DAQ-2025-000746

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DAQC-122-25
Site ID 10348 (B1)

MEMORANDUM

TO: FILE – MURRAY CITY POWER (MCP) – Department – Electrical Generation
Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Haynes, Environmental Scientist

DATE: February 05, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, SM80, FRS# UT0000004903500044, Salt
Lake County
INSPECTION DATE: January 30, 2025

SOURCE LOCATION: 153 West 4800 South, Murray, UT 84107

MAILING ADDRESS: 153 West 4800 South, Murray, UT 84107

SOURCE CONTACTS: Matt Youngs – Assistant Power Director:
Office: 801-264-2748 email: [e-mail]

Chris Niemann – Engineering Manager:
Office: 801-264-2717 email: [e-mail]

OPERATING STATUS: Not Operating (On Standby)

PROCESS DESCRIPTION: Murray City Power Plant is a peaker plant. The annual power
production varies upon the demand for peaking, emergency, and
stand-by needs. MCP has three gas turbine generating stations
with low NOx burners. Each has a peak power generating
capacity of 14.3 MW and runs on natural gas. The turbines
required a "new unit exemption" from the Title IV - Acid Rain
Program. MCP also has a 1,000 bhp black start generator that
burns fuel oil and is used for emergency plant startup during
power outages. There are also two propane-fired emergency
generators for the offices. Produced power is supplied to Murray
City or sold to the grid.

APPLICABLE REGULATIONS: AO DAQE-AN103480007-17, dated May 23, 2017

40 CFR Part 60 Subpart GG: Standards of Performance for
Stationary Gas Turbines
40 CFR Part 63 Subpart ZZZZ: National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines
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SOURCE EVALUATION:

Section I: GENERAL PROVISIONS
I.1

All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
Status: This is a statement of fact and not an inspection item. I.2

The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
Status: In compliance – No limitations were noted to be exceeded, at time of inspection. I.3

Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In compliance – No modifications to the equipment or processes were noted at time of the inspection. I.4

All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: In compliance – Records were provided upon request during inspection. Corrected values of turbine hours were received in a phone call on February 03, 2025. See status for condition II.B.1.c.1. 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 Approval Order including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In compliance – Maintenance of the three natural gas turbines is conducted on a regular basis, performed by Wheeler Power Systems. Maintenance records were seen on computers while on site. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In compliance – There have been no breakdowns since the last inspection, which was conducted on December 08, 2022. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In compliance – The 2023 annual emission inventory was submitted on April 11, 2024. See emission inventory below. The 2024 annual emission inventory will be submitted by April 15, 2025.
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Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Murray City Power Plant

Gas turbine generating station
II.A.2 Unit 1 (Model 130-18001S)
Solar-Titan natural gas-fired combustion turbine, equipped with dry controls-low NOx
combustor technology (SoLoNOx)
II.A.3 Unit 2 (Model 130-19501S)

Solar-Titan natural gas-fired combustion turbine, equipped with dry controls-low NOx
combustor technology (SoLoNOx)

II.A.4 Unit 3 (Model 130-19501S)

Solar-Titan natural gas-fired combustion turbine, equipped with dry controls-low NOx
combustor technology (SoLoNOx)

II.A.5 Black Start Generator

1000 bhp, diesel-fired generator

Status: In compliance – No unapproved equipment was noted at the time of this inspection.

II.B Requirements and Limitations

II.B.1 Conditions on Permitted Source

II.B.1.a Visible emissions from the following emission points shall not exceed the following values:

1. All natural gas turbines exhausts - 10% opacity

2. Black Start Generator - 20% opacity

Opacity observations of emissions from stationary sources shall be conducted in accordance
with 40 CFR 60, Appendix A, Method 9. [R307-401-8(1)(a)]

Status:

In compliance – Records indicated that no visible emissions were observed during
turbine and black start generator operations. The natural gas turbines do not emit
emissions unless there is a maintenance problem. The turbines are maintained on a
regular basis. See status of condition I.5.

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II.B.1.b MCPD shall use only pipeline quality natural gas as fuel in the turbines. Diesel fuel not exceeding 0.0015% sulfur (15 ppm) shall be used as fuel in the Black Start Generator.

Sulfur content shall be determined by ASTM Method D2880-71 or D-4294-89, or by EPA-approved equivalent. The percent by weight of sulfur contained in the fuel can be obtained
from the fuel oil certification. Certification of fuels shall be either by MCPD's own testing or
test reports from the fuel supplier. Records of the fuel supplier's test report on sulfur content shall be available on-site for each load delivered. [R307-401-8(1)(a)]

Status: In compliance – According to a British Petroleum (BP) invoice, dated October 14, 2024, only pipeline quality natural gas is used to fuel the turbines. According to a Rhinehart
Oil invoice, dated November 18, 2016, ultra-low sulfur (ULS) #2 diesel has been delivered
to the plant for the black start generator. The source stated that as of January 2025, a routine maintenance plan will be enacted to run the generator for 15 minutes each
month.

II.B.1.c Combined plant-wide NOx and CO emissions shall not exceed the following:

Pollutant Tons/rolling 12-month period
NOx 63
CO 95

[R307-401-3]

Status: In compliance – NOx and CO data are maintained in Microsoft Excel. Combined plant
wide NOX and CO emissions for the 12-month period of January through December
2024, are summarized below:

Pollutant Limit (Tons) Actual Emissions (Tons)
NOx 63 10.54
CO 95 11.36

II.B.1.c.1

For demonstrating compliance with the above NOx and CO emission limits, the actual
emissions from the plant shall be determined by no later than the 20th day of the following
month as outlined below:

A. Emissions from the Black Start Generator shall be calculated using the following
equations:

NOx (tons/month) = (hrs of operation/month) * (0.024 lb NOx/hp-hr) * (1000 hp-ton/2000 lbs)
CO (tons/month) = (hrs of operation/month) * (0.0059 lb CO/hp-hr) * (1000 hp-ton/2000 lbs)

B. Emissions from each Turbine shall be calculated as follows:

NOx (tons/month) = (MW-hrs/month) * (X lbs/MW-hr) * (1 ton/2000 lb)
CO (tons/month) = (MW-hrs/month) * (Y lbs/MW-hr) * (1 ton/2000 lb)

Unless adjusted by performance testing, the default emission factors to be used are as follows:

X = 0.543
Y = 0.585

The default emission factors apply until such time as stack testing is conducted. A stack test
for NOx and CO emissions shall be performed every 3,000 operating hours per turbine, but no
less frequently than once every 5 years. At that time a new emission factor in terms of
lbs/MW-hr shall be derived for each pollutant listed above. MCPD is not required to stack test
more frequently than once per year per turbine.

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c) Emission totals for each month from the 3 natural gas turbines and the black start generator shall be added to the totals from the previous 11 months to generate a new
rolling 12-month total.
[R307-165]

Status: Out of compliance – The source stated that they had a different interpretation of the condition. It was thought the 3,000 hour limit for each turbine would be combined to give
a total of 9,000 running hours, instead of a 3,000 hour limit for each unit. According to a
phone call on February 03, 2025, the updated run times since the last stack test (conducted in August 2021) showed that Turbine #1 had operated for 3,785.08 hours,
Turbine #2 for 2,624.22 hours, and Turbine #3 for 1,165.25 hours. The attached VEO
form specifies turbine hours that were recorded during the on-site inspection, but the phone conversation provided an update to these numbers, which are still out of
compliance for Turbine #1. The source stated that turbines are not currently operating
and are not expected to run until after testing (third week of July 2025). A new stack test
is required. See attached correspondence and status of condition II.B.1.d.

II.B.1.d

For all stack testing the following shall apply:

A. Sample Location:

The emission point shall be designed to conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved methods acceptable to the Director.

B. Volumetric Flow Rate:

40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods
acceptable to the Director.

C. CO:

40 CFR 60, Appendix A, Method 10 or other EPA-approved testing methods
acceptable to the Director.

D. NOx:

40 CFR 60 Appendix A, Method 7E or other EPA-approved testing methods
acceptable to the Director.

E. Calculations:

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric
flow rate and any necessary conversion factors to give the results in the specified units
of the emission limitation.

F. A stack test protocol shall be provided at least 30 days prior to the test. A pretest
conference shall be held if directed by the Director.

G. The emission point shall be designed to conform to the requirements of 40 CFR 60,
Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA)
approvable access shall be provided to the test location.

H. The production rate during all compliance testing shall be no less than 90% of the
maximum production rate achieved in the previous 3 years. If the desired production
rate is not achieved at the time of the test, the maximum production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production rate.
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This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. The owner/operator shall request a higher production rate when
necessary. Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum allowable production
rate is achieved.
[R307-165]

Status: In compliance – The last stack test was conducted on August 23 and 24, 2021. A review of the source file (DAQC -1301-21) indicates that the source met all the requirements of this
condition. See stack test results:

Unit Test Date Pollutant DAQ Results Test Results 1 8/24/2021 CO 5.0 lbs/hr 5.0 lbs/hr
2 8/23/2021 CO 0.43 lbs/hr 0.43 lbs/hr
3 8/24/2021 CO 0.16 lbs/hr 0.16 lbs/hr
1 8/24/2021 NOx 3.6 lbs/hr 3.6 lbs/hr
2 8/23/2021 NOx 2.2 lbs/hr 2.2 lbs/hr
3 8/24/2021 NOx 5.4 lbs/hr 5.3 lbs/hr

II.B.2 Conditions on Black Start Generator

II.B.2.a The Black Start Generator shall be used for the gas turbine(s) startups operation only during
those periods when electric power from the public utilities is interrupted, or for regular
maintenance of the generator. Records documenting generator usage shall be kept in a log and
these records shall show the date the generator was used, the duration in hours of the generator
usage, and the reason for each usage. [R307-401-8(1)(a)]

Status:

In compliance – The black start generator is used only for power outages and
maintenance testing. The latest reading of the hours run at the time of inspection were
280 hours. Correspondence at the end of the previous inspection memo in 2022
(DAQC-1619-22) listed the hours at 262.5 hours, so the generator has run 17.5 hours
since the last inspection. As of January 2025, the generator is planned to be run more
routinely for maintenance (see status for condition II.B.1.b)

II.B.2.b The Black Start Generator shall comply with the maintenance requirements of Table 2d #4 of
40 CFR 63 Subpart ZZZZ. [40 CFR 63 Subpart ZZZZ]

Status: In compliance – Records indicate maintenance according to manufacturer’s
recommendations. The latest maintenance was completed on January 07, 2025.

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Section III: APPLICABLE FEDERAL REQUIREMENTS
NSPS Subpart GG: Standards of Performance for Stationary Gas Turbines –
Status: In compliance:

60.330 – This subpart applies to stationary gas turbines with a heat input at peak load equal to or greater than 10 MMBtu/hr that commenced construction after October 03, 1977. The
three turbines have a heat input of 138 MMBtu/hr each and were installed in 2001 and 2002.
60.332 – Plantwide NOx emissions are limited by Condition II.B.1c above. Stack testing was
last conducted on August 23 and 24, 2021.
60.333(b) – Based on information submitted on November 30, 2017, (attached to
memorandum dated January 2, 2018, DAQC-033-18) the sulfur content of the gas burned in
the turbines was less than 20 gr/100 scf.

60.334 – The turbines were constructed before July 8, 2004, but do not use water or steam
injection to control NOx emissions.

60.334(h)(3) – The fuel burned in the turbines meets the definition of pipeline quality natural
gas in 60.331(u). Murray City has an agreement with Dominion Energy that the sulfur
content of the gas supplied will be 20 gr/100 scf or less.

MACT Subpart ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion Engines

Status: In compliance – This subpart applies to the black start generator. Subpart ZZZZ reporting
requirements for the generator are addressed in Section II.B.2 of the AO. The filters were
changed on January 07, 2025, and other maintenance was performed by Wheeler Power
Systems.

AREA SOURCE RULES EVALUATION:

R307-203. Emission Standards: Sulfur Content of Fuels

Status: In compliance – Compliance with this rule is addressed in condition II.B.1.b of the AO.

EMISSION INVENTORY: The 2023 annual Emissions Inventory was submitted, to the
DAQ, on April 11, 2024. The 2024 annual Emission Inventory is
due April 15, 2025.

Murray City Power’s 2023 total Annual Emission Inventory
Summary (As Currently Stands):

Pollutants Tons/Year
PM10 0.61
PM2.5 0.61
SOX 0.03
NOx 4.75
VOC 0.20
CO 7.57

PREVIOUS ENFORCEMENT
ACTIONS: None in the previous five years.

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COMPLIANCE STATUS &
RECOMMENDATIONS: Out of compliance with Condition II.b.1.c.1.B for failure to test
turbine every 3,000 hours to determine turbine emission factors.
The source is expected to perform stack testing in July and is not
expected to operate the turbines until after testing is completed.
Issue warning letter.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: None

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual.

ATTACHMENTS: VEO Form
Correspondence
Robert Haynes <[e-mail]>
Follow-up for today's DEQ compliance inspection
Chris Niemann <[e-mail]>Fri, Jan 31, 2025 at 12:30 PM
To: Robert Haynes <[e-mail]>
Robert, it was good to meet you yesterday. Yes I will have Cory double check those hours. It doesn’t make sense as Unit
3 has not been operating at all last year. I’ll also follow up on the hours for the other units. It was my understanding that
we do a stack test every 9000 hours collectively or 5 years, so 3000 each unit. But waiting to do the test until the 9000
hour mark. So now I have that clarification I will move forward with that standard. That being said, the hours still don’t
add up. I will do some investigating.
Thanks,
Chris
Sent from my iPhone
On Jan 30, 2025, at 3:28 PM, Robert Haynes <[e-mail]> wrote:
[Quoted text hidden]
2/3/25, 12:38 PM State of Utah Mail - Follow-up for today's DEQ compliance inspection
https://mail.google.com/mail/u/0/?ik=7511128095&view=pt&search=all&permmsgid=msg-f:1822793985755783002&simpl=msg-f:1822793985755783002 1/1
Robert Haynes <[e-mail]>
Additional questions about the turbines
Chris Niemann <[e-mail]>Tue, Feb 4, 2025 at 2:44 PM
To: Robert Haynes <[e-mail]>
Robert we are going to put new controls on all 3 units ,And yes we are going to test them after the controls
are done 3rd week of July 2025 I can send you the PO for the controls if needed Thanks Chis
From: Robert Haynes <[e-mail]>
Sent: Tuesday, February 4, 2025 2:23 PM
To: Chris Niemann <[e-mail]>
Subject: [EXTERNAL]Addional quesons about the turbines

Hi Chris,

I just wanted to get clarification on our phone conversation yesterday:

1. Do you have an idea of when you will perform stack testing on the turbine that exceeded the hours (as well as testing of
the other turbines)?
2. I believe you said that you were not planning on running the turbines until the stack testing is completed (and that you
were going to do the testing after you have the new controls on them), but can you confirm?

Thank you,

Robert Haynes, 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.
2/4/25, 2:46 PM State of Utah Mail - Additional questions about the turbines
https://mail.google.com/mail/u/0/?ik=7511128095&view=pt&search=all&permmsgid=msg-f:1823164857552504441&dsqt=1&simpl=msg-f:1823164857…1/1