DAQ-2025-001062

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DAQC-152-25
Site ID 10414 (B1)

MEMORANDUM

TO: FILE – CENTRAL VALLEY WATER RECLAMATION FACILITY

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: February 6, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Salt Lake County,
FRS # UT00000004903500191

INSPECTION DATE: January 29, 2025

SOURCE LOCATION: 800 West Central Valley Road, Salt Lake City, Salt Lake County

Mailing Address:

800 West Central Valley Road
Salt Lake City, UT 84119-3379

SOURCE CONTACTS: Bryan Mansell – Director of Engineering: 801-973-9178, Ext. 171

OPERATING STATUS: JMS #1 and #3 online, 1677 kw per unit. South Boiler online. Flares
not online.

PROCESS DESCRIPTION:

Central Valley Water Reclamation Facility (CVWRF) operates a wastewater treatment plant where solids are
separated from wastewater streams (sewage) and decomposed through bacterial action. As the bacteria
consume the solid waste, “digester” gases are produced. This gas is used as fuel for several engine generators,
which generate electricity for the plant. The system is designed to capture all of the digester gas and send it to
the generators. The digester gas is supplemented with natural gas when there is not enough digester gas
available to maintain a constant fuel supply for the engines, or, the engines are shut off and electricity is
purchased from a utility company. Ferric chloride is used to control H2S output. No additional emission
controls have been installed at this facility.

If a generator unit shuts down or if excess digester gas is produced, then excess digester gas is sent to the flare.
The flare is typically used for very short intervals (2 - 3 minutes) before an additional engine is brought online
to use the excess digester gas. Emergency generators are on-site in the event of loss of the digester engines.

APPLICABLE REGULATIONS: Title V Operating Permit 3500191001, issued March 16, 2020
Last Revised September 9, 2021

40 CFR 63, Subpart ZZZZ: RICE – included in permit
40 CFR 63, Subpart IIII RICE - included in permit
Utah SIP - included in permit.

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SOURCE INSPECTION 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: Not Evaluated. This is a statement of fact.

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: In Compliance. The permittee has operated in compliance with the conditions of this permit. See
each condition below for specific details.

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: In Compliance. The permittee appeared to be in compliance with all conditions of this permit at the
time of inspection. See specific conditions below.

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))
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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))

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))

Status: Permit expires March 16, 2025.

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))

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: Permit renewal is due September 16, 2024. Company is aware of the date.

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: Not Evaluated. This is a statement of fact.

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 emission fees have been paid as invoiced.

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: Not Evaluated. This is a statement of fact.

I.I Revision Exception.

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

Status: Not Evaluated. This is a statement of fact.

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 times 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. Access was granted to the facility and records. 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. All documents submitted by CVWRF in the past year have been signed by the
responsible official.

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. Annual certification was submitted March 18, 2024 (due date of March 16, 2024).
The certification was reviewed by DAQ, and memo and report are in the main source file.

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: No permit shields are listed for this source.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events beyond
the control of the source, including acts of God, which situation requires immediate corrective
action to restore normal operation, and that causes the source to exceed a technology-based
emission limitation under this permit, due to unavoidable increases in emissions attributable to the
emergency. An emergency shall not include noncompliance to the extent caused by improperly
designed equipment, lack of preventive maintenance, careless or improper operation, or operator
error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance with
such technology-based emission limitations if the affirmative defense is demonstrated through
properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards, or other requirements in this
permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))
I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency
has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any
other section of this permit. (R307-415-6g(5))

Status: There have been no emergency situations reported at this facility since the last inspection.

I.O Operational Flexibility.

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

Status: Not Evaluated. This is a statement of fact.

I.P Off-permit Changes.

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

Status: Not Evaluated. This is a statement of fact.
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I.Q Administrative Permit Amendments.

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

Status: Not Evaluated. This is a statement of fact.

I.R Permit Modifications.

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

Status: Not Evaluated. This is a statement of fact.

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.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

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.
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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
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone].

Status: In Compliance. Records were reviewed during inspection and appeared to be complete. Semi-
annual reports have been submitted, reviewed by DAQ, and are in the main source file.

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))
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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: Not Evaluated. This is a statement of fact.

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. Emission inventories have been submitted as required.

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: Not Evaluated. This is a statement of fact.

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 JMS Digester Gas/Natural Gas Engines
Four (#1, #2, #3, and #4) GE Jenbacher Model JMS 612-F28F02 generator engines. Rating: 2,509 hp
(each). Fuel Type: Natural Gas/Digester Gas. These engines are subject to 40 CFR 60 Subpart JJJJ and
40 CFR 63 Subpart ZZZZ.

II.A.3 Diesel Fired Emergency Generators
Seven diesel emergency back-up generators.

II.A.4 Existing Emergency CI Engines (Subpart ZZZZ).
Three diesel engines rated at approximately 896, 896, and 349 hp. These engines are subject to 40 CFR
Part 63, Subpart ZZZZ, as existing-emergency CI engines constructed before June 12, 2006.

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II.A.5 New Emergency CI Engines (Subpart ZZZZ/IIII).
Two diesel engines rated at approximately 800 hp each, manufactured 2016, and two diesel engines rated
at approximately 1,341 hp each, manufactured 2015.

These engines are subject to 40 CFR Part 60, Subpart IIII, referenced through 40 CFR Part 63, Subpart
ZZZZ, as New-emergency CI engines, 2007 model year and later, constructed after July 11, 2005, and
manufactured after April 1, 2006.

II.A.6 Waste Oil Heaters
Three waste oil heaters rated at 0.28, 0.33, and 0.35 MMBtu/hr. each. Fuel: Used Oil.

II.A.7 Digester Gas Flares
Two flares for burning off digester gas.

II.A.8 Boilers
Two natural gas fired boilers rated at 6.05 MMBtu/hr, and 6.28 MMBtu/hr.

II.A.9 H2S Removal Vessel
H2S removal vessel upstream of the engines used to treat digester gas. No unit specific applicable
requirements.

Status: In Compliance. No unapproved equipment was observed during this inspection. The company has
submitted an NOI for three new emergency generators. The units are on site but not installed.

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:

Sulfur content of any fuel oil burned shall be no greater than 0.85 lb/MMBtu heat input, with the
exception of more stringent fuel sulfur limits specified elsewhere in this permit. [Origin: R307-203-1(1);
Authority: R307-203-1(1)].

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 maintain records of each delivery of fuel oil. Records shall include the name
of the supplier, and a statement from the supplier that the oil complies with the specifications
under the definition of distillate oil*.

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

*Distillate oil means fuel oil that complies with the specifications for fuel oil numbers 1 or 2, as
defined by the American Society for Testing and Materials in ASTM D396-78, 89, 90, 92, 96, or
98, "Standard Specifications for Fuel Oils.".

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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. The only fuel oil used is ULS diesel (confirmed in delivery billing) for emergency
generators.

II.B.1.b Condition:

At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the
extent practicable, maintain and operate any equipment under this permit, 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. [Origin: DAQE-AN104140015-21; Authority: R307-401-8].

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

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.b.3 Reporting:

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

Status: In Compliance. All equipment observed during the inspection appeared to be in good operational
order. Records are kept and were made available. Company has a preventative maintenance and
tracking (NEXGEN) program.

II.B.2 JMS Digester Gas/Natural Gas Engines

II.B.2.a Condition:

Visible emissions shall not exceed 10% opacity. [Origin: DAQE-AN104140015-21; Authority
R307-401-8].

II.B.2.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at any time during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall be
performed by a certified observer within 24 hours of the initial visual emission observation. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9.

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II.B.2.a.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each quarter for each affected emission unit, the log shall include either the
date of the opacity observation and if visual emission other than condensed water vapor were
observed or a note that the emission unit was not operated. For each observed visual emission
other than condensed water vapor the permittee shall record: date and time of visual emission
observation, emission unit location and description, time and date of opacity determination, and
percent opacity. The records required by this provision and all data required by 40 CFR 60,
Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.a.3 Reporting:

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

Status: In Compliance. No visible emissions were observed from any part of the plant during this
inspection or three Occupational Medicine tours. Opacity observations are done quarterly based
on app which issues work orders and tracks completion. Company personnel do a method nine
reading as the first reading. App has all required Method 9 info in click and fill format. The
company has two employees certified and Method 9 certifications have been kept up to date. Last
readings were done in December 2024.

II.B.2.b Condition:

The permittee shall operate and maintain each digester gas/natural gas engine that achieves the emission
standards as required in 40 CFR 60.4233 over the entire life of the engine [Origin: 40 CFR 60.4234].

Air-to-fuel ratio controllers must be maintained and operated appropriately in order to ensure proper
operation of the engine and control device to minimize emissions at all times [Origin: 40 CFR
60.4243(g)].

The permittee shall, to the extent practicable, maintain and operate the engine in a manner consistent with
good air pollution control practice for minimizing emissions [Origin: 40 CFR 60.4243(b)(2)(ii)].

The permittee shall comply with the applicable general provisions in 40 CFR 60.1 thru 60.19 as identified
in Table 3 of 40 CFR Part 60,Subpart JJJJ [Origin: 40 CFR 60.4246]

[Authority: 40 CFR 60 Subpart JJJJ].

II.B.2.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.b.2 Recordkeeping:

The permittee shall keep a maintenance plan and records of conducted maintenance [Origin: 40
CFR 60.4243(b)(2)(ii), and 40 CFR 60.4245(a)(2)].

If the stationary SI internal combustion engine is a certified engine, the permittee shall keep
documentation from the manufacturer that the engine is certified to meet the emission standards
and information as required in 40 CFR parts 90, 1048, 1054, and 1060, as applicable. [Origin: 40
CFR 60.4245(a)(3)].

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If the stationary SI internal combustion engine is not a certified engine or is a certified engine
operating in a non-certified manner and subject to 40 CFR 60.4243(a)(2), the permittee shall keep
documentation that the engine meets the emission standards. [Origin: 40 CFR 60.4245(a)(4)].

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

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. CVWRF has a team dedicated to maintaining the engines on site. A maintenance
plan is in place and the maintenance activities are recorded. Work orders and preventative
maintenance service reminders are created and recorded in CMMS software (NEXGEN).

II.B.2.c Condition:

Emissions from each engine shall not exceed the following limits:

Pollutant Digester Gas Mode Natural Gas Mode

VOC* 1.0 g/bhp-hr*** 0.7 g/bhp-hr***
VOC(NMHC)** 0.3 g/bhp-hr**** 0.3 g/bhp-hr****
NOx 0.55 g/bhp-hr**** 0.55 g/bhp-hr****
CO 2.50 g/bhp-hr***** 2.0 g/bhp-hr*****

*When calculating emissions of VOC, emissions of formaldehyde should not be included.
** VOC (NMHC) includes emissions of non-methane hydrocarbons.
***[Origin: 40 CFR 60.4233(e), and 40 CFR Part 60, Subpart JJJJ-Table 1; Authority: 40 CFR Part 60,
Subpart JJJJ].
**** [Origin DAQE-AN104140015-21; Authority: R307-401-8]
*****[Origin: 40 CFR 60.4233(e), 40 CFR Part 60 Subpart JJJJ-Table 1, and DAQE-AN104140015-21;
Authority: 40 CFR Part 60, Subpart JJJJ, and R307-401-8].

II.B.2.c.1 Monitoring:

The permittee shall conduct performance testing to demonstrate compliance with emission
standards.

The permittee shall conduct an initial performance test within 180 days of engines #3 and #4
startup [Origin: R307- 401-8].

The permittee shall conduct subsequent performance testing every 8,760 hours or 3 years,
whichever comes first [Origin: 40 CFR 60.4243(b)(2)(ii) & R307- 401-8].

Performance testing shall be conducted as specified in 40 CFR 60.4244 [Origin: 40 CFR
60.4243(b)(2)], and in accordance with the following requirements:

(A) Sample Location: The sampling location shall be designed to conform to the requirements of
40 CFR 60, Appendix A, Method 1, or other methods as approved by EPA and acceptable to the
Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location [Origin: R307-
415-6c(1) & R307- 401-8].

14
(B) Volumetric Flow Rate Test Methods: 40 CFR 60, Appendix A, Method 2 or other testing
methods approved by EPA and accepted by the Director [Origin: R307-415-6c(1) &
R307- 401-8].

(C) NOx Test Methods: 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E and in
accordance with 40 CFR 60.4244(d), or other EPA approved testing methods approved by the
Director [Origin: R307-415-6c(1), R307- 401-8, and 40 CFR 60.4244(d)].

(D) CO Test Methods: 40 CFR 60, Appendix A, Method 10, and in accordance with 40 CFR
60.4244(e), or other EPA approved testing methods acceptable to the Director [Origin: R307-
415-6c(1), R307- 401-8, and 40 CFR 60.4244(e)].

(E) VOC test methods: Test in accordance with 40 CFR 60, Appendix A, Method 18 and 40 CFR
60.4244(f)-(g) [Origin R307-415-6(c), R307-401-8, and 40 CFR 60.4244(f)-(g)].

(F) 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 determined by the Director, to give the results in the specified
units of the emission limitation.

(G) New Source Operation: For a new source/emission point, the production rate during all
compliance testing shall be no less than 90% of the production rate listed in this AO. If the
maximum AO allowable production rate has not been achieved at the time of the test, the
following procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully tested at
a higher rate.

3) 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 AO production rate is achieved.

(H) Existing Source Operation: For an existing source/emission point, the production rate during
all compliance testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

The source may be tested at any time if directed by the Director.

II.B.2.c.2 Recordkeeping:

There are no additional recordkeeping requirements except as outlined in Provision I.S.1 of this
permit.

II.B.2.c.3 Reporting:

The Director shall be notified at least 30 days prior to conducting any required emission testing
[Origin: R307-165-3]. A source test protocol shall be submitted to DAQ when the testing
notification is submitted to the Director. The source test protocol shall be approved by the

15
Director prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack(s) to be tested, and procedures to be used [Origin: R307-415-6c(1)]. A
pretest conference shall be held, if directed by the Director [Origin: R307-165-3].

The permittee shall submit the results of each performance test to the Director within 60 days
after the test has been completed [Origin: 40 CFR 60.4245(d), R307- 401-8].

Performance test reports using EPA Method 18, EPA Method 320, or ASTM D6348-03
(incorporated by reference-see 40 CFR 60.17) to measure VOC require reporting of all QA/QC
data. For Method 18, report results from sections 8.4 and 11.1.1.4; for Method 320, report results
from sections 8.6.2, 9.0, and 13.0; and for ASTM D6348-03 report results of all QA/QC
procedures in Annexes 1-7 [Origin: 40 CFR 60.4245(d)].

The permittee shall submit an initial notification as required in 40 CFR 60.7(a)(1). The
notification must include the information in paragraphs (1) - (5) below:

(1) Name and address of the owner or operator;

(2) The address of the affected source;

(3) Engine information including make, model, engine family, serial number, model year,
maximum engine power, and engine displacement;

(4) Emission control equipment; and

(5) Fuel used.

[Origin: 40 CFR 60.4245(c)]

There are no additional reporting requirements except as outlined in Section I of this permit.

Status: In Compliance. Initial Stack testing for JMS engines have been completed and all engines are on
the 3 year or 8,760 hours schedule. Initial notices were submitted with initial reports. Engines
operate at a standard load which meets the 90% requirement for subsequent testing. Hours are
tracked in the maintenance program. Engines 2 and 4 have about 5,000 hours and will be tested by
the end of 2025. Most current testing is shown below.

Source Test Date Test Method Pollutant Result Limit

Jenbacher 1 9/4-5/24 RM 320 NOx 0.52 g/bhp-hr 0.55 g/hp-hr
CO 2.19 g/bhp-hr 2.50 g/hp-hr
VOC 0.1 g/bhp-hr 1.0 g/hp-hr
NMHC 0.3 g/bhp-hr 0.3 g/hp-hr

Jenbacher 2 12/15/2023 RM 320 NOx 0.40 g/bhp-hr 0.55 g/hp-hr
CO 1.89 g/bhp-hr 2.50 g/hp-hr
VOC 0.16 g/bhp-hr 1.0 g/hp-hr
NMHC 0.27 g/bhp-hr 0.3 g/hp-hr

Jenbacher 3 9/5-6/24 RM 320 NOx 0.46 g/bhp-hr 0.55 g/bhp-hr
CO 2.19 g/bhp-hr 2.50 g/bhp-hr
VOC 0.1 g/bhp-hr 1.0 g/bhp-hr
NMHC 0.2 g/bhp-hr 0.3 g/bhp-hr

16
Source Test Date Test Method Pollutant Result Limit

Jenbacher 4 12/14/23 RM 320 NOx 0.40 g/bhp-hr 0.55 g/bhp-hr
CO 1.71 g/bhp-hr 2.0 g/bhp-hr
VOC 0.14 g/bhp-hr 0.7 g/bhp-hr
NMHC 0.24 g/bhp-hr 0.3 g/bhp-hr

II.B.2.d Condition:

The permittee shall limit emissions from all JMS Digester Gas/Natural Gas engines to 53 tons of NOx per
rolling 12-month period.

[Origin: DAQE-AN104140015-21; Authority: R307-401-8].

II.B.2.d.1 Monitoring:

The permittee shall determine compliance with a rolling 12-month total by calculating a new 12-
month total using data from the previous 12 months. Monthly calculations shall be made no later
than 20 days after the end of each calendar month. The permittee shall demonstrate compliance
with the rolling 12-month limit by using the following equation for each engine and the
appropriate conversion factors:

NOx = [Emission rate of engine] x [Hours of operation of engine]

The most recent stack test data shall be used as the emission rates for the rolling 12-month total
calculations. For the period between installation and the initial stack test, the NOx emission limit
in condition II.B.2.c shall be used.

II.B.2.d.2 Recordkeeping:

Records of hours of operation shall be kept for all periods when the engines are in operation.
Continuous recording is required. Records shall be kept on a daily basis and shall be maintained
in accordance with Provision I.S.1 of this permit.

II.B.2.d.3 Reporting:

There are no additional reporting requirements except as outlined in Section I of this permit.

Status: In Compliance. Company has a daily spreadsheet which has engine parameters and does
calculation for NOx emissions to include daily and 12-month rolling totals for NOx. Review of
Spreadsheet does show correct emission factors are being used. The NOx 12-month total as of
December 31, 2024, was 18.32 tons.

II.B.3 Diesel Fired Emergency Generators

II.B.3.a Condition:

Visible emissions shall be no greater than 20 percent opacity.

[Origin: DAQE-AN104140015-21; Authority: R307- 401-8].

17
II.B.3.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at any time during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall be
performed by a certified observer within 24 hours of the initial visual emission observation. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.3.a.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each quarter for each affected emission unit, the log shall include either the
date of the opacity observation and if visual emission other than condensed water vapor were
observed or a note that the emission unit was not operated. For each observed visual emission
other than condensed water vapor the permittee shall record: date and time of visual emission
observation, emission unit location and description, time and date of opacity determination, and
percent opacity. The records required by this provision and all data required by 40 CFR 60,
Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

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

Status: In Compliance. No visible emissions were observed from any part of the plant during this
inspection. Opacity observations are done quarterly based on app which issues work orders and
tracks completion. App has all required Method 9 info in click and fill format. Method 9
certifications have been kept up to date.

II.B.4 Existing Emergency CI Engines (Subpart ZZZZ)

II.B.4.a Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation 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, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63.6595(a) and 63.6605(b);
Authority: 40 CFR 63 Subpart ZZZZ].

II.B.4.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.a.2 Recordkeeping:

18
The permittee shall keep the records described in (1)-(5) below, as applicable:

(1) A copy of each notification and report that you submitted to comply with this subpart,
including all documentation supporting any Initial Notification or Notification of Compliance
Status that you submitted, according to the requirement in 40 CFR 63.10(b)(2)(xiv).

(2) Records of the occurrence and duration of each malfunction of operation (i.e., process
equipment) or the air pollution control and monitoring equipment.

(3) Records of performance tests and performance evaluations as required in 40 CFR
63.10(b)(2)(viii).

(4) Records of all required maintenance performed on the air pollution control and monitoring
equipment.

(5) Records of actions taken during periods of malfunction to minimize emissions in accordance
with 40 CFR 63.6605(b), including corrective actions to restore malfunctioning process and air
pollution control and monitoring equipment to its normal or usual manner of operation.

[40 CFR 63.6655(a)(1)-(5)].

The permittee shall document activities performed to assure proper operation and maintenance.

[40 CFR 63.6655(e)].

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.4.a.3 Reporting:

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

Status: In Compliance. Records are kept. The engines appear to be operated according to this condition.
Engine hours are consistent with records. Spot check of engines show no leaks and engines appear
to be in good operational order. Logs are kept with the engines and show use and maintenance
activities.

II.B.4.b Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
generator:

(1) The permittee shall operate the affected emission unit according to the requirements in paragraphs
(1)(a) through (1)(b). Any operation other than emergency operation, maintenance and testing, operation
in non-emergency situations for 50 hours per year, as described in (1)(a) through (1)(b), is prohibited. If
the engine is not operated in accordance with paragraphs (1)(a) through (1)(b), it will not be considered
an emergency engine and shall meet all requirements for non-emergency engines.

(a) There is no time limit on the use of emergency stationary RICE in emergency situations.

(b) Emergency stationary RICE may be used as specified in paragraph (i) below for a maximum
of 100 hours per calendar year.

19
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine. The permittee may
petition the Director for approval of additional hours to be used for maintenance checks and
readiness testing, but a petition is not required if the permittee maintains records indicating that
federal, state, or local standards require maintenance and testing of emergency RICE beyond 100
hours per calendar year.

(2) The permittee shall meet the following requirements at all times, except during periods of startup:

(a) Change oil and filter every 500 hours of operation or annually, whichever comes first.

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first,
and replace as necessary.

(3) The permittee has the option to utilize an oil analysis program as described in 40 CFR 63.6625(i) in
order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

(4) During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.

(5) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40CFR 63 Subpart ZZZZ.

[Origin: 40 CFR 63.6595(a)(1), 40 CFR 636603(a), 40 CFR 63.6605(a), 40 CFR63.6625(h), 40 CFR
63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d(4), 40 CFR 63 Subpart ZZZZ Table
2d(footnote 1), and 40 CFR 63 Subpart ZZZZ Table 8; Authority: 40 CFR 63 Subpart ZZZZ].

(6) Each emergency engine shall also not exceed 100 hours of operation for testing and maintenance per
rolling 12-month period. The 100 hours of operation for testing and maintenance purposes may include
up to 50 hours per calendar year for operation in nonemergency situations as provided in 40 CFR
60.4211(f).

[Origin: DAQE-AN104140015-21; Authority: R307- 401-8.].

II.B.4.b.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)].

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under Federal, State, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
the unacceptable risk under Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

20
The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6].

II.B.4.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable.
[40 CFR 63.6655(a)]

Calendar year limitation: For each engine, the permittee shall keep records of annual hours of
operation recorded by the non-resettable hour meter. The permittee shall document how many
hours are spent for emergency operation; including what classified the operation as emergency
and how many hours are spent for non-emergency operation. If the engines are used for demand
response operation, the permittee shall keep records of the notification of the emergency
situation, and the time the engine was operated as part of demand response [40 CFR 63.6655(f)].

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

Rolling 12-month limitation: Compliance with the 100 hours, rolling 12-month limit shall be
determined by installation of an hour meter, or by recording hours of operation in an operations
log. The permittee shall calculate a new 12-month total by the 20th day of each month using data
from the previous 12 months.

Records documenting the operation of the emergency generator engine shall be kept in a log and
shall include the following:

A. The date the emergency generator engine was used;

B. The duration of operation each day in hours; and

C. The reason for the emergency generator engine usage.

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.4.b.3 Reporting:
21
The permittee shall report any failure to perform the management practice on the schedule
required and the Federal, State or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

The permittee shall also report each instance in which it did not meet the applicable requirements
in Table 8. [40 CFR 63.6640(e)]

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

Status: In Compliance. Records of generator usage are kept. For the 12-month period ending December
31, 2024, the following hours were reported. Work orders and preventative maintenance service
reminders are created and recorded in CMMS software (NEXGEN). The spreadsheet shows
monthly use and calendar and 12-month totals for both non-emergency use and emergency use.

Gen # HP Location Non emer
hrs
Emer
hrs
New/
existing
6 800 Pwr gen bldg. 18 1 New
7 800 Pwr gen bldg. 19 1 New
9 896 RSS bldg. 54 4 Existing
10 349 Admin 72 1 Existing
11 896 RSS bldg. 59 1 Existing
12 1341 Headworks 38 1 New
13 1341 Headworks 30 2 New

The company has had multiple generator uses due to construction activities but all use is tracked
and recorded as required.

II.B.4.c Condition:

The permittee shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency
generator engines. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and
contain no more than 15 ppm sulfur.

[Origin: DAQE-AN104140015-21; Authority: R307- 401-8].

II.B.4.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.c.2 Recordkeeping:

To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the
permittee shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall
indicate the diesel fuel meets the ULSD requirements, or the permittee shall obtain certification
of sulfur content from the fuel supplier. [R307-401-8]

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

22
II.B.4.c.3 Reporting:

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

Status: In Compliance. CVWRF purchases ultra-low sulfur #2 diesel. The most recent fuel invoice
indicated a sulfur content of 15 ppm.

II.B.5 New Emergency CI Engines (Subpart ZZZZ/IIII)

II.B.5.a Condition:

Emergency generators shall be installed and configured according to the manufacturer's emission-related
specifications, except as permitted by 40 CFR 60.4211(g) [Origin: 40 CFR 60.4211(c); Authority: 40
CFR Part 60, Subpart IIII referenced through 40 CFR Part 63, Subpart ZZZZ]

Emergency generators shall be certified to, and shall comply with, the emission standards assigned under
40 CFR 60.4202(a)(2). [Origin: 40 CFR 60.4205(b)-(c); Authority: 40 CFR Part 60, Subpart IIII
referenced through 40 CFR Part 63, Subpart ZZZZ].

The permittee shall comply with the applicable general provisions in 40 CFR 60.1-19 as identified in
Table 8 of 40CFR 60 Subpart IIII.

II.B.5.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.5.a.2 Recordkeeping:

Records of engine certifications shall be maintained indicating compliance with the above
referenced standards. Records may include labels attached to engines indicating conformance
with U.S. EPA regulations for the appropriate year. Records shall be maintained demonstrating
compliance with the manufacturer's specifications for engine installation and configuration. [40
CFR 60 Subpart IIII]

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

II.B.5.a.3 Reporting:

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

Status: In Compliance. All four engines have the certification paperwork and do have engine labels.

II.B.5.b Condition:

Emergency generators and control devices (if any) shall be operated and maintained according to the
manufacturer's emissions-related written instructions, over the entire life of the engine. The permittee
may only change those settings that are permitted by the manufacturer. The permittee shall also meet the
requirements of 40 CFR part 89, as they apply. [Origin: 40 CFR 60.4206, 40 CFR 60.4211(a)(1)-(3),
Authority: 40 CFR Part 60, Subpart IIII and 40 CFR Part 63, Subpart ZZZZ.].

23
II.B.5.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.5.b.2 Recordkeeping:

Records demonstrating proper operation and maintenance shall be maintained. Records shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.5.b.3 Reporting:

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

Status: In Compliance. At the time of this inspection all engines have been commissioned. Work orders
and preventative maintenance service reminders are created and recorded in CMMS software
(NEXGEN).

II.B.5.c Condition:

Emergency generators shall use diesel fuel that meets the requirements of 40 CFR 1090.305 for non-road
diesel fuel. [Origin: 40 CFR 60.4207(b), and DAQE-AN104140015-21; Authority: 40 CFR Part 60,
Subpart IIII, 40 CFR Part 63, Subpart ZZZZ, and R307-401-8].

II.B.5.c.1 Monitoring:

The permittee shall either: (1) Determine the fuel sulfur content expressed as wt% in accordance
with the methods of the American Society for Testing Materials (ASTM); (2) Inspect the fuel
sulfur content expressed as wt% determined by the vendor using methods of the ASTM; or (3)
Inspect documentation provided by the vendor that directly or indirectly demonstrates compliance
with this provision.

II.B.5.c.2 Recordkeeping:

Fuel receipt records and documentation demonstrating compliance with this provision shall be
maintained. [40 CFR 60 Subpart IIII].

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

II.B.5.c.3 Reporting:

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

Status: In Compliance. CVWRF purchases is ultra-low sulfur #2 diesel. This was confirmed by the most
recent fuel invoice.

II.B.5.d Condition:

Each emergency generator shall be operated according to paragraphs (i) through (iii) below. Any
operation other than emergency operation, maintenance and testing, emergency demand response, and
operation in non-emergency situations for 50 hours per year, as described in paragraphs (i) through (iii),
is prohibited. Engines not operated according to the requirements in paragraphs (i) through (iii), will not

24
be considered emergency engines and will be subject to requirements for non-emergency engines.

(i) There is no time limit on the use of emergency engines in emergency situations.

(ii) Emergency engines may be operated for maintenance checks and readiness testing, provided that the
tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional
transmission organization or equivalent balancing authority and transmission operator, or the insurance
company associated with the engine. The permittee may petition the Director for approval of additional
hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner
or operator maintains records indicating that federal, state, or local standards require maintenance and
testing of emergency ICE beyond 100 hours per calendar year.

(iii) Emergency engines may be operated for up to 50 hours per calendar year in non- emergency
situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per
calendar year for maintenance and testing provided in paragraph (ii) above. [Origin: 40 CFR 60.4211(f);
Authority: 40 CFR Part 63, Subpart ZZZZ, and 40 CFR Part 60, Subpart IIII.]

Each emergency generator shall also not exceed 100 hours of operation for testing and maintenance per
rolling 12-month period. The 100 hours of operation for testing and maintenance purposes may include
up to 50 hours per calendar year for operation in nonemergency situations as provided in 40 CFR
60.4211(f).

Each emergency generator shall be equipped with a non-resettable hour meter prior to startup [Origin: 40
CFR 60.4209(a); Authority: 40 CFR Part 63, Subpart ZZZZ, and 40 CFR Part 60, Subpart IIII.].

II.B.5.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.5.d.2 Recordkeeping:

Calendar year limitations: Usage records shall be kept on a monthly basis in an operation and
maintenance log. Records shall distinguish between maintenance-related hours and emergency
use-related hours. If maintenance and testing beyond 100 hours per year are required by Federal,
State, or local standards, records of these standards shall also be kept. The permittee shall record
the time of operation of the engine and the reason the engine was in operation during that time.
[40 CFR 60.4211(e), and 40 CFR 60.4214(b)].

Rolling 12-month limitation: Compliance with the 100 hours, rolling 12-month limit shall be
determined by installation of an hour meter, or by recording hours of operation in an operations
log. The permittee shall calculate a new 12-month total by the 20th day of each month using data
from the previous 12 months.

Records documenting the operation of the emergency generator engine shall be kept in a log and
shall include the following:

A. The date the emergency generator engine was used;

B. The duration of operation each day in hours; and

C. The reason for the emergency generator engine usage.

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II.B.5.d.3 Reporting:

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

Status: In Compliance. Records of generator usage are kept. For the 12-month period ending March 2022,
the following hours were reported. Work orders and preventative maintenance service reminders
are created and recorded in CMMS software (NEXGEN). The spreadsheet shows monthly use and
calendar and 12-month totals for both non-emergency use and emergency use.

Gen # HP Location Non emer
hrs
Emer
hrs
New/
existing
6 800 Pwr gen bldg. 18 1 New
7 800 Pwr gen bldg. 19 1 New
9 896 RSS bldg. 54 4 Existing
10 349 Admin 72 1 Existing
11 896 RSS bldg. 59 1 Existing
12 1341 Headworks 38 1 New
13 1341 Headworks 30 2 New

The company has had multiple generator uses due to construction activities, but all use is tracked
and recorded as required.

II.B.6 Digester Gas Flares

II.B.6.a Condition:

Visible emissions shall not exceed 10% opacity.

[Origin: DAQE-AN104140015-21; Authority: R307- 401-8].

II.B.6.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at any time during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall be
performed by a certified observer within 24 hours of the initial visual emission observation. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.6.a.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each quarter for each affected emission unit, the log shall include either the
date of the opacity observation and if visual emission other than condensed water vapor were
observed or a note that the emission unit was not operated. For each observed visual emission
other than condensed water vapor the permittee shall record: date and time of visual emission
observation, emission unit location and description, time and date of opacity determination, and
percent opacity. The records required by this provision and all data required by 40 CFR 60,
Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of this permit.

26
II.B.6.a.3 Reporting:

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

Status: In Compliance. No visible emissions were observed from any part of the plant during this
inspection. Opacity observations are done quarterly based on app which issues work orders and
tracks completion. App has all required Method 9 info in click and fill format. Method 9
certifications have been kept up to date.

II.B.7 Boilers

II.B.7.a Condition:

Visible emissions shall not exceed 10% opacity. [Origin: DAQE-AN104140015-21; Authority:
R307-401-8].

II.B.7.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at any time during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall be
performed by a certified observer within 24 hours of the initial visual emission observation. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.7.a.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each quarter for each affected emission unit, the log shall include either the
date of the opacity observation and if visual emission other than condensed water vapor were
observed or a note that the emission unit was not operated. For each observed visual emission
other than condensed water vapor the permittee shall record: date and time of visual emission
observation, emission unit location and description, time and date of opacity determination, and
percent opacity. The records required by this provision and all data required by 40 CFR 60,
Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.7.a.3 Reporting:

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

Status: In Compliance. No visible emissions were observed from any part of the plant during previous
tours and stack tests. Opacity observations are done quarterly based on app which issues work
orders and tracks completion. App has all required Method 9 info in click and fill format. Method
9 certifications have been kept up to date.

II.C Emissions Trading.

Not applicable to this source.

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II.D Alternative Operating Scenarios.

Not applicable to this source.

II.E Source-specific Definitions.

Not applicable to this source.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

EMISSION INVENTORY: From 2023 emissions inventory were as follows: (fil and cond, excl
tailpipe). 2024 inventory listed as not started in SLEIS.

Pollutant Tons/Year
PM10 2.89
PM2.5 1.80
SO2 2.43
NOx 17.56
CO 75.63
VOC 16.52
NH3 14.70
Lead 0.0042
CH2O 0.00006 HAPS
PhCH3 0.00005 HAPS

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Central Valley Water Reclamation Facility should be considered to be
in compliance with the conditions of the AO evaluated at the time of
this inspection.

HPV STATUS: Not Applicable.

COMPLIANCE
ASSISTANCE: Assistance was provided in review of new generator AO process and
time.

RECOMMENDATION
FOR NEXT INSPECTION: Inspect as usual.

ATTACHMENTS: VEO form.