DAQ-2025-000013

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DAQC-1253-24
Site ID 12495 (B1)

MEMORANDUM

TO: FILE – UTAH MUNICIPAL POWER AGENCY (UMPA) – West Valley Power
Plant (WVPP)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: December 19, 2024

SUBJECT: FULL COMPLIANCE EVALUATION (FCE), Major, Salt Lake County,
FRS #UT0000004903500527
INSPECTION DATE: December 18, 2024

SOURCE LOCATION: 5935 West 4700 South, West Valley City, UT 84118

MAILING ADDRESS: Utah Municipal Power Agency
696 West 100 South
Spanish Fork, UT 84660

SOURCE CONTACTS: Jerame Blevins, Plant Manager: [phone] ext. 102

Stephen Rogers, O&M Manager: [phone] ext. 103

Chris Cook, O&M Technician: [phone] ext. 106

OPERATING STATUS: Turbine #3 was online and the remaining turbines were on standby at
time of the inspection.

PROCESS DESCRIPTION:

The peaker plant consists of five natural gas fueled simple cycle turbine generator sets (SCGT). These
generator sets have a combined nominal generating capacity of 217 MW at 43.4 MW each. Compressed air
and natural gas are injected into the combustion section of the turbine and are ignited. The resulting hot
combustion gasses pass through a power turbine, which drives a generator and the compressor section of the
combustion turbine. The turbine is connected to a shaft, which turns a magnet inside coils of wire. The
spinning magnet moves electrons in the wire, creating a stream of electricity. The power produced by the
SCTG system will be sold to the wholesale generation market. To control emissions, the five turbines are
equipped with a combination of water injection and selective catalytic reduction (SCR) for NOx and a CO
oxidation catalyst. Each turbine has a continuous monitoring system (CEM) that is used to monitor emissions
at all times.

APPLICABLE REGULATIONS: Title V Operating Permit (TVOP) # 3500527005, dated July 8, 2024,
and revised July 8, 2024.

40 CFR 60 Subpart GG-Standards of Performance for Stationary Gas
Turbines

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SOURCE EVALUATION:
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements." (R307-415-6b)

Status:

This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status:

This is a statement of fact and not an inspection item.
I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the
Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon
request, the permittee shall also furnish to the Director copies of records required to be kept
by this permit or, for information claimed to be confidential, the permittee may furnish such records directly to the EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under "Enforceable
Dates and Timelines" at the front of this permit. An application may be submitted early for
any reason. (R307-415-5a(1)(c))
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I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not relieve
the permittee of any enforcement actions resulting from submitting a late application.
(R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In Compliance – The permit expires July 8, 2029. Application for renewal is due
January 8, 2029.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's failure
to have an operating permit will not be a violation of R307-415, until the Director takes final
action on the permit renewal application. In such case, the terms and conditions of this permit
shall remain in force until permit renewal or denial. This protection shall cease to apply if,
subsequent to the completeness determination required pursuant to R307-415-7a(3), and as
required by R307-415-5a(2), the applicant fails to submit by the deadline specified in writing
by the Director any additional information identified as being needed to process the
application. (R307-415-7b(2))

Status: Application for permit renewal is due January 8, 2029.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In Compliance – The annual emission fee invoice, dated August 20, 2024, was paid on
September 3, 2024, before the due date of October 4, 2024.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
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permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related activity
is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution
control equipment), practice, or operation regulated or required under this permit.
(R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable time’s substances or parameters for the purpose of assuring
compliance with this permit or applicable requirements. (R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be
made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In Compliance – Required records were made available at time of the inspection. No
claims of confidentiality were made.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible official
as defined in R307-415-3. This certification shall state that, based on information and belief
formed after reasonable inquiry, the statements and information in the document are true,
accurate, and complete. (R307-415-5d)

Status: In Compliance – West Valley City Power is aware that reports and certifications are
required to have certification statements and are to be signed by the responsible
officials (RO). See status of condition I.L.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the certification;
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I.L.1.b The identification of the methods or other means used by the permittee for determining the
compliance status with each term and condition during the certification period. Such methods
and other means shall include, at a minimum, the monitoring and related recordkeeping and
reporting requirements in this permit. If necessary, the permittee also shall identify any other
material information that must be included in the certification to comply with section
113(c)(2) of the Act, which prohibits knowingly making a false certification or omitting
material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period covered
by the certification, including whether compliance during the period was continuous or
intermittent. The certification shall be based on the method or means designated in Provision
I.L.1.b. The certification shall identify each deviation and take it into account in the
compliance certification. The certification shall also identify as possible exceptions to
compliance any periods during which compliance is required and in which an excursion or
exceedance as defined under 40 CFR Part 64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In Compliance – The 2023 annual compliance certification (ACC) was received by the
UDAQ on April 1, 2024, and deemed acceptable. The 2024 ACC is due by April 1, 2025.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or
(R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in this
permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and
the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to or
at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section
408(a). (R307-415-6f(3)(c))
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I.M.2.d The ability of the Director to obtain information from the source under Utah Code Ann.
Section 19-2-120, and the ability of the EPA to obtain information from the source under the
CAA Section 114. (R307-415-6f(3)(d))

Status: Not Applicable – See Section III of this permit.

I.N Reserved

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: These are statements of fact and not inspection items. (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained by the
permittee for a period of at least five years from the date of the monitoring sample,
measurement, report, or application. Support information includes all calibration and
maintenance records, all original strip-charts or appropriate recordings for continuous
monitoring instrumentation, and copies of all reports required by this permit.
(R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall
record the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

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I.S.1.c

Additional record keeping requirements, if any, are described in Section II, Special
Provisions.
Status: In Compliance – Required records were provided, upon request, at time of the
inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently if
specified in Section II. All instances of deviation from permit requirements shall be clearly
identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official
in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements including
those attributable to upset conditions as defined in this permit, the probable cause of such
deviations, and any corrective actions or preventative measures taken. Prompt, as used in this
condition, shall be defined as written notification within the number of days shown under
"Enforceable Dates and Timelines" at the front of this permit. Deviations from permit
requirements due to breakdowns shall be reported in accordance with the provisions of
R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.
I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the Director are to be sent to the following address or to such other address as may be required by the Director: Utah Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84114-4820 Phone: [phone]
I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to the
EPA should be sent to one of the following addresses or to such other address as may be
required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Assistance Air and Program (mail code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]
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Status: In Compliance – Quarterly monitoring reports are submitted to the UDAQ CEM
Specialist. The latest quarterly monitoring report, for the 3rd quarter of 2024, was
received by the UDAQ on October 28, 2024. No deviations were noted in the report. See
attached quarterly monitoring report cover letter.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining
permit term of three or more years. No such reopening is required if the effective date of the
requirement is later than the date on which this permit is due to expire, unless the terms and
conditions of this permit have been extended pursuant to R307-415-7c(3), application shield.
(R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or
conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure
compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of this
permit and are in conflict with existing permit conditions. (R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In Compliance – The 2023 annual emission inventory was received by the UDAQ on
April 9, 2024. The 2024 annual emission inventory is due by April 15, 2025. See
Emission Inventory and SLEIS database.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both provisions
shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.

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SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Natural Gas Simple Cycle Turbine EU#1
Natural gas simple cycle turbine, output rate at 43.4 MW and maximum firing rate at
389,186 scf/hr, with water injection, evaporative spray mist inlet air cooling, NOx SCR
catalyst and CO oxidation catalyst.

II.A.3 Natural Gas Simple Cycle Turbine EU#2
Natural gas simple cycle turbine, output rate at 43.4 MW and maximum firing rate at
389,186 scf/hr, with water injection, evaporative spray mist inlet air cooling, NOx SCR
catalyst and CO oxidation catalyst.

II.A.4 Natural Gas Simple Cycle Turbine EU#3
Natural gas simple cycle turbine, output rate at 43.4 MW and maximum firing rate at
389,186 scf/hr, with water injection, evaporative spray mist inlet air cooling, NOx SCR
catalyst and CO oxidation catalyst.

II.A.5 Natural Gas Simple Cycle Turbine EU#4
Natural gas simple cycle turbine, output rate at 43.4 MW and maximum firing rate at
389,186 scf/hr, with water injection, evaporative spray mist inlet air cooling, NOx SCR
catalyst and CO oxidation catalyst.

II.A.6 Natural Gas Simple Cycle Turbine EU#5
Natural gas simple cycle turbine, output rate at 43.4 MW and maximum firing rate at
389,186 scf/hr, with water injection, evaporative spray mist inlet air cooling, NOx SCR
catalyst and CO oxidation catalyst.

II.A.7 Natural Gas Simple Cycle Turbine Group
Includes EUs #1 through #5.

Status: In Compliance – No unapproved equipment was noted at the time of this inspection.
The EPA Good Neighbor Policy is currently in a stay status.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the
permitted facility as indicated:

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to
the extent practicable, maintain and operate the affected emission unit, 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
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Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source.
[Origin: DAQE-282-02 & 40 CFR 60.11(d)]. [ 40 CFR 60 Subpart A, R307-401-8(2)]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and
maintenance. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In Compliance – Maintenance activities are documented through work orders and
records which are stored electronically in the E-Maintenance database and the logging
system. When Trans Canada Turbine (TCT) performs repairs or overhauls on the
turbines, electronic reports of the repairs or overhauls are provided.

II.B.1.b Condition:

The permittee shall comply with the applicable requirements for recycling and emission
reduction for class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling
and Emissions Reduction. [Origin: 40 CFR 82.150(b)]. [40 CFR 82 Subpart F]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In Compliance – The most recent annual compliance certification indicated that the
West Valley plant complies with 40 CFR 82, Subpart F. Air conditioner maintenance is
completed by CCI technicians. CCI provides maintenance records to the plant
manager. Two A/C units were replaced in the spring of 2024. See page 4 of the 2023
annual compliance certification and status of condition I.L.

II.B.2 Conditions on Natural Gas Simple Cycle Turbine Group

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II.B.2.a Condition:
Visible emissions shall be no greater than 10 percent opacity from each affected unit. [AO
DAQE-282-02]. [R307-401-8]

II.B.2.a.1 Monitoring:

In lieu of opacity monitoring, the report required for this permit condition will serve as
monitoring.

II.B.2.a.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described
in Provision I.S.1 of the permit

II.B.2.a.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee
should certified each annual certification report that only pipeline quality natural gas is used
as fuel during the reporting year.

Status: In Compliance – Natural gas is the only fuel burned in the turbines. The most recent
annual compliance certification indicated that the West Valley plant has used only
pipeline quality natural gas, from Kern River Gas, in the last year. See page 4 and 5 of
the 2023 annual compliance certification and status of condition I.L.

II.B.2.b Condition:

Sulfur content of any fuel burned shall be no greater than 0.8 percent by weight (8000
ppmw) from each affected unit. [40 CFR 60.333(b)]. [40 CFR 60 Subpart GG]

II.B.2.b.1 Monitoring:

In lieu of monitoring the total sulfur content of gaseous fuel combusted in the turbines, the
permittee should use one of the following sources of information to demonstrate that the
gaseous fuel meets the definition of natural gas in 40 CFR 60.331(u):

(a) The gas quality characteristics in a current, valid purchase contract, tariff sheet or
transportation contract for the gaseous fuel, specifying that the maximum total sulfur content
of the fuel is 20.0 grains/100 scf or less; or

(b) Representative fuel sampling data which show that the sulfur content of the gaseous fuel
does not exceed 20 grains/100 scf. At a minimum, the amount of fuel sampling data
specified in section 2.3.1.4 or 2.3.2.4 of appendix D to 40 CFR Part 75 is required.

II.B.2.b.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit.

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II.B.2.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In Compliance – The West Valley plant manager receives a monthly gas quality report
from Kern River Gas. These reports provide daily sulfur content of the natural gas
used by the power plant. The most recent report, dated November 2024, indicated that
only natural gas with a sulfur content of < 1 grains/100 scf has been received, by the
plant for the month of November. The report for December will be received by the end
of December.

II.B.2.c Condition:

Emissions of CO from each individual turbine shall be no greater than 10 ppmdv (15% O2,
dry) based on 30-day rolling average under steady state operation (not including startup and
shutdown). [AO DAQE-282-02]. [R307-401-8]

II.B.2.c.1 Monitoring:

(a)The emission of CO shall be monitored by continuous emission monitoring system
(CEMS) consisting of CO and O2 monitors. The O2 monitor shall be used to adjust the
measured CO concentrations to 15% O2.

(b) Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) of 40 CFR 60.13, the permittee shall continuously operate all
required continuous monitoring systems and shall meet the minimum frequency of operation
requirements as outlined in R307-170 and 40 CFR 60.13.

(c) The monitoring system shall comply with all applicable sections of R307-170, 40 CFR
60.13, and 40 CFR 60, Appendix B - Performance Specification 4A.

(d) The daily average of CO emissions shall be calculated once for each day and the 30-day
rolling average shall be calculated by adding previous 30 days data on a daily basis.

II.B.2.c.2 Recordkeeping:

Results of CO monitoring shall be recorded and maintained as required in R307-170, 40
CFR 60.13, and as described in Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9, 40 CFR 60.13, and
all the reporting provisions contained in Section I of this permit. The quarterly reports
required in R307-170-9 is considered prompt notification of permit deviations required in
Provision I.S.2.c of this permit if all information required by Provision I.S.2.c is included in
the report.

Status: In Compliance – A CO CEM has been installed and operated for each of the five
turbines. Detailed quarterly monitoring reports are submitted to and evaluated by the
UDAQ CEM specialist. See status of condition I.S.2.a and memorandums in the source
files.

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II.B.2.d Condition:

Total emissions of CO from all five turbines shall be no greater than 43.75 lbs/hour (15%
O2, dry) based on 30-day rolling average under steady state operation (not including startup
and shutdown). [AO DAQE-282-02]. [R307-401-8]

II.B.2.d.1 Monitoring:

The emission rate (lb/hr) shall be calculated from the ppmvd CEMs recorded data
using 40 CFR 60 Appendix A, Method 19. The volumetric flow rate shall be
determined by 40 CFR 60 Appendix A, Method 2 or Method 19. The daily average
of CO emission (lb/hr) shall be calculated for each turbine and the daily totals of CO
emissions from five turbines shall be calculated by adding data from five turbines
once for each day. 30-day rolling average shall be calculated by adding previous 30
days data on a daily basis.

II.B.2.d.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In Compliance – A CO CEM has been installed and operated for each of the five
turbines. Detailed quarterly monitoring reports are submitted to and evaluated by the
UDAQ CEM specialist. See status of condition I.S.2.a and memorandums in the source
files.

II.B.2.e Condition:

Emission of NOx from each individual turbine shall be no greater than 5 ppmdv (15% O2,
dry) based on 30 day rolling average under steady state operation (not including startup and
shutdown) and shall be no greater than the NSPS limit of 100 ppmdv (15% O2, dry). [AO
DAQE-282-02, 40 CFR 60.332, Utah SIP Section IX.H.2.m and Utah SIP Section
IX.H.12.o]. [40 CFR 60 Subpart GG, R307-110-17, R307-401-8]

II.B.2.e.1 Monitoring:

(a) The permittee shall install, certify, maintain, operate, and quality-assure a continuous
emission monitoring system (CEMS) consisting of NOx and O2 monitors to determine
compliance with the applicable NOx limitations. Except for system breakdown, repairs,
calibration checks, and zero and span adjustments required under paragraph (d)of 40 CFR
60.13, the permittee shall continuously operate all required continuous monitoring systems
and shall meet the minimum frequency of operation requirements as outlined in R307-170
and 40 CFR 60.13. The CEMS shall be installed, certified, maintained and operated as
follows:

(1) Each CEMS must be installed and certified according to PS 2 and 3 (for diluent) of 40
CFR part 60, appendix B, except the 7-day calibration drift is based on unit operating days,
not calendar days. Appendix F, Procedure 1 is not required. The relative accuracy test audit
(RATA) of the NOx and diluent monitors may be performed individually or on a combined
14
basis, i.e., the relative accuracy tests of the CEMS may be performed either:

(i) On a ppm basis (for NOx) and a percent O2 basis for oxygen; or

(ii) On a ppm at 15 percent O2 basis.

(2) As specified in 40 CFR 60.13(e)(2), during each full unit operating hour, each monitor
must complete a minimum of one cycle of operation (sampling, analyzing, and data
recording) for each 15-minute quadrant of the hour, to validate the hour. For partial unit
operating hours, at least one valid data point must be obtained for each quadrant of the hour
in which the unit operates. For unit operating hours in which required quality assurance and
maintenance activities are performed on the CEMS, a minimum of two valid data points
(one in each of two quadrants) are required to validate the hour.

(3) For purposes of identifying excess emissions, CEMS data must be reduced to hourly
averages as specified in 40 CFR 60.13(h).

(i) For each unit operating hour in which a valid hourly average, as described in paragraph
(a)(2) of this section, is obtained for both NOx and diluent, the data acquisition and handling
system must calculate and record the hourly NOx emissions in the units of percent NOx by
volume, dry basis, corrected to 15 percent O2 and International Organization for
Standardization (ISO) standard conditions (if required as given in 40 CFR 60.335(b)(1)). For
any hour in which the hourly average O2 concentration exceeds 19.0 percent O2, a diluent
cap value of 19.0 percent O2 may be used in the emission calculations.

(ii) A worst case ISO correction factor may be calculated and applied using historical
ambient data. For the purpose of this calculation, substitute the maximum humidity of
ambient air (Ho), minimum ambient temperature (Ta), and minimum combustor inlet
absolute pressure (Po) into the ISO correction equation.

(iii) If the permittee has installed a NOx CEMS to meet the requirements of 40 CFR Part 75,
and is continuing to meet the ongoing requirements of 40 CFR Part 75, the CEMS may be
used to meet the requirements of this section, except that the missing data substitution
methodology provided for at 40 CFR Part 75, subpart D, is not required for purposes of
identifying excess emissions. Instead, periods of missing CEMS data are to be reported as
monitor downtime in the excess emissions and monitoring performance report required in
Sec. 60.7(c).

(b) Each continuous emission monitoring system shall meet the Specifications and Test
Procedures required by 40 CFR Part 75, Appendix A.

(c) The permittee shall implement Quality Assurance and Quality Control Procedures
required by 40 CFR Part 75, Appendix B.

(d) The quality assurance requirements of R307-170, Continuous Emission Monitoring
Systems Program, shall be used in addition to 40 CFR Part 75 procedures to fulfill data
quality assurance requirements.

(e) The daily average of NOx emissions shall be calculated every day and the 30-day rolling
average shall be calculated by adding previous 30 days data on a daily basis.

II.B.2.e.2 Recordkeeping:

15
Results of NOx monitoring shall be recorded and maintained as required in R307-170, 40
CFR 60 subpart GG, 40 CFR 75 subpart F, and as described in Provision I.S.1 of this permit.

II.B.2.e.3 Reporting:

(a) The permittee shall comply with the reporting provisions in R307-170-9, 40 CFR 75
Subpart G, 40 CFR Subpart GG and all the reporting provisions contained in Section I of
this permit.

(b) The permittee shall submit reports of excess emissions and monitor downtime, in
accordance with 40 CFR 60.7(c). Excess emissions shall be reported for all periods of unit
operation, including startup, shutdown and malfunction. For the purpose of reports required
under 40 CFR 60.7(c), periods of excess emissions and monitor downtime that shall be
reported are defined as follows:

(1) An hour of excess emissions shall be any unit operating hour in which the 4-hour rolling
average NOx concentration exceeds applicable NSPS emission standard of 100 ppmdv (15%
O2, dry). A ``4-hour rolling average NOx concentration'' is the arithmetic average of the
average NOx concentration measured by the CEMS for a given hour (corrected to 15 percent
O2 and, if required under 40 CFR 60.335(b)(1), to ISO standard conditions) and the three
unit operating hour average NOx concentrations immediately preceding that unit operating
hour.

(2) A period of monitor downtime shall be any unit operating hour in which sufficient data
are not obtained to validate the hour, for either NOx concentration or diluent (or both).

(3) Each report shall include the ambient conditions (temperature, pressure, and humidity) at
the time of the excess emission period. The ambient conditions is not required if the
permittee opt to use the worst case ISO correction factor as specified in 40 CFR
60.334(b)(3)(ii).

(4) All reports of excess emissions and monitor downtime shall be postmarked by the 30th
day following the end of each calendar quarter.

(c) The quarterly reports required in R307-170-9 and 40 CFR 75 Subpart G are considered
prompt notification of permit deviations required in Provision I.S.2.c of this permit if all
information required by Provision I.S.2.c is included in the report

Status: In Compliance – A NOx CEM has been installed and operated for each of the five
turbines. Detailed quarterly monitoring reports are submitted to and evaluated by the
UDAQ CEM specialist. See status of condition I.S.2.a and memorandums in the source
files.

II.B.2.f Condition:

Total emissions of NOx from all five turbines shall be no greater than 37 lbs/hour (15% O2,
dry) based on 30 day rolling average under steady state operation (not including startup and
shutdown). [AO DAQE-282-02]. [R307-401-8]

II.B.2.f.1 Monitoring:

The NOx emission rate (lb/hr) shall be calculated from the ppmvd CEMs recorded data
using 40 CPR 60 Appendix A, Method 19. The volumetric flow rate shall be
16
determined by 40 CPR 60 Appendix A, Method 2 or Method 19. The daily average of
NOx emission rate (lb/hr) shall be calculated for each turbine and the daily total
emissions shall be calculated by adding data from five turbines once for each day. 30-
day rolling average shall be calculated by adding previous 30 days data on a daily basis.

II.B.2.f.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status:

In Compliance – A NOx CEM has been installed and operated for each of the five
turbines. Detailed quarterly monitoring reports are submitted to and evaluated by the
UDAQ CEM specialist. See status of condition I.S.2.a and memorandums in the source
files.

II.B.2.g Condition:

Total emissions of NOx from all five turbines combined shall be no greater than 1050
lbs/day (15% O2, dry). A "day" is defined as a period of 24-hours commencing at midnight
and ending at the following midnight. Total emission shall include the sum of all periods in
the day including startup, shutdown and maintenance. [Utah SIP Section IX.H.2.m and Utah
SIP Section IX.H.2.o ]. [R307-110-17]

II.B.2.g.1

Monitoring:

The NOx emission rate (lb/day) shall be calculated from the ppmvd CEMs recorded data
using 40 CFR 60 Appendix A, Method 19. The volumetric flow rate shall be
determined by 40 CFR 60 Appendix A, Method 2 or Method 19.

The daily NOx emission rate (lb/day) shall be calculated for each turbine and the daily
total emissions shall be calculated by adding data from five turbines once for each day.

II.B.2.g.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In Compliance – The daily NOx emissions totals are tracked, in real time, on an excel
spreadsheet. An audible and visual alarm has been put in place to alert the control
room of any exceedance of the above permitted limit. The real time values also light up
if exceedances occur. The control room can make adjustments to stay within limits.
The spreadsheet was reviewed, for NOx emission exceedances, at time of the
inspection.

17
Emissions Trading
(R307-415-6a(10))

Not Applicable to this source.

Alternative Operating Scenarios
(R307-415-6a(9))

Not Applicable to this source.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

IV.A Utah Acid Rain Program Authority

Authority to implement the Acid Rain Program is contained in R307-417, Permits: Acid
Rain Sources, and R307-415-6a(4), standard permit requirements [for operating permits].

IV.B Permit Requirements.

IV.B.1 The designated representative of the source and each affected unit at the source shall:

IV.B.1.a

Submit a complete Acid Rain permit application (including a compliance plan) under
R307-417 and 40 CFR Part 72 in accordance with the deadlines specified in 40 CFR 72.30;
and

IV.B.1.b Submit in a timely manner any supplemental information that the Director determines is
necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain
permit;

IV.B.2 The owners and operators shall:

IV.B.2.a Operate each affected unit at the source in compliance with a complete Acid Rain permit
application or a superseding Acid Rain permit issued by the Director; and

IV.B.2.b

Have an Acid Rain Permit.
IV.C Sulfur Dioxide Requirements.

IV.C.1 The owners and operators of each affected unit at the source shall:
IV.C.1.a Hold allowances, as of the allowance transfer deadline, in the unit's compliance subaccount (after deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide for the previous calendar year from the unit; and
IV.C.1.b

Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.
IV.C.2 Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for
sulfur dioxide shall constitute a separate violation of the Act.
18
IV.C.3 An affected unit shall be subject to the requirements under Provision IV.C.1. of the sulfur
dioxide requirements as follows:

IV.C.3.a Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or

IV.C.3.b Starting on later of January 1, 2000 or the deadline for monitor certification under 40 CFR
Part 75, an affected unit under 40 CFR 72.6(a)(3).

IV.C.4 Allowances shall be held in, deducted from, or transferred among Allowance Tracking
System accounts in accordance with the Acid Rain Program.

IV.C.5 An allowance shall not be deducted in order to comply with the requirements under
Provision IV.C.1.a. of the sulfur dioxide requirements prior to the calendar year for which
the allowance was allocated.

IV.C.6 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program is a
limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No
provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit,
or the written exemption under 40 CFR 72.7 and 72.8 and no provision of law shall be
construed to limit the authority of the United States to terminate or limit such authorization.

IV.C.7 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program does
not constitute a property right.

IV.D Nitrogen Oxides Requirements.

The owner and operators of the source and each affected unit at the source shall comply with
the applicable Acid Rain emissions limitations of nitrogen oxide.

IV.E Monitoring Requirements.

IV.E.1 The owners and operators and, to the extent applicable, designated representative of each
affected unit at the source shall comply with the monitoring requirements as provided in 40
CFR Parts 74, 75, and 76.

IV.E.2 The emissions measurements recorded and reported in accordance with 40 CFR Part 75
shall be used to determine compliance by the unit with the Acid Rain emissions limitations
and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid
Rain Program.

IV.E.3 The requirements of 40 CFR Parts 74 and 75 shall not affect the responsibility of the owners
and operators to monitor emissions of other pollutants or other emissions characteristics at
the unit under other applicable requirements of the Act and other provisions of the operating
permit for the source.

IV.F Recordkeeping and Reporting Requirements.

IV.F.1 Unless otherwise provided, the owners and operators for each affected unit at the source
shall keep on site at the source each of the following documents for a period of 5 years from
the date the document is created. This period may be extended for cause, at any time prior to
the end of 5 years, in writing by the Administrator, USEPA, or Director:

19
IV.F.1.a The certificate of representation for the designated representative for the source and each
affected unit at the source and all documents that demonstrate the truth of the statements in
the certificate of representation, in accordance with 40 CFR 72.24; provided that the
certificate and documents shall be retained on site at the source beyond such 5-year period
until such documents are superseded because of the submission of a new certificate of
representation changing the designated representative;

IV.F.1.b All emissions monitoring information, in accordance with 40 CFR Part 75;

IV.F.1.c

Copies of all reports, compliance certifications, and other submissions and all records made
or required under the Acid Rain Program; and,

IV.F.1.d

Copies of all documents used to complete an Acid Rain permit application and any other
submission under the Acid Rain Program or to demonstrate compliance with the
requirements of the Acid Rain Program.

IV.F.2 The designated representative of each affected unit at the source shall submit the reports and
compliance certifications required under the Acid Rain Program, including those under 40
CFR Part 72 Subpart I and 40 CFR Part 75.

IV.G Excess Emissions Requirements.

IV.G.1 The designated representative of an affected unit that has excess emissions in any calendar
year shall submit a proposed offset plan to the Administrator, USEPA, as required under 40
CFR Part 77.

IV.G.2 The owners and operators of an affected unit that has excess emissions in any calendar year
shall:

IV.G.2.a Pay without demand the penalty required, and pay upon demand the interest on that penalty,
to the Administrator, USEPA, as required by 40 CFR Part 77; and

IV.G.2.b Comply with the terms of an approved offset plan, as required by 40 CFR Part 77.

IV.H Liability.

IV.H.1 Any person who knowingly violates any requirement or prohibition of the Acid Rain
Program, a complete Acid Rain permit application, an Acid Rain permit, or a written
exemption under R307-417, 40 CFR 72.7 or 40 CFR 72.8, including any requirement for the
payment of any penalty owed to the United States, shall be subject to enforcement pursuant
to section 113(c) of the Act.

IV.H.2 Any person who knowingly makes a false, material statement in any record, submission, or
report under the Acid Rain Program shall be subject to criminal enforcement pursuant to
section 113(c) of the Act and 18 U.S.C. 1001.

IV.H.3 No permit revision shall excuse any violation of the requirements of the Acid Rain Program
that occurs prior to the date that the revision takes effect.

IV.H.4 Each affected source and each affected unit shall meet the requirements of the Acid Rain
Program.

20
IV.H.5 Any provision of the Acid Rain Program that applies to an affected source (including a
provision applicable to the designated representative of an affected source) shall also apply
to the owners and operators of such source and of the affected units at the source.

IV.H.6 Any provision of the Acid Rain Program that applies to an affected unit (including a
provision applicable to the designated representative of an affected unit) shall also apply to
the owners and operators of such unit. Except as provided under 40 CFR 72.44 (Phase II
repowering extension plans) and 40 CFR 76.11 (NOx averaging plans), and except with
regard to the requirements applicable to units with a common stack under 40 CFR part 75
(including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated
representative of one affected unit shall not be liable for any violation by any other affected
unit of which they are not owners or operators or the designated representative and that is
located at a source of which they are not the owners and operators, owners or operators, or
the designated representative.

IV.H.7 Each violation of a provision of 40 CFR Parts 72, 73, 74, 75, 76, 77, and 78 by an affected
source or affected unit, or by an owner or operator or designated representative of such
source or unit, shall be a separate violation of the Act.

IV.H.8 The owners and operators of a unit governed by an approved early election plan shall be
liable for any violation of the plan or 40 CFR 76.8 at that unit. The owners and operators
shall be liable, beginning January 1, 2000, for fulfilling the obligations specified in 40 CFR
Part 77.

IV.I Effect on Other Authorities.

No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain
permit, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as:

IV.I.1 Except as expressly provided in Title IV of the Act, exempting or excluding the owners and
operators and, to the extent applicable, the designated representative from compliance with
any other provision of the Act, including the provisions of Title I of the Act relating to
applicable National Ambient Air Quality Standards or the Utah State Implementation Plan;

IV.I.2 Limiting the number of allowances a unit can hold; provided, that the number of allowances
held by the unit shall not affect the source's obligation to comply with any other provisions
of the Act;

IV.I.3 Requiring a change of any kind in any State law regulating electric utility rates and charges,
affecting any State law regarding such State regulation, or limiting such State regulation,
including any prudence review requirements under such State law;

IV.I.4 Modifying the Federal Power Act or affecting the authority of the Federal Energy
Regulatory Commission under the Federal Power Act; or,

IV.I.5 Interfering with or impairing any program for competitive bidding for power supply in a
State in which such program is established.

Status: The West Valley Power Plant must hold allowances under the Acid Rain Program.
Compliance with this provision is determined by EPA. The facility uses natural gas
that is very low in sulfur content. The Acid Rain CEM program is reviewed by the
UDAQ CEM specialist and EPA.

21
EMISSION INVENTORY: The 2023 Annual Emissions Inventory was submitted, to the DAQ, on
April 9, 2024.

PREVIOUS ENFORCEMENT
ACTIONS:

None within the last five years.

COMPLIANCE STATUS &
RECOMMENDATIONS:

In Compliance with the conditions of the Title V Operating Permit
3500527005, dated July 8, 2024, and revised July 8, 2024, at time of the
inspection.

COMPLIANCE ASSISTANCE: Discussed providing inspector with Quarterly Monitoring report cover
letters.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR NEXT
INSPECTION:

Inquire about the EPA Good Neighbor Policy. Inspect as usual.
ATTACHMENTS: VEO Form
Correspondence
Latest Quarterly Monitoring Report Cover Letter

Joe Rockwell <[e-mail]>
Quarterly Monitoring Reports
2 messages
Chris Cook <[e-mail]>Wed, Dec 18, 2024 at 12:51 PM
To: "[e-mail]" <[e-mail]>
Joe,

Attached are the Quarterly Monitoring Reports for quarters 1, 2, and 3 of 2024. I will send you quarter 4’s report next
month.

Thanks,

Chris Cook
O&M Technician
Utah Municipal Power Agency
5935 W 4700 S, West Valley City, UT 84118
Office: 801 967 1200 ext 106
[e-mail]

NOTE: This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the
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disclosure, reproduction, distribution or other use including taking any action in reliance on the contents of this email transmission or any attachments by an individual orentity other than the intended recipient is prohibited.
12/18/24, 3:33 PM State of Utah Mail - Quarterly Monitoring Reports
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3 attachments
POD 04292024.pdf
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Joe Rockwell <[e-mail]>Wed, Dec 18, 2024 at 3:29 PM
To: Chris Cook <[e-mail]>
Thanks Chris, for helping me out.
Have A Merry Christmas.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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12/18/24, 3:33 PM State of Utah Mail - Quarterly Monitoring Reports
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