DAQ-2024-012006

1
DAQC-CI155230001-24
Site ID 15523 (B1)

MEMORANDUM

TO: FILE – UTAH ASSOC. MUNICIPAL POWER SYSTEMS – Veyo Waste Heat
Recovery Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: December 9, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County

INSPECTION DATE: August 7, 2024

SOURCE LOCATION: Remote location northwest of St. George
Washington County, UT
DIRECTIONS: Take 1-15 to the St. George Bluff Street exit. Then take
Highway 18 north to Veyo. Take Center Street in Veyo west for
about 5.5 miles to the Eagle Mt. Ranch and turn north on
well-maintained dirt road heading northwest for about 4 miles to
the facility.

SOURCE CONTACTS: Erik Campbell, Power Superintendent
[e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: The waste heat recovery facility utilizes the exhausted heat from
the Kern River Veyo CS turbines and generates energy for the
electrical grid.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN155230001-15, dated
November 5, 2015
NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) A: General Provisions,
MACT (Part 63) -A: General Provisions,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

* - ) - # )
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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Utah Assoc. Municipal Power Systems - Veyo
Waste Heat Recovery Facility

155 North 400 West Suite 480 Remote location northwest of St. George
Salt Lake City, UT 84103 Washington County, UT

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] Status: In Compliance. No limits have been exceeded. No unapproved equipment was observed at the time of inspection. No breakdowns have occurred since the previous inspection. No Emission Inventory is required at this source at the current time.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Site Operations Waste Heat Recovery Facility
II.A.2 Site Operations One (1) Ormat Energy Converter Unit/Turbine Informational purpose only
3
II.A.3 Engine One (1) Diesel Powered Standby Generator
Capacity: 389 hp

Status: In Compliance. No unapproved equipment was observed at the time of
inspection.

II.B Requirements and Limitations
II.B.1 Site Wide Requirement
II.B.1.a The VOC emissions from waste heat recovery facility shall not exceed 12.7 tons per rolling 12-month period. [R307-401]
II.B.1.a.1 Compliance with each limitation shall be determined on a calendar year basis (Jan. 1 - Dec. 31).
A cumulative total of annual emissions shall be maintained. No later than 20 days after the end of
each month, the cumulative annual total shall be updated to include the data from the previous month. [R307-401]

II.B.1.a.2 The VOC emissions shall be determined by maintaining a record of VOC materials injected into the facility each month. The record shall include the amount of VOC material injected, the
density of the material (pounds per gallon), the percent by weight of VOC and the gallons of
VOC. The amount of VOC emitted monthly by the VOC material used shall be calculated by the following procedure: VOC = % VOC by Weight / 100 x [Density ( lb / gal )] x Gal Consumed x
1 ton / 2000 pounds. The amount of VOCs reclaimed for the month shall be similarly quantified
and subtracted from the quantities calculated above to provide the monthly total VOC. [R307-401]

Status: In Compliance. The rolling 12-month total for VOCs injected from August 2023 to July 2024, is 0.0 tons of VOC. The source hasn't injected VOCs into the facility within the
previous 12 months. Source does maintain calculations when that does occur. Source has
not tracked VOC injections, as the source has never injected VOCs. Based on email conversation with Erik Campbell, they are tracking this information based on the amount
of pentane added to the system when conducting maintenance, as that is when there is a
chance for emissions since they operate on a closed loop system normally. They add pentane to the system from a pentane storage tank onsite. They have not added pentane
within the previous 12 months, as the level of pentane in the system has remained at the
same amount, 44 gallons. See the attachments section for more information.
II.B.1.b The emergency generator shall be used for electricity producing operation only during the
periods when electric power from the public utilities is interrupted. The emergency diesel generators shall be limited to 100 hours of operation per rolling 12-month period for regular
maintenance and testing. [R307-401]
Status: In Compliance. The runtime for the generator from August 2023 to July 2024, is
32.6 hours. Source maintains monthly records of generator operation, as well as noting the
usage.

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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) IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. The generator applies to this subpart. The generator is maintained and operated
according to manufacturer's specifications. The generator runtime was less than 100 hours within the
previous 12-month period, with the hours of operation being 32.6 hours. This generator is a certified
Tier IV generator under 500 hp, which does not require performance testing.
NSPS (Part 60) A: General Provisions

Status: Compliance with subpart A is determined by compliance with applicable federal subparts. In
compliance with Subpart IIII.
MACT (Part 63) -A : General Provisions

Status: Compliance with subpart A is determined by compliance with applicable federal subparts. In
compliance with Subpart ZZZZ.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. The generator onsite applies to this subpart. The generator did not exceed 100
hours of operations within the previous 12-month period, 32.6 hours being the runtime for the
generator. The generator is equipped with a non-resettable meter and is maintained according to
manufacturer's specifications.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. The diesel fuel utilized onsite is characterized as ULSD, according to a fuel
invoice from Pilot Thomas logistics. A copy of the fuel invoice can be found in the attachments
section.
Stationary Sources [R307-210]

Status: In Compliance. R307-210 is applicable as this source is subject to NSPS Part 60 Subpart IIII.
See Section III for compliance information.
National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. R307-214 is applicable as this source is subject to MACT Part 63 Subpart
ZZZZ. See Section III for compliance information.

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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Utah Assoc.
Municipal Power Systems - Veyo Waste Heat Recovery Facility on the Approval Order (AO)
DAQE-AN155230001-15, dated November 5, 2015. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 17.01
Carbon Monoxide 0.11
Nitrogen Oxides 0.13
Particulate Matter - PM10 0.01
Particulate Matter - PM2.5 0.01
Volatile Organic Compounds 12.78

Hazardous Air Pollutant PTE lbs/yr

PREVIOUS ENFORCEMENT
ACTIONS: None

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN155230001-15,
dated November 5, 2015, the overall status is: In Compliance. In
compliance with the conditions listed. Records were provided
upon request.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the usual frequency

NSR RECOMMENDATIONS: None

ATTACHMENTS: Applicable Supporting Documentation Included
INVOICE
UTAH ASSOCIATED MUNICIPAL
155 N 400 W STE 480
SALT LAKE CITY, UT 84103
Sold To:0006737
Ordered By:
VEYO POWER PLANT
VEYO, UT 84782
ERIK CAMPBELL 435-705-6109
GUNLOCK 84733
UT
435-705-6109
Ship To:1000
Related Entities:
Simons Petroleum, LLC 4/25/2024
0898086-IN
Invoice Date:
Invoice Number:
Ship Date:
Salesperson:
Due Date:
4/25/2024
5/13/2024

KENDELL COOK
Apply to Invoice:
Acct Rep:
Rep. Email
AR SUPPORT
[e-mail]
ACH and Wire Instructions:
JP Morgan Chase
Account# 961901136
ABA# 111000614 (ACH)
ABA# 021000021 (FED WIRES)
Swift Code: CHASUS33 (FED WIRES)
P.O.:NET 20 DAYSTerms:
Item No:Unit:Ordered:Price:Shipped:Amount:
BOL# 0000272805,71534154Comment:
Item Description:Alias Item Number
/FUELSRG 20.90
FUEL SURCHARGE
227 GAL
Whse:WA4
534.73 200.00
ULSD #2 DYED
3.5792 149.40
ADD-PSBK680OZ CASE
Whse:LA4
577.73 0.25
PS BIO KLEEN BIOCIDE 6/80OZ
2,310.9188 0.25
Excise Tax Recap
FED LUST - DSL 0.00100 0.15
FED OIL SPILL - DSL 0.00214 0.32
FED SUPERFUND RECOVERY FEE 0.00405 0.61
UT ENVIRONMENTAL FEE 0.00650 0.97
To sign up for the PTL Portal to view invoices and place orders online please contact [e-mail]
Net Invoice:1,135.41
Sales Tax:0.00
1,135.41 Invoice Total:
Current 1 - 30 31 - 60 61 - 90 90 +
Customer Aging Summary as of 8/13/2024
0.00 0.00 0.00 0.00 0.00
If there is an issue with this invoice please email [e-mail]
Remit Address:
PO Box 737749
Dallas, TX 75373-7749
Jordan Garahana <[e-mail]>
Records Request for Inspection
17 messages
Jordan Garahana <[e-mail]>Thu, Aug 8, 2024 at 4:48 PM
To: "[e-mail]" <[e-mail]>
Hello Erik,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's Division of Air Quality. I am
requesting some records for inspection. these are the records I am requesting:
VOC emissions from the facility from August 2023 to July 2024 (II.B.1.a)
A record of the VOCs injected into the facility each month if applicable, including the calculation of the VOCs emitted
(II.B.1.a.2)
The hours the diesel powered generator operated from August 2023 to July 2024 (II.B.2.a)
A recent copy of a bill of sale for the diesel fuel purchased and utilized onsite that shows the diesel fuel is ultra low sulfur.
Please let me know if you have any questions. Please have these records to me by Friday, August 16th.
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Erik Campbell <[e-mail]>Thu, Aug 8, 2024 at 6:20 PM
To: Jordan Garahana <[e-mail]>
Jordan, I would be happy to get this information to you. Are you referring to the UAMPS Veyo Heat
Recovery Project and the backup generator for there?
[Quoted text hidden]
Jordan Garahana <[e-mail]>Mon, Aug 12, 2024 at 12:06 PM
To: Erik Campbell <[e-mail]>
Hey Erik,
12/9/24, 3:26 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5029168876340533817&simpl=msg-a:r328375389690966…1/5
Yes I am referring to the Veyo Waste Heat Recovery Facility.
Thanks,
Jordan Garahana
[Quoted text hidden]
Erik Campbell <[e-mail]>Tue, Aug 13, 2024 at 4:16 PM
To: Jordan Garahana <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
Jordan attached is the latest fuel invoice for the generator.
Total hours of run time August 3rd, 2023 (484.9 hrs.)-July 1st, 2024 (517.5 hrs.) are 32.6 hours.
On the VOC’s injected we don’t monitor those numbers due to it being a backup generator.
Let me know if you have any other questions. I also have cc Wayne Anderson with UAMPS on this email in
case you have questions I am unable to answer.
[Quoted text hidden]
Invoice 898086 Utah Association Municipal 04 25 24.pdf
51K
Jordan Garahana <[e-mail]>Tue, Aug 13, 2024 at 4:29 PM
To: Erik Campbell <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
Hey Erik,
Thank you for the information you provided me. Were there any VOC emissions calculated from the facility for the
timeframe I specified in my original email?
Thanks,
Jordan
[Quoted text hidden]
Erik Campbell <[e-mail]>Tue, Aug 13, 2024 at 5:33 PM
To: Jordan Garahana <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
No we haven’t. This is the first time we have ever been asked anything regarding VOCs. The past couple of times that I
have dealt with an inspector from the state they just wanted the hours ran and did a visual on the unit.
Sent from my iPhone
On Aug 13, 2024, at 4:30 PM, Jordan Garahana <[e-mail]> wrote:
[Quoted text hidden]
Jordan Garahana <[e-mail]>Tue, Nov 5, 2024 at 2:10 PM
To: Erik Campbell <[e-mail]>
Hey Erik,
12/9/24, 3:26 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5029168876340533817&simpl=msg-a:r328375389690966…2/5
Sorry for the late response to this but I need some more information regarding the VOCs injected and emitted from the
facility. This AO condition is related to the pentane and VOC emissions from the OEC unit, not the generator. If you could
please provide me with the numbers from the timeframe in my original email with a monthly breakdown that would be
appreciated.
Thanks,
Jordan
[Quoted text hidden]
Jordan Garahana <[e-mail]>Tue, Nov 12, 2024 at 10:57 AM
To: Erik Campbell <[e-mail]>
Hey Erik,
Just checking in on my request for more information. Please respond to me as soon as possible with the information I am
requesting.
Thanks,
Jordan
[Quoted text hidden]
Erik Campbell <[e-mail]>Tue, Nov 12, 2024 at 11:06 AM
To: Jordan Garahana <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
Jordan, regarding the pentane system it is a closed loop system with no exhaust. So there is no VOCs for
us to monitor.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Tue, Nov 12, 2024 at 1:30 PM
To: Chad Gilgen <[e-mail]>
Hey Chad,
I requested more information from Erik about the Veyo Facility and this was his response regarding the VOCs and
pentane injected into the system at the facility. Is this sufficient for the compliance status for that portion of my inspection?
Or is this considered a compliance issue?
Thanks,
Jordan
[Quoted text hidden]
Chad Gilgen <[e-mail]>Thu, Nov 21, 2024 at 1:41 PM
To: Jordan Garahana <[e-mail]>
Hi Jordan,
No, this does not address my questions/comments. Please see my previous email with the comments and Notice of
Intent for this site. These pentane emission conditions are not related to exhaust. Pages 23 and 24 of the NOI state this
is a closed loop system and the pentane emissions are associated with maintenance of the unit when additional pentane
is added.
If they cannot provide this information then it is a potential compliance issue.
Chad
Chad Gilgen | Manager | Minor Source Compliance
12/9/24, 3:26 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5029168876340533817&simpl=msg-a:r328375389690966…3/5
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Thu, Nov 21, 2024 at 1:54 PM
To: Erik Campbell <[e-mail]>
Hey Erik,
The pentane emissions condition of the AO is not related to the exhaust. The pentane emissions are related to the overall
maintenance of the system when additional pentane is added to the system. This information comes from the original
Notice of Intent that this facility filed in 2015 and described the closed loop system and the pentane losses from the
system. If the amount of pentane added to the system is not being tracked and that information cannot be provided, then
this is considered a compliance issue. Please let me know if you have any questions.
Thanks,
Jordan
[Quoted text hidden]
Erik Campbell <[e-mail]>Thu, Nov 21, 2024 at 3:13 PM
To: Jordan Garahana <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
Pentane Storage Tank Levels.
July 3rd, 2023- 44 ½”
June 27th,2024- 44 ½”
[Quoted text hidden]
Jordan Garahana <[e-mail]>Thu, Nov 21, 2024 at 3:31 PM
To: Erik Campbell <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
Hey Erik,
Thanks for sending this over. Just for clarification, you have not added any pentane into the system when conducting
maintenance within the last year? You are tracking how much is added when that does happen, correct?
Thanks,
Jordan
[Quoted text hidden]
Erik Campbell <[e-mail]>Thu, Nov 21, 2024 at 4:07 PM
To: Jordan Garahana <[e-mail]>
Cc: Wayne Anderson <[e-mail]>
12/9/24, 3:26 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5029168876340533817&simpl=msg-a:r328375389690966…4/5
Jordan, we did not add any pentane to the system from July 3rd,2023 to June 27th, 2024. Yes we do track
when pentane is added to the system and it is also on our rounds sheet to check the level of the pentane
storage tank.
[Quoted text hidden]
Jordan Garahana <[e-mail]>Thu, Nov 21, 2024 at 4:19 PM
To: Chad Gilgen <[e-mail]>
Hey Chad,
I received a response from Erik at the Veyo facility. He states that they do track the amount of pentane that is added when
maintenance is conducted and that they haven't added any pentane within the last year. I explained to him what we were
looking to see if that additional pentane usage was tracked and he states that it is based on what is added from the
pentane storage tank. They check the levels and record them. Is there anything more we need to request?
Thanks,
Jordan
[Quoted text hidden]
Chad Gilgen <[e-mail]>Fri, Dec 6, 2024 at 10:17 AM
To: Jordan Garahana <[e-mail]>
Hi Jordan,
That sounds like it covers everything. Please include that information in your memo.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/9/24, 3:26 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-5029168876340533817&simpl=msg-a:r328375389690966…5/5