energy Systems emissions testing report received December 11, 2023 Technical Response worksheets received from EES on March 22, 2024 Technical Response worksheets received from EES on March 28, 2024 DAQ generated excel spreadsheets 1 DAQC-125-24 Site ID # 16121-B4 MEMORANDUM TO: STACK TEST FILE – CRUSOE ENERGY SYSTEMS – Duchesne Data Center Power Station THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Robert Sirrine, Environmental Scientist DATE: February 6, 2024 SUBJECT: Location: One mile Northeast of Upalco, Duchesne County, UT Contact: Ken Parker 720-495-3656, Pinyon ES Kaitlin Meszaros 631-245-0308 Tester: Great Plains Analytical Services (GAS), Macie McClellan 580-225-0403 Source: Two 530 hp Waukesha H24 CEs and one 13,634 kw Titan 130 Turbine FRS Site ID#: UT0000004901300215 Permit #: AO DAQE-AN161210002-23 Dated February 13, 2023 Action Code: Tr Subject: Review of stack test report dated January 5, 2024 On January 8, 2024, the DAQ received a stack test report for emissions testing of the Crusoe Energy Systems – Duchesne Data Center Power Station’s, two 530 hp Waukesha H24 compressor engines and one 13,634 kw Titan 130 Turbine located 1 mile Northeast of Upalco, Duchesne County, UT. Testing was performed December 20-21, 2023, to determine compliance with AO Condition II.B.2.a, and NSPS 40 CFR 60, Subpart JJJJ for NOX, CO, and VOC emissions. The DAQ calculated results are: Source Test Date RM/Pollutant DAQ Result Tester Result Limit CE H24-1 12/20/23 */NOX 0.12 lb/hr 0.12 lb/hr 0.18 lb/hr 0.12 g/BHP-H 0.12 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.02 lb/hr 0.02 lb/hr 0.35 lb/hr 0.02 g/BHP-Hr 0.02 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.01 lb/hr 0.01 lb/hr 0.02 lb/hr 0.01 g/BHP-Hr 0.006 g/BHP-Hr 0.02 g/BHP-Hr CE H24-2 12/20/23 */NOX 0.01 lb/hr 0.01 lb/hr 0.18 lb/hr 0..01 g/BHP-H 0.01 g/BHP-Hr 0.15 g/BHP-Hr */CO 0.02 lb/hr 0.025 lb/hr 0.35 lb/hr 0.03 g/BHP-Hr 0.025 g/BHP-Hr 0.30 g/BHP-Hr */VOC 0.004 lb/hr 0.004 lb/hr 0.02 lb/hr 0.004 g/BHP-Hr 0.004 g/BHP-Hr 0.02 g/BHP-Hr 2 Source Test Date RM/Pollutant DAQ Result Tester Result Limit Turbine 12/21/23 */NOX 2.44 lb/hr 2.42 lb/hr 13.33 lb/hr 0.09 g/BHP-Hr 0.09 g/BHP-Hr 0.33 g/BHP-Hr */CO 0.06 lb/hr 0.06 lb/hr 8.11 lb/hr 0.002 g/BHP-Hr 0.002 g/BHP-Hr 0.20 g/BHP-Hr */VOC 0.72 lb/hr 0.716 lb/hr 4.65 lb/hr 0.03 g/BHP-Hr 0.028 g/BHP-Hr 0.12 g/BHP-Hr *ASTM D6348-03 DEVIATIONS: No deviations were noted. The one discrepancy is the Turbine lb/hr value for NOX, which is an error in entering the correct final value in the test report since the three values listed in the report yield a final average of 2.44 lb/hr which matches the DAQ calculated value. CONCLUSION: All method stipulated QA/QC requirements appear to have been met as determined by a review of the report and entering the provided data into our Excel spreadsheets. The emissions test report appears to be acceptable. RECOMMENDATION: The two 530 hp Waukesha H24 CEs and one 13,634 kw Titan 130 Turbine should be considered to have been in compliance with the NOx, CO, and VOC applicable emissions limits at the time of testing. HPV: No. ATTACHMENT: Crusoe Energy DDC stack testing report received January 8, 2024. DAQ generated Excel spreadsheets.