DAQ-2024-006982

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

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-252-24
Site ID 10096 (B5)

Edward McCourt, Agent
Sunnyside Cogeneration Associates
P.O. Box 159
Sunnyside, UT 84539

Dear Mr. McCourt:

Re: Sunnyside Cogeneration Associates (Sunnyside) – Pretest Protocol for Carbon Dioxide (CO2), Flow,
Nitrogen Oxides (NOx), Oxygen (O2), Sulfur Dioxide (SO2), Relative Accuracy Test – also Carbon
Monoxide (CO) – Carbon County

The Utah Division of Air Quality (DAQ) reviewed Sunnyside’s pretest protocol dated February 16, 2024. The
proposed test shall be performed under the following conditions:

Sunnyside’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Unit 1
NOx EcoChem MC3 425
O2 EcoChem MC3 425
SO2 EcoChem MC3 425

Montrose Air Quality Services will conduct a relative accuracy/performance specification test on Sunnyside’s
continuous monitoring system and an emission rate compliance demonstration.

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

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
May 21, 2024 Unit 1
CO Method 10 and 19
Flow Method 1, 2, 3A, 4
CO2 and O2 Method 3A
NOx Method 7E and 19
SO2 Method 6C and 19
/ % Ú Þ Û Ù Û Ý
DAQC-252-24
Page 2

• Reference Method 1 - Sample and Velocity Traverses for Stationary Point.

• Reference Method 2 - Determination of Stack Gas Velocity and Volumetric Flow Rate – (Type S
Pitot Tube) as outlined in 40 CFR 60 Appendix A.

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

• Reference Method 4 - Determination of Moisture Content in Stack Gases as outlined in 40 CFR 60
Appendix A shall be used to determine the stack gas moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide Emissions from Stationary Point Sources
- (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

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

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

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

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

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

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

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

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

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

DAQC-252-24
Page 3

Relative accuracy test reports must contain:

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

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

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

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

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

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

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

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

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

HB:RL: jl

cc: Southeast Utah Health Department
Montrose Air Quality Services
* $ . # ( ) - — - @ C v A ? A C @ D w ? F ˜
Rob Leishman Jr