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HomeMy WebLinkAboutDAQ-2024-0120801 DAQC-CI141380001-24 Site ID 14138 (B1) MEMORANDUM TO: FILE – TICABOO UTILITY IMPROVEMENT DISTRICT – Ticaboo Generation Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jordan Garahana, Environmental Scientist DATE: December 11, 2024 SUBJECT: ATTEMPTED COMPLIANCE EVALUATION, Minor, Garfield County INSPECTION DATE: August 29, 2024 SOURCE LOCATION: 135 West Mesa Way Ticaboo, UT 84533 DIRECTIONS: Take Ticaboo Road into town by the gas station. Follow Ticaboo Road to Mesa Drive. Turn right onto Mesa Drive and follow it to the gated entrance by the solar panels. The Daryl P. Winters Power Plant is located on the north side of a large hill. SOURCE CONTACTS: John Motley, Director of Energy Resources 435-337-2021, john@ticaboouid.com OPERATING STATUS: Unknown PROCESS DESCRIPTION: The source consists of four diesel-fired, internal combustion, electrical generation engines and two diesel storage tanks. The source generates electricity year-round for the town of Ticaboo and for the Bullfrog Marina at Lake Powell during the warmer months. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN141380008-15, dated November 10, 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 * - ) - # ) 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Ticaboo Utility Improvement District Ticaboo Generation Facility Highway 276, Mile Marker 27 P.O. Box 2140 P.O. Box 2140 Ticaboo, UT 84533 Ticaboo, UT 84533 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 appear to have been exceeded. No breakdowns have occurred since the previous inspection. No Emission Inventory is required at this source. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: 3 II.A.1 Daryl P. Winters Power Plant Permitted source II.A.2 Engine 1 Caterpillar C15 (500), 779 hp (listed rating), w/ charge air cooling and exhaust gas recirculation, Tier 4 II.A.3 Engine 2 Caterpillar C9, 241 hp (listed rating), w/ charge air cooling, Tier 3 II.A.4 Engine 3 Caterpillar C9, 241 hp (listed rating), w/ charge air cooling, Tier 3 II.A.5 Engine 4 MQ Power DCA150SSI, 240 hp (listed rating), w/ charge air cooling and exhaust gas recirculation, Tier 3 II.A.6 Tank 1 15,000 gallon diesel storage tank II.A.7 Tank 2 15,000 gallon diesel storage tank Status: Compliance Not Determined. Unable to view equipment or facility during attempted inspection. Source emailed information regarding the generators, including photographs of the equipment and power output. Source also verified the equipment list via email. See the attachments section for additional information. II.B Requirements and Limitations II.B.1 Conditions on Permitted Source. II.B.1.a The total amount of diesel burned shall not exceed 150,000 gallons per rolling 12-month period. By the last day of each month a new 12-month total shall be calculated using data from the previous 12 months. Diesel consumption shall be determined by examination of operation logs. [R307-401-8] Status: In Compliance. The rolling 12-month total for diesel fuel burned from August 2023 to July 2024 is as follows: 63,090 gallons of diesel fuel burned Totals are calculated monthly by the end of each month. See the attachments section for additional information. II.B.1.b The sulfur content of any diesel burned shall not exceed 0.0015% by weight. [R307-203-1] II.B.1.b.1 For each delivery of oil, the permittee shall either: (a) Determine the fuel sulfur content expressed as wt% in accordance with the methods of the American Society for Testing Materials (ASTM); or 4 (b) Inspect the fuel sulfur content expressed as wt% determined by the vendor using methods of the ASTM; or (c) Inspect documentation provided by the vendor that indirectly demonstrates compliance with this provision. [R307-203-1] Status: In Compliance. According to the invoice from Pierce Oil, the diesel fuel utilized onsite is classified as ULSD. See the attachments section for a copy of the invoice. II.B.1.c All emissions from the diesel engine generators shall be vented vertically unrestricted. [R307-410] Status: Compliance Not Determined. Unable to view equipment during the attempted inspection. 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: Compliance Not Determined. The generators onsite are subject to this subpart. They are Tier 3 and Tier 4 generators that are onsite. Currently, there are no annual maintenance reports that demonstrate the generator is being maintained according to the manufacturer’s guidelines. Maintenance is conducted on the engines on a timed basis, based on usage. Compliance assistance was provided via email to the source to ensure the generators are being maintained according to the manufacturer’s specifications. Source either needs to create an SOP that would detail how they are following the recommendations from the manufacturer on maintaining the generator and creating an annual report or they need to have the manufacturer service the generators annually. NSPS (Part 60) A: General Provisions Status: Compliance with Subpart A is determined by compliance with applicable subparts. Compliance not determined with Subpart IIII. MACT (Part 63) -A : General Provisions Status: Compliance with Subpart A is determined by compliance with applicable subparts. Compliance not Determined with Subpart ZZZZ. 5 MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: Status: Compliance Not Determined. The generators onsite are subject to this subpart. They are Tier 3 and Tier 4 generators that are onsite. Compliance assistance was provided via email to the source to ensure the generators are being maintained according to the manufacturer’s specifications. Source either needs to create an SOP that would detail how they are following the recommendations from the manufacturer on maintaining the generator and creating an annual report or they need to have the manufacturer service the generators annually. 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. According to the invoice from Pierce Oil, the diesel fuel utilized onsite is classified as ULSD. See the attachments section for a copy of the invoice. Stationary Sources [R307-210] Status: R307-210 applies 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: R307-214 applies as this source is subject to MACT 63 Subpart ZZZZ. See Section III for compliance information. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Ticaboo Utility Improvement District – Ticaboo Generation Facility on the Approval Order (AO) DAQE-AN141380008-15, dated November 10, 2015. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 2314.60 Carbon Monoxide 6.10 Nitrogen Oxides 48.20 Particulate Matter - PM10 14.10 Particulate Matter - PM2.5 14.10 Sulfur Dioxide 16.30 Volatile Organic Compounds 0.10 Hazardous Air Pollutant PTE lbs/yr Total HAPs (CAS #THAPS) 200 6 PREVIOUS ENFORCEMENT ACTIONS: None within the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN141380008-15, dated November 10, 2015, the overall status is: Compliance not determined. Unable to view equipment at the facility during attempted inspection. The source provided records, information, and photographs of equipment after attempted inspection via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Contact before inspecting to inquire about operating status. The facility is located behind a locked fence that requires staff to be there to allow entrance into the facility. NSR RECOMMENDATIONS: None. ATTACHMENTS: Applicable Supporting Documentation Included Jordan Garahana <jordangarahana@utah.gov> Records Request for Inspection 1 message Ticaboo Admin <admin@ticaboouid.com>Fri, Aug 30, 2024 at 9:43 AM To: "jordangarahana@utah.gov" <jordangarahana@utah.gov> Cc: "john@ticaboouid.com" <john@ticaboouid.com> Hi Jordan, You're correct; Chip is no longer in Ticaboo. John Motley is now the TUID general manager (copied here). Let us know what kind of informaon you need and we'll see if we can find it for you. Thanks, Connie From: Jordan Garahana <no-reply@ruralwaterimpact.com> Sent: Friday, August 30, 2024 8:57 AM To: admin@ticaboouid.com <admin@ticaboouid.com> Subject: New Website Contact - Records Request for Inspecon You have received the following Customer Contact Submission Form from your website. Date: Aug 30, 2024 8:57:40AM Contact Name: Jordan Garahana Email: jordangarahan@utah.gov Phone: Account Number: Service Address: NA Department: Customer Support Subject: Records Request for Inspection Comments: Hello, My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah\'s Division of Air Quality. I am looking for some records as part of an inspection of the Ticaboo Utility Improvement District facility. I am looking for a contact who can provide me with the records I am requesting as it seems that Chip Shortreed no longer works here. Please let me know who I can contact in order to help complete my inspection. Thanks, Jordan Garahana Sent from ticaboouid.com Sender's IP address 166.70.239.210 10/22/24, 4:04 PM State of Utah Mail - Records Request for Inspection https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1808827824580074226 1/1 Jordan Garahana <jordangarahana@utah.gov> Records Request 17 messages Jordan Garahana <jordangarahana@utah.gov>Mon, Oct 7, 2024 at 10:36 AM To: "john@ticaboouid.com" <john@ticaboouid.com> Hey John, My name is Jordan Garahana and I made a request about a month ago for records from an inspection. Sorry I forgot to follow up on my records request. Things have been busy here the last month and this got lost in my inbox. Can you please send me the amount of diesel fuel utilized by the plant from August 2023 to July 2024, and a recent fuel invoice that shows the diesel fuel is ULSD? Thanks, Jordan Garahana -- Jordan Garahana Environmental Scientist | Minor Source Compliance M: (385) 271-2871 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. john@ticaboouid.com <john@ticaboouid.com>Mon, Oct 7, 2024 at 11:31 AM To: Jordan Garahana <jordangarahana@utah.gov>, john@ticaboouid.com Cc: admin@ticaboouid.com Jordan, I must have lost this too. We’re prepping for financials and a public meeting this week, so it may take a few days, but we can get the information to you. A few questions and comments: Do you want the “usage” to be based on what we purchased during that time vs actual consumption? I’ll check on the USLD. I assume it is, but our power plant is a tier 3 approved plant, so I’ll verify. I think that is all we can get regardless. 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…1/11 Let us know what other questions or requests you have, and we can get this for you guys. John Motley Director of Energy Resources North Lake Powell/Ticaboo Ulity Improvement District john@ticaboouid.com Hwy 276 MM 28, Ticaboo, UT 84533 Office: 435-337-2021 Visit our website at: www.ticaboouid.com CONFIDENTIALITY NOTICE This e-mail message, including any aachments, is for the sole use of the intended recipient(s) and may contain confidenal and privileged informaon. You are hereby nofied that any review, use, disclosure, duplicaon or distribuon of this transmission by someone other than the intended recipient is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Mon, Oct 7, 2024 at 11:33 AM To: john@ticaboouid.com Hey John, That's no problem at all. I am looking for the consumption. When you provide that number, can you please include a monthly breakdown for each month in the timeframe I am requesting? Thanks, Jordan [Quoted text hidden] john@ticaboouid.com <john@ticaboouid.com>Thu, Oct 17, 2024 at 4:32 PM To: Jordan Garahana <jordangarahana@utah.gov> Jordan, Apologies for the delay. We had some generator issues and I’m a one man show for most of the work. Let me know how these look and if you need anything else. Date gallons used gph 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…2/11 8/1/2023 8180 9/1/2023 5755 10/1/2023 5745 11/1/2023 3800 12/1/2023 3750 1/1/2024 4200 2/1/2024 4300 3/1/2024 3890 4/1/2024 3980 5/1/2024 4090 6/1/2024 7200 7/1/2024 8200 Total gallons used 63090 7.29 avg gph [Quoted text hidden] TUID Pierce oil invoice 7 24.pdf 436K Jordan Garahana <jordangarahana@utah.gov>Fri, Oct 18, 2024 at 10:34 AM To: john@ticaboouid.com Hey John, Thanks for getting back to me with the records. I will let you know if there is anything else I need for my inspection. Thanks, Jordan [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Wed, Nov 6, 2024 at 11:35 AM To: john@ticaboouid.com Hey John, I received some feedback from my supervisor about my inspection and there is some additional information I need in order to complete my inspection. 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…3/11 Can you verify that the equipment listed on this AO is accurate and that there has been no new equipment added or any of the equipment listed removed from the site? I have attached the AO so you can see what equipment is listed on the AO. Can you send me pictures of the generators showing the power rating for each of the generators listed onsite as well as the year of manufacture? Can you also send me your most recent annual maintenance report for each generator as well as the standard operating procedures for how you are maintaining the generators? You also mentioned that you had generator issues at the facility. What sort of issues did the generators have? Thanks for your help. Please let me know if you have any questions about the information I am requesting. Thanks, Jordan [Quoted text hidden] Ticaboo AO 2015.pdf 78K john@ticaboouid.com <john@ticaboouid.com>Mon, Nov 11, 2024 at 3:16 PM To: Jordan Garahana <jordangarahana@utah.gov> Jordan, Apologies for the belated reply, as on the ground items have kept me busy on both properties I run. Here’s some comments, and questions and I can work on getting the rest of the information to you too: Comments and responses: Can you verify that the equipment listed on this AO is accurate and that there has been no new equipment added or any of the equipment listed removed from the site? I have attached the AO so you can see what equipment is listed on the AO. I’ve reviewed that document and verify that all of that is correct. Can you send me pictures of the generators showing the power rating for each of the generators listed onsite as well as the year of manufacture? Yes, I can get you those pictures this week. Can you also send me your most recent annual maintenance report for each generator as well as the standard operating procedures for how you are maintaining the generators? I don’t have any annual maintenance reports (I wasn’t aware we needed those) but do record maintenance on daily inspection logs I do on the machines. Between that recording and invoices for more involved repairs that’s how I keep up with it annually. I can extract that information if that is what you guys need, and I can also start keeping one yearly separately if that is something we need to do. Unfortunately with the management and board removal here, the operations just got handed over to me with missing information in most areas and no “how to” on any compliance or daily operations. There was also no SOP for maintenance, so I relied on my training for other items (water and waste water for example) and maintain the equipment based on manufacturers recommendations. Specifically for the generators, it’s oil, oil filter and fuel filter changes every 500 run hours, air filters 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…4/11 are every 5000 hours (or sooner if the indicators show they need it) and coolant is every 8000 hours for a drain, flush and refill unless a sample indicates otherwise when taken. You also mentioned that you had generator issues at the facility. What sort of issues did the generators have? Our issues center around one main item in the operation of the generators. One, is the communication of the software, which CAT technicians come and update and reprogram. Knock on wood there’s never been any actual engine or generator issues in my time so far, and it’s all been on the communication and programming end, and this year we had to rebuild an automatic breaker that ties the machine into the power switch and grid. Questions: Really, as stated about the annual report, of what we need to do now to get that to you, or if the generator logs will work or some example of? I do record fuel tank readings and fuel day tank meter readings on that sheet to, to do manual fuel calculations for use in addition to looking at what the ECM of the machine is telling me it’s consuming per hour. See attached pics of the generator inspections logs as an illustration of what I’m referring to on those. 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…5/11 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…6/11 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…7/11 [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Tue, Nov 12, 2024 at 2:45 PM To: Chad Gilgen <cgilgen@utah.gov> Response from Ticaboo about the generator maintenance. It looks like he is maintaining the generators per the manufacturer's specifications and is tracking maintenance daily. Does he need to have annual maintenance reports or are these daily reports sufficient? The generator issues also don't sound like something that is impacting performance or has the potential to negatively impact air quality. Seems like its a communication issue that is being addressed by CAT. Thanks, Jordan [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Thu, Nov 21, 2024 at 2:04 PM To: Jordan Garahana <jordangarahana@utah.gov> 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…8/11 Hi Jordan, Thanks for gathering this additional information. The source is required, per 40 CFR 60 Subpart IIII, to maintain and operate the engines in accordance with manufacturer's instructions. See https://www.ecfr.gov/current/title-40/section-60.4211 for more information. The easiest way for them to do this is to have the manufacturer come out annually to conduct that maintenance. Otherwise, it sounds like they may need to put together an SOP for this and be able to demonstrate they are meeting the Subpart requirements for future inspections. This is especially important for Engine 1 (II.A.2) as Subpart IIII requires stack testing of any non- emergency use engine greater than 500 HP if the engine is not being operated in accordance with those instructions. See https://www.ecfr.gov/current/title-40/part-60/subpart-IIII#p-60.4211(g)(3) for more information. I think, at this point, you could note compliance is not determined with Subpart IIII and reference the above as compliance assistance for the next inspection since the source contact is new and working to figure everything out. 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] Jordan Garahana <jordangarahana@utah.gov>Thu, Nov 21, 2024 at 3:03 PM To: john@ticaboouid.com Hey John, Sorry for the delayed response, I was waiting for more information from my manager about the questions you had. Since these generators are subject to a federal subpart, 40 CFR 60 Subpart IIII, the easiest way to be in compliance for maintaining and operating the generator according to manufacturer's specifications, would be to have the manufacturer come out annually and conduct maintenance. The manufacturer would then give you a report stating the maintenance was conducted and that is what would qualify as following the manufacturer's specifications. Otherwise, you would need to put together an SOP that would show that you are meeting the requirements of this Subpart in future inspections. This is important specifically for Engine 1 due to the size of the engine, as if you can't demonstrate it is being maintained to those standards, stack testing on that engine may be required. For more information, you can visit these links to the rules here: https://www.ecfr.gov/current/title-40/section-60.4211 https://www.ecfr.gov/current/title-40/part-60/subpart-IIII#p-60.4211(g)(3) Please let me know if you have any questions about my response. Thanks, Jordan [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Mon, Nov 25, 2024 at 4:11 PM To: john@ticaboouid.com Hey John, Did you happen to take the pictures of the equipment onsite? If so, can you send those to me? 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-13732772305894…9/11 Thanks, Jordan [Quoted text hidden] john@ticaboouid.com <john@ticaboouid.com>Tue, Nov 26, 2024 at 2:45 PM To: Jordan Garahana <jordangarahana@utah.gov> Jordan, See pics below with the exception of engine #4, the one that is used in the off season. It’s currently at a shop getting repairs and tune ups. I may have an old picture of the information on it, or can get it soon when I travel to Colorado to check on it. See attached pics of the 3 larger CAT generators attached below. Thanks for the explanation on the maintenance log. We do that now, minus a formal report from the manufacturer technicians (Wheeler CAT in our case) but they do give detailed invoices of what they did, that may work. I’ll look more and read more about it, but they do come out at least annually for ECU updates, testing and larger jobs that I can’t do alone such as a recent coolant flush and replacement we did on the 2 C9 machines. [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Tue, Nov 26, 2024 at 2:50 PM To: john@ticaboouid.com Hey John, Thanks for the information. An old pic of the generator will work. Sounds like Wheeler CAT takes care of the maintenance annually, just as long as you receive some sort of report on the machine from them, then you are compliant with the rule. Thanks, Jordan [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Mon, Dec 9, 2024 at 4:28 PM To: john@ticaboouid.com Hey John, Just checking in on my request for the last photo for generator #4. Please let me know as soon as possible about my request. Thanks, Jordan [Quoted text hidden] john@ticaboouid.com <john@ticaboouid.com>Tue, Dec 10, 2024 at 9:49 AM To: Jordan Garahana <jordangarahana@utah.gov> 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-1373277230589…10/11 Hi Jordan, Apologies, as I’ve been in Moab for waste water training. I’ll get that photo after this EPA webinar I have to attend this morning and send it over to you. [Quoted text hidden] john@ticaboouid.com <john@ticaboouid.com>Tue, Dec 10, 2024 at 11:35 AM To: Jordan Garahana <jordangarahana@utah.gov> Jordan, Here’s the MQ information. This is the “off season” machine that is run around 2-3 months out of the year as lower demands dictate. [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Tue, Dec 10, 2024 at 12:59 PM To: john@ticaboouid.com Hey John, Thanks for sending that over. I will let you know if there is anything else I need for my report. Thanks, Jordan [Quoted text hidden] 12/11/24, 11:42 AM State of Utah Mail - Records Request https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-2929372369119879511&simpl=msg-a:r-1373277230589…11/11