DAQ-2025-001079

1

DAQC-183-25
Site ID 12825 (B5)

MEMORANDUM

TO: CEM FILE – UTAH ASSOCIATED MUNICIPAL POWER SYSTEMS (UAMPS)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: February 18, 2025

SUBJECT: Source: Nebo Generating Facility Natural Gas Turbine Generator
Contact: Dave Gammell (Plant Manager) – 801-925-4012
Location: 1265 Bamberger Road, Payson, Utah County, UT
Test Contractor: Montrose Air Quality Services, LLC
FRS ID#: UT0000004904900234
Permit/AO#: Title V operating permit 4900234004, dated January 18, 2022
Subject: Review of RA/PST Protocol dated February 4, 2025

On February 4, 2025, DAQ received a protocol for a RA/PST (relative accuracy/performance
specification test) of the UAMPS Nebo power station in Payson, UT. Testing will be performed on May
9, 2025, to determine the relative accuracy of the O2, NOx, and CO monitoring systems.

PROTOCOL CONDITIONS:

1. RM 3A used to determine dry molecular weight of the gas stream: OK
2. RM 7E used to determine NOx concentrations of emissions: OK
3. RM 10 used to determine CO concentrations of emissions: OK
4. RM 19 used to determine volumetric flow: OK

DEVIATIONS: No deviations were noted in the protocol.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.

ATTACHMENTS: UAMPS 2025 RATA Source Test Plan

1 8 2
Source Test Plan for the 2025 Relative Accuracy
Test Audit
Utah Associated Municipal Power Systems
(UAMPS)
Nebo Power Generating Station
GE Frame 7EA/HRSG Gas-Fired Turbine (EU #2)
New CEMS Certification
Payson, Utah
Prepared For:
UAMPS
155 North 400 West, Suite 480
Salt Lake City, Utah 84103
Prepared By:
Montrose Air Quality Services, LLC
6823 South 3600 West
Spanish Fork, Utah 84660
For Submission To:
State of Utah DEQ, Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GP081AS-046248-PP-922-R1
Proposed Test Date: May 9, 2025
Test Plan Submittal Date: February 4, 2025
Utah Association of Municipal Power Systems (UAMPS), Payson, Utah2025 Nebo Power Generating Station EU #2 New CEMS Certification RATA Test Plan
Review and Certification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date:February 4, 2025
Name:Beckie Hawkins Title:District Manager
I have reviewed, technically and editorially, details, calculations, results, conclusions, and
other appropriate written materials contained herein. I hereby certify that, to the best of my
knowledge, the presented material is authentic, accurate, and conforms to the requirements
of the Montrose Quality Management System and ASTM D7036-04.
Signature:Date:February 4, 2025
Name:Joby Dunmire Title:Reporting/QC Specialist III
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Table of Contents
Section Page
1.0 Introduction ........................................................................................................5
1.1 Summary of Test Program.............................................................................5
1.2 Applicable Regulations and Emission Limits......................................................6
1.3 Key Personnel..............................................................................................7
2.0 Plant and Sampling Location Descriptions................................................................8
2.1 Process Description, Operation, and Control Equipment.....................................8
2.2 CEMS Description .........................................................................................9
2.3 Flue Gas Sampling Location ...........................................................................9
2.4 Operating Conditions and Process Data .........................................................10
3.0 Sampling and Analytical Procedures .....................................................................13
3.1 Test Methods .............................................................................................13
3.1.1 EPA Methods 3A, 7E, and 10, Determination of Oxygen, Nitrogen Oxides,
and Carbon Monoxide Concentrations in Emissions from Stationary Sources
(Instrumental Analyzer Procedure) ......................................................13
3.1.2 EPA Method 19, Determination of Nitrogen Oxide and Carbon Monoxide
Emission Rates..................................................................................14
4.0 Quality Assurance and Reporting..........................................................................15
4.1 QA Audits..................................................................................................15
4.2 Quality Control Procedures ..........................................................................15
4.2.1 Equipment Inspection and Maintenance................................................15
4.2.2 Audit Samples...................................................................................15
4.3 Data Analysis and Validation........................................................................15
4.4 Sample Identification and Custody................................................................16
4.5 Quality Statement ......................................................................................16
4.6 Reporting ..................................................................................................16
4.6.1 Example Report Format......................................................................16
4.6.2 Example Presentation of Test Results...................................................17
List of Appendices
A Supporting Information......................................................................................19
A.1 Units and Abbreviations..............................................................................20
A.2 Accreditation Information/Certifications........................................................2
“S” Site Specific Safety Plan.............................................................................3
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List of Tables
1-1 Summary of Test Program and Proposed Schedule...................................................5
1-2 Summary of Part 60/75 RA Requirements – Nebo EU #2 ..........................................6
1-3 Test Personnel and Responsibilities ........................................................................7
2-1 CEMS Information................................................................................................9
2-2 Sampling Location................................................................................................9
4-1 Example Nitrogen Oxide (ppmvd) RATA Results - Nebo EU #2................................. 18
List of Figures
3-1 US EPA Methods 3A, 7E, and 10 Sampling Train....................................................14
4-1 Typical Report Format .......................................................................................17
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1.0 Introduction
1.1 Summary of Test Program
Utah Association of Municipal Power Systems (UAMPS) contracted Montrose Air Quality
Services, LLC (Montrose) to perform a RATA on the recently installed CEMS associated with
GE Frame 7EA w/HSRG Unit, natural gas-fired, combined-cycle, stationary, combustion
turbine (identified as emission unit EU #2) at the Nebo Power Generating Station located in
Payson, Utah.
The tests are conducted to determine compliance with the applicable RA requirements listed
in State of Utah Department of Environmental Quality (UDEQ), Division of Air Quality Title V
Operating Permit No. 4900234004, dated January 18, 2022, 40 CFR 60 Appendix B and 40
CFR Part 75, Appendix A.
The specific objectives are to:
x Determine the RA for the new O2, NOX, and CO CEMS installed to monitor the
emissions from Nebo EU #2 to meet initial certification requirements.
x Conduct the test program with a focus on safety.
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.
Table 1-1
Summary of Test Program and Proposed Schedule
Proposed
Test Date
Unit ID/
Source Name Activity/Parameters Test Methods
No. of
Runs
Duration
(Minutes)
May 9, 2025 Nebo EU #2 Perform O2, NOX and CO RATAs EPA 3A, 7E, 10, 19 9-12 21
To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
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1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The RA requirements are presented in Table 1-2.
Table 1-2
Summary of Part 60/75 RA Requirements – Nebo EU #2
Parameter/Units
Regulatory
Reference Allowable
Part 60
Nitrogen Oxides (NOx as NO2)
ppmvd PS-2 ”RI50RU”RI$6
Carbon Monoxide (CO)
ppmvd PS-4A ”RI50RU”RI$6RU”SSPYG&2
Part 75
Oxygen (O2)
YROXPHGU\App. B Sect. 2.3.1.2 $QQXDO”RI50RU“22
YROXPHGU\App. A Sect. 3.3.3 6HPLDQQXDO”RI50RU“22
Nitrogen Oxides (NOx as NO2)
lb/MMBtu App. B Sect. 2.3.1.2 $QQXDO”RI50RU“OE00%WX1
lb/MMBtu App. A Sect. 3.3.2
6HPLDQQXDO”RI50RU“
lb/MMBtu1
1 Alternate is for low emitter (average NOX 50FRQFHQWUDWLRQVDUH”SSPRUDYHUDJH12X RM emission rates DUH”OE00%WX
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1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: UAMPS
Nebo Power Generating Station
1265 N. Bamberger Road
Payson, Utah 84651
Project Contact: Dave Gammell
Role: Plant Manager
Company: UAMPS
Telephone: [phone]
Email: [e-mail]
Agency Information
Regulatory Agency: State of Utah DEQ, Division of Air Quality
Agency Contact: Chad Gilgen, Minor Source
Compliance
Telephone: [phone]
Email: [e-mail]
Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Beckie Hawkins Cheyney Guymon
Title: District Manager Client/Field Project Manager
Telephone: [phone]
Email: [e-mail] [e-mail]
Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personnel and Responsibilities
Role Primary Assignment Additional Responsibilities
Client Project Manager Coordinate Project Post-test follow up
Field Project Manager Operate mobile lab Facility interface, test crew coordination
Field Technician Execute stack platform
responsibilities Preparation, support PM
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2.0 Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Turbines are stationary, internal combustion engines that operate with rotary rather
than reciprocating motion. Gas turbines are essentially composed of three major
components: compressor, combustor, and power turbine. In the compressor section,
ambient air is drawn in and compressed up to 30 times ambient pressure and
directed to the combustor section where fuel is introduced, ignited, and burned.
Combustors can either be annular, can-annular, or silo. An annular combustor is a
doughnut-shaped, single, continuous chamber that encircles the turbine in a plane
perpendicular to the airflow. Can-annular combustors are like the annular; however,
they incorporate several can-shaped combustion chambers rather than a single
continuous chamber. Annular and can-annular combustors are based on aircraft
turbine technology and are typically used for smaller scale applications. A silo
(frame-type) combustor has one or more combustion chambers mounted external to
the gas turbine body. Silo combustors are typically larger than annular or can-
annular combustors and are used for larger scale applications.
This GE Frame 7EA/HSRG (EU #2) is a combined-cycle gas turbine (CCGT) plant.
The gas turbine generator generates electricity and the waste heat from the gas
turbine is used to make steam to generate additional electricity via a steam turbine;
this last step enhances the efficiency of electricity generation.
Hot gases from the combustion section are diluted with additional air from the
compressor section and directed to the power turbine section at temperatures up to
2600 degrees Fahrenheit. Energy from the hot exhaust gases, which expand in the
power turbine section, are recovered in the form of shaft horsepower. More than 50
percent of the shaft horsepower is needed to drive the internal compressor and the
balance of recovered shaft horsepower is available to drive an external load. Gas
turbines may have one, two, or three shafts to transmit power between the inlet air
compression turbine, the power turbine, and the exhaust turbine. The heat content
of the exhaust gases exiting the turbine can either be discarded without heat
recovery (simple cycle); recovered with a heat exchanger to preheat combustion air
entering the combustor (regenerative cycle); recovered in a heat recovery steam
generator to raise process steam, with or without supplementary firing
(cogeneration); or recovered, with or without supplementary firing, to raise steam
for a steam turbine Rankine cycle (combined cycle or repowering).
The primary pollutants from gas turbine engines are nitrogen oxides (NOX), carbon
monoxide (CO), and to a lesser extent, volatile organic compounds (VOC). Particulate
matter (PM) is also a primary pollutant for gas turbines using liquid fuels. Nitrogen oxide
formation is strongly dependent on the high temperatures developed in the combustor.
Carbon monoxide, VOC, hazardous air pollutants (HAP), and PM are primarily the result of
incomplete combustion. Trace to low amounts of HAP and sulfur dioxide (SO2) are emitted
from gas turbines. Ash and metallic additives in the fuel may also contribute to PM in the
exhaust. Oxides of sulfur (SOX) will only appear in a significant quantity if heavy oils are
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fired in the turbine. Emissions of sulfur compounds, mainly SO2, are directly related to the
sulfur content of the fuel.
2.2 CEMS Description
A new continuous emissions monitoring system (CEMS) has been installed on the EU #2
exhaust stack. The CEMS configurations include a diluent gas oxygen (O2) analyzer, a
nitrogen oxide (NOx) analyzer, a carbon monoxide (CO) analyzer, and a data acquisition and
handling system (DAHS). Only the analyzers are being replaced; the existing DAHS
remains the same.
The new CEMS analyzers information is presented in Table 2-1.
Table 2-1
CEMS Information
Analyzer Type Manufacturer Model No.Serial No.
EU #2 NOX/O2 Teledyne T200MO2 2125
EU #2 CO Teledyne T300 6545
2.3 Flue Gas Sampling Location
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-2 presents the anticipated
stack measurements and traverse points for the sampling location listed.
Table 2-2
Sampling Location
Sampling
Location
Stack Inside
Diameter
(in.)
Distance from Nearest Disturbance
Number of Traverse
Points
Downstream EPA
“B” (in. / dia.)
Upstream EPA
“A” (in. / dia.)
EU #2
Exhaust Stack 198 1,225.5 / 6.20 574.5 / 2.90
Gaseous: Based on
Results of 3-pt
Stratification Test
Sample location measurements are verified in the field to conform to EPA Method 1.
Acceptable cyclonic flow conditions are confirmed prior to testing using EPA Method 1,
Section 11.4.
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2.4 Operating Conditions and Process Data
Emission tests will be performed while the source/unit and air pollution control devices are
operating at the conditions required by 40 CFR Part 75 (i.e., entirely within the “normal”
load range) and 40 CFR Part 60 (i.e., greater than RIIXOOORDG
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
x Relevant CEMS data
x Unit Load, MW
2.5 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.5.1 Safety Responsibilities
Planning
x Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work.
x We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed.
x The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
x Montrose will provide a list of equipment being brought to the site, if required
by the client.
Project Day
x Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate.
x Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
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x Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection.
x We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area.
x As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
x Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
x Safe sampling platforms.
x Safe access to the platforms and test ports, including any scaffolding or
man lifts.
x Sufficient utilities to perform all necessary testing.
x Montrose will use the client communication system, as directed, in case of
plant or project emergency.
x Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
x Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site.
x Montrose will clean up our work area to the same condition as it was prior to
our arrival.
x We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.5.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
x All regulatory required policies/procedures and training for OSHA, EPA and
FMCSA
x Medical monitoring, as necessary
x Use of Personal Protective Equipment (PPE) and chemical detection equipment
x Hazard communication
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x Pre-test and daily toolbox meetings
x Continued evaluation of work and potential hazards
x Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”.
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3.0 Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Methods 3A, 7E, and 10, Determination of Oxygen,
Nitrogen Oxides, and Carbon Monoxide Concentrations in
Emissions from Stationary Sources (Instrumental Analyzer
Procedure)
Concentrations of O2, NOX, and CO are measured simultaneously using EPA Methods 3A, 7E,
and 10, which are instrumental test methods. Conditioned gas is sent to a series of
analyzers to measure the gaseous emission concentrations. The performance requirements
of the method must be met to validate the data.
Pertinent information regarding the performance of the method is presented below:
x A dry extractive sampling system is used to report emissions on a dry
basis.
x A paramagnetic analyzer is used to measure O2.
x A chemiluminescent analyzer is used to measure NOX.
x A gas filter correlation nondispersive infrared analyzer is used to
measure CO.
x The alternative NOX converter efficiency test described in EPA Method
7E Section 16.2 may be used (bag procedure).
x Anticipated calibration span values are 0-21O2, 0-25 ppmvd NOX,
and 0- 25 ppmvd CO
x Prior to conducting the RATA testing, a stratification traverse of the
effluent gas will be conducted. If the three (3) traverse points
ORFDWHGDQGRIWKHLQVLGHGLDPHWHUWUDYHUVHOLQH
VKRZWKDWWKHHIIOXHQWJDVDWHDFKSRLQWGRHVQRWYHU\E\“
SHUFHQWRIWKHPHDQFRQFHQWUDWLRQRU“SSPZKLFKHYHULVOHVV
restrictive), the gas stream is considered not stratified, and the use of
a single point may be used for sampling.
x Minimum Required Sample Duration: 21 minutes
The typical sampling system is detailed in Figure 3-1.
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Figure 3-1
US EPA Methods 3A, 7E, and 10 Sampling Train
O2 AND/OR CO2
ANALYZER
NOx ANALYZER
Exhaust
Exhaust
CO ANALYZER
Exhaust
SIGNAL
SIGNAL
SIGNAL
Sample / Calibration Gas
Sample / Calibration Gas
Sample / Calibration Gas
DATA
OUTPUT DAS
“ANALYZER” ROTAMETERS WITH FLOW CONTROL VALVES
SAMPLE
CONDITIONING SYSTEM WITH
PUMP
CALIBRATION
GAS LINE
STACKGAS
STACKWALL
HEATED
SAMPLE
LINE
HEATEDFILTER
"SAMPLE” AND “BY-PASS" ROTAMETERS WITH FLOW CONTROL VALVES
THREE WAY VALVE
BY-PASS
“BIAS” ROTAMETER WITH FLOW CONTROL VALVES
EPA ProtocolCalibration Gases MASS FLOW CONTROLLER / CALIBRATION GAS MANIFOLD
3.1.2 EPA Method 19, Determination of Nitrogen Oxide and Carbon
Monoxide Emission Rates
EPA Method 19 is a manual method used to determine NOx and CO emission rates, in units
of lb/hr, from the measurement of the heat input rate, stack concentration of O2, and an F
factor. The metered fuel flow rate is recorded during each test period. Typically, fuel flow
rates are reported in scf/hr or lb/hr.
Pertinent information regarding the performance of the method is presented below:
x F factor is the oxygen-based F factor, dry basis (Fd)
x F factor is the published source-based F factor in EPA Method 19,
Table 19-2
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4.0 Quality Assurance and Reporting
4.1 QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also perform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may perform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.1 Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The “Standard Conditions” for this project are 29.92
inches of mercury and 68 °F.
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4.4 Sample Identification and Custody
No samples are required to be recovered for this test program.
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented limits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Reporting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within
30 days of the completion of the field work. The report will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
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Figure 4-1
Typical Report Format
Cover Page
Certification of Report
Table of Contents
Section
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility CEMS and Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information
4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the results in the
final source test report. Separate tables will outline the results for each CEMS parameter/set
of units and compare them to their respective RA requirements.
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Table 4-1
Example Nitrogen Oxide (ppmvd) RATA Results - Nebo EU #2
Run
No.Date Time RM CEMS Difference
Run used
(Y or N)
Unit Load
(MW)
1 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
2 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
3 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
4 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
5 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
6 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
7 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
8 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
9 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
10 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
11 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
12 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
Averages XX XX XX XX
Applicable Standard (AS)XX ppmvd
Standard Deviation XX ppmvd
Confidence Coefficient (CC)XX ppmvd
Bias Adjustment Factor (BAF)XX
Unit Load XX MW
RA based on mean RM value XX 
RA based on AS XX 
RA based on difference plus CC XX ppmvd
RA based on absolute difference XX ppmvd
18 of 44 GP081AS-046248-PP-922-R1
Utah Association of Municipal Power Systems (UAMPS), Payson, Utah2025 Nebo Power Generating Station EU #2 New CEMS Certification RATA Test Plan
Appendix A
Supporting Information
19 of 44 GP081AS-046248-PP-922-R1
Utah Association of Municipal Power Systems (UAMPS), Payson, Utah2025 Nebo Power Generating Station EU #2 New CEMS Certification RATA Test Plan
Appendix A.1
Units and Abbreviations
20 of 44 GP081AS-046248-PP-922-R1







  
 







 







 







 


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27 of 44 GP081AS-046248-PP-922-R1
Utah Association of Municipal Power Systems (UAMPS), Payson, Utah2025 Nebo Power Generating Station EU #2 New CEMS Certification RATA Test Plan
Appendix A.2
Accreditation Information/Certifications
28 of 44 GP081AS-046248-PP-922-R1
Accredited Air Emission Testing Body
A2LA has accredited
MONTROSE AIR QUALITY SERVICES
In recognition of the successful completion of the joint A2LA and Stack Testing Accreditation Council (STAC)
evaluation process, this laboratory is accredited to perform testing activities in compliance with
ASTM D7036:2004 - Standard Practice for Competence of Air Emission Testing Bodies.
Presented this 27th day of February 2024.
_______________________
Vice President, Accreditation Services
For the Accreditation Council
Certificate Number 3925.01
Valid to February 28, 2026
This accreditation program is not included under the A2LA ILAC Mutual Recognition Arrangement.
American Association for Laboratory Accreditation
29 of 44 GP081AS-046248-PP-922-R1
Utah Association of Municipal Power Systems (UAMPS), Payson, Utah2025 Nebo Power Generating Station EU #2 New CEMS Certification RATA Test Plan
Appendix “S”
Site Specific Safety Plan
30 of 44 GP081AS-046248-PP-922-R1
SITE SAFETY PLAN BOOKLET
Project: _____________________
Customer: ___________________
Location: ____________________
Units: _______________________
Client Project Manager: ______________________
Revision Date:June 29th, 2023
31 of 44 GP081AS-046248-PP-922-R1
PROJ-046248
UAMPS
Payson, Utah
GE Frame 7EA/HRSG Gas-Fired
Cheyney Guymon
Page 1 of 2

Site Safety Plan and JHA Purpose and Instructions

Purpose
Employee safety is the top priority of Montrose Environmental Group. All employees must be
trained to assess and mitigate hazards. The District Manager and Project Manager are
responsible to ensure all hazards have been properly identified and managed. All employees
have Stop Work Authority in all situations where an employee feels they or their co-worker
cannot perform a job safely or if there is a task for which they have not been adequately trained.
The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with
identifying physical and health hazards and determining how the hazards will be managed.
Additionally, the SSP will help each crew manage the safety of the employees by providing
emergency procedures and information. The booklet contains a several safety forms that may
be required in the field.
Instructions
The SSP consists of the following:

communicated to all employees, signed, and posted.
Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed,
CPM will maintain a roster and be responsible for accounting for all employees. The Job
to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/
emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior
the Emergency Action Plan form and ensure that all employees are familiar with the facility
4. Emergency Action Plan -The Job Supervisor/ Client Project Manager (CPM) will complete
observed plus applicable PPE that may be required.
administrative controls that a crew can use to reduce or eliminate the hazards they have
3. Hazard Control Matrix - contains useful information on both engineering and
with the toolbox topic and signatures can be added to the SSP packet.
the hazard analysis is required daily for the duration of the test. An additional sheet of paper
modified when conditions change. A toolbox meeting with a daily topic in addition to a review of
sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be
Each team member has the option to discuss making changes or adding to the JHA and must
Section 9 will require at least three tasks, hazards and controls be identified for the project.
form for accuracy, making any corrections required and complete the remainder of the JHA.
complete the JHA form through section 8. Upon arrival at the test site, the team will review the
daily hazard review with sign off by the team.The client Project Manager is responsible to
task/site’s particular hazards and controls. The form also includes a daily toolbox topic and
2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the
prior to the test.
1. A Pre-Mobilization Test Plan – To be completed in it’s entirety by the client project Manager
AQS-FRM-1.13R1
Extended Hours Formc.
Heat Stress Prevention Form Based on Heat Indexb.
MEWP Lift Inspection Forma.
Additional Forms, as applicable5.
32 of 44 GP081AS-046248-PP-922-R1
Page 2 of 2

Site Safety Plan and JHA Purpose and Instructions

The SSP is a living document. The Project Manager should continually update their SSPs as
new information and conditions change or if new hazards are presented.
Each completed SSP should be maintained with the Test Plan in the office for a period of 3
years. There will be an audit process developed for the Site Safety Plans.

AQS-FRM-1.13R1
33 of 44 GP081AS-046248-PP-922-R1
Page 1 of 2
PRE-MOBILIZATION TEST INFORMATION

Source Type: New Source: ____ Revisit: ____ Prj#/Date/Tech: __________________________
Coal Fired Electric Utility: ____ Ethanol Plant: ____ Chemical Mfg. of _________________________
Cement/Lime Kiln Plant: ____ Specialty Mfg. of: ___________ Other: _______________

Anticipated Effluent Composition – check all that apply and fill in expected concentration in ppm/%

CO NOX SO2 VOC other
If other, explain: _______________________________________________________

Flammable: _______ Toxic: ________ Corrosive: _______ Dust: __________
Engineering Controls to be Implemented:
______________________________________________________________________________________
__________________________________________________________________________________
Additional Safety Equipment Required:
Personal gas monitors: ____
Respiratory Protection:
Half Face____ Full Face____ HEPA Filters____ Supplied Air: _____ (Safety Dept. Approval)
Approximate Flue Gas Temperatures, (F)

below 210 210 to 450 450 to 950 above 950 other
If other, explain: _______________________________________________________
Approximate Duct Pressure, (iwg):

below -3 -3 to +3 +3 to +7 above +7 other
If other, explain: _______________________________________________________

PROJECT NAME/LOCATION: ______________________ PROJECT #: ____________________
TEST DATE: ______________________ PROJECT MANAGER: ___________________
TEST SCOPE: _________________________________________________________________
SITE CONTACT: Name: _____________________ Contact Phone: _________________________
AQS-FRM-1.17
34 of 44 GP081AS-046248-PP-922-R1
X PROJ-039393/5/29/24/CG & JA
Gas-Fired Turbine
< 10 ppm CO; <10 ppm NOx; 15% O2
UAMPS PROJ-046248
May 9, 2025 Cheyney Guymon
New CEMS Certification - GE Frame 7EA/HRSG Gas-Fired Turbine EU #2 RATA
Dave Gammell 801-925-4012
Page 2 of 2
PRE-MOBILIZATION TEST INFORMATION

Sampling Location: Stack Port ____ Duct Port ____
Approximate Sampling Platform Height, (ft)

Effluent Chemical Regulatory Limits

Gas Name Chemical
Formula
Cal OSHA PEL1
(ppm)
Cal OSHA
STEL2
(ppm)
NIOSH REL
TWA3 (ppm)
Cal OSHA
Ceiling
(ppm)
IDLH4
(ppm)
Carbon Monoxide CO 25 200 35 200 1,200
Nitric Oxide NOx 25 ND5 25 ND 100
Sulfur Dioxide SO2 2 5 2 ND 100
Hydrogen Chloride HCl 0.3 2 ND 2 50
Hydrogen Sulfide H2S 10 15 10 (10 min.)C 50 100
California Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) based on an 8-hour shift;
2: Cal OSHA Short-term Exposure Limit (STEL) based on a 15-minute period; 3: National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based
on an 8-hour shift;
4: Immediately Dangerous to Life or Health (IDLH);
5: Not Defined (ND);
C: Ceiling Limit - Maximum allowable human exposure limit for an airborne or gaseous substance, which is not to be exceeded, even momentarily.

Prepared by: Date:
Reviewed by: Date:

______________________________________________________________________________
______________________________________________________________________________
Additional Information:
______________________________________________________________________________
______________________________________________________________________________
Describe how equipment will be mobilized to the sampling location:
Other:_____________________________________________________________________________
Guardrails: ____ Toe plate: ____ Engineered Tie Off Points: ____ Heat Shield: ____
Elevators: ____ Ladders: ____ MEWP Lift: ____ Scaffold: ____ Equipment Hoist: ____
Access and Protection:
If other, explain: _______________________________________________________
below 6 6 to 50 50 to 100 above 100 other
AQS-FRM-1.17
35 of 44 GP081AS-046248-PP-922-R1
X
X
Hoisted or hand carried
Joby Dunmire September 30, 2024
Job Hazard Analysis 1 of 3
1.
Client Rep
Job Preparation
Job Site Walk Through Completed Site Specific Training Complete
Safe Work Permit Received from Client
2.Facility Information/Emergency Preparedness
If non-emergency medical attention is needed, call: AXIOM #: 877-502-9466.
Plant Emergency # Certified First Aid Person:
EMS Location Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
Operational: Yes No
Source Information: (list type):
Stack Gas Temp. (oF)Stack Gas Press. ("H2O)Stack Gas Components:
Stack Gas Inhalation Potential?Yes No If yes, see List of Hazard Chemicals.
3.Error Risk
Time Pressure Remote Work Location > 12 hr shift Working > 8 consecutive days
Lack of procedures Extreme temps, wind >30mph Personal illness/fatigue Vague work guidance
Monotonous Activity First day back after time off Multiple job locations Other:
4.Physical Hazards Hazard Controls
Dust Hazards Dust Mask Goggles Other:
Thermal Burn Hot Gloves Heat Shields Other Protective Clothing:
Electrical Hazards Connections Protected from Elements External GFCI Other:
XP Rating Requirement Intrinsically Safe Requirement
Inadequate Lighting Install Temporary Lighting Headlamps
Slip and Trip Housekeeping Barricade Area Other:
Hand Protection Cut Resistant Gloves Pinch Pts. General Electrical Impact Resistant
Other:
Potential Hazards for Consideration
Secondary Permits Hot Work Confined Space Excavation
Working from Heights Falling objects Fall protection Drop zone protection Platform load ratings
See also Sect. 7 Scaffold inspection Ladder inspection Barricades for equipment
Electrical Exposed wire/connector Verify equipment grounding Arc Flash
Lifting Crane lift plan Rigging inspection Tag lines used Hoists in place
Respiratory Unexpected exposure Chemical Dust (combustible) PEL provided
See also Sect. 8 Cartridges or supplied air available Gas detection equipment
5.Required PPE Hard Hats Safety Glasses Safety Toe Shoe/Boot Hearing Protection Safety Spotter
Hi-Vis Vests Harness/Lanyard*Goggles Personal Monitor Type:
Metatarsal Guards Hot Gloves Face Shield Respirator Type:
Nomex/FRC Other PPE:
Client Contact Name Date
Facility SSP Writer PM
If the heat index is expected to be above 91°, fill out the Heat Stress Prevention Form.
All hazards and mitigation steps must be documented.
If this JHA does not cover all the hazards identified,
use Section 9 to document that information.
AQS-FRM-1.18
36 of 44 GP081AS-046248-PP-922-R1
UAMPS Dave Gammell May 9, 2025
Payson, Utah
Job Hazard Analysis 2 of 3
Additional Work Place Hazards
6.Critical Procedures – check all that apply – *indicates additional form must be completed or collected from client
Heat Stress Prevention* Confined Space* Roof Work Scaffold
Cold Weather Work Hazardous Energy Control* Other:
7.Working From Heights
Fall Protection Fixed Guardrails/Toe boards Fall Prevention PPE Warning Line System
Falling Objects Protection Barricading Netting House Keeping Tethered Tools Catch Blanket or Tarp
Fall Hazard Communication Adjacent/Overhead Workers Contractor Contact Client Contact
8.Other Considerations
Environmental Hazards - Weather Forecast
Heat/Cold Lightning Rain Snow Ice Tornado Wind Speed
Steps for Mitigation:
Electrical Safety Planning
Plant Hook up:110V 220/240V 480V Generator Hard wired into panel
Electrical Classified Area: Yes No Trailer Grounded: Yes No Plug Type
Electrical Hook Up Responsibility:
List of Hazardous Chemicals Other Chemicals:
Acetone Nitric Acid Hydrogen Peroxide Compressed Gases
Hexane Sulfuric Acid Isopropyl Alcohol Flammable Gas
Toluene Hydrochloric Acid Liquid Nitrogen Non-Flammable Gas
H2S Carbon Monoxide
Steps for Mitigation:
Wildlife/Fauna in Area
Poison Ivy Poison Oak Insects: Wildlife:
Personnel w/ known allergies to bees stings or other allergens?Yes No
9.Observed Hazards and Mitigation Steps
Task Potential Hazard(s) Steps for Mitigation
● 11
22
33
● 11
22
33
● 11
22
33
● 11
22
33
Exposure Monitoring
MEWP*
AQS-FRM-1.18
37 of 44 GP081AS-046248-PP-922-R1
Job Hazard Analysis 3 of 3
10.JHA REVIEW: Crew Names & Signatures
11.Daily JHA Meeting & Review
Items to review:
● Change in conditions ● Extended work hours ● Daily Safety Topic
● New workers or contractors ● Occurrence of near misses or injuries
Printed Name Signature
2
Discussion TopicDay
Initialing demonstrates that site conditions and hazards have not changed from the original SSP. If changes did occur, make the
necessary updates to this JHA and add notes as applicable in Section 9.
Initials
9
8
7
6
3
Date Printed Name Signature Date
5
4
11
10
AQS-FRM-1.18
38 of 44 GP081AS-046248-PP-922-R1
1
2
3
4
5
6 Local Hospital/ Clinic Telephone Number:
7
8
9
10
11
12
13
14
15
16
17
MEG Job Supervisor/ CPM's Telephone Number:
Plant's #1 Contact Person's Name:
Plant's #1 Contact Person's Telephone Number:
MEG Job Safety Supervisor's Telephone Number:
Plant's Emergency Telephone Number:
Emergency Ops Radio Channel:
The Fire Extinguisher is Located:
Eye Wash and Safety Shower Location:
The First Aid Kit is Located:
Page 1 of 2
The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation
procedures, assembly/ rally points, alert systems, and signals prior to work commencing. In the event of an emergency situation/
evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/
CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, and posted.
• You must follow the client’s emergency action plan first, and notify your Supervisor immediately.
•If incident is life threatening, CALL 911 IMMEDIATELLY
• If non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466.
EMERGENCY ACTION PLAN FORM
MEG Job Supervisor/ CPM's Name:
MEG Job Safety Supervisor (if applicable):
Evacuation Routes:
Severe Weather Shelter Location:
Plant's #2 Contact Person's Name:
Plant's #2 Contact Person's Telephone Number:
Designated Assembly Point Location:
AQS-FRM-1.11
39 of 44 GP081AS-046248-PP-922-R1
1
2
4
5
Signature: Date: Printed Name: Signature: Date:
EVACUATE:____________________________________;
OTHER:_______________________________________;
Alarm Tones:
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures
Printed Name:
Draw the evacuation and assembly map here
Page 2 of 2
EMERGENCY EVACUATION AND ASSEMBLY MAP
3
Designated Shelter(s) Description:
Designated Assembly Point(s) Description:
YES or NO
Facility Name:
Facility Alarm (Circle):
FIRE:_________________________________________;
CHEMICAL/ GAS:_______________________________;
SHELTER-IN-PLACE:_____________________________;
AQS-FRM-1.11
40 of 44 GP081AS-046248-PP-922-R1

Serial Number:
Make: Rented or Owned:

x Check “Yes” if an item is adequate, operational, and safe.
x Check “No” to indicate that a repair or other corrective action is required prior to use.
x Check “N/A” to indicate “Not Applicable.”
Yes No N/A

܆ ܆ ܆
2. Hydraulic fluid level is sufficient, with the platform fully lowered ܆ ܆ ܆
3. Hydraulic system pressure (see manufacturer specs) is acceptable.
If the pressure is low, determine cause and repair in accordance with accepted procedures
as outlined in service manual.
܆ ܆ ܆
4. Tires and wheel lug nuts (for tightness) ܆ ܆ ܆
5. Hoses and cables (i.e. worn areas or chafing) ܆ ܆ ܆
6. Platform rails and safety gate (no damage present) ܆ ܆ ܆
7. Pivot pins secure ܆ ܆ ܆
8. Welds are not cracked and structural members are not bent or broken ܆ ܆ ܆
9. Warning and instructional labels are legible and secure, and load capacity is clearly marked. ܆ ܆ ܆
10. Manufacturer’s Instruction Manual is present inside the bucket ܆ ܆ ܆
11. Base controls (switches and push buttons) can be properly operated ܆ ܆ ܆
12. Platform conditions are safe (i.e. not slippery) ܆ ܆ ܆
13. Fire extinguisher is present, mounted and fully charged, located inside the bucket ܆ ܆ ܆
14. Headlights, safety strobe light and back-up alarm are functional ܆ ܆ ܆
15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds,
etc.) *Do not operate if winds are 20 mph, unless otherwise specified by manufacturer
recommendations.
܆ ܆ ܆

Operator Name & Signature Location Date

Ground Control Name & Signature Location Date

Harness Inspections:

Printed Name Signature Date

Printed Name Signature Date

Printed Name Signature Date
Daily MEWP Lift Inspection Form
Page 1 of 1
atthe beginning of each shift or following 6 to 8 hours of use.
All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used
MEWP Lift Model #:
loose hoses, etc.) – if something can be easily loosened by hand then it is not sufficient.
1.All MEWP lift components are in working condition (i.e. no loose or missing parts, torn or
Items to be Inspected
AQS-FRM-1.16
41 of 44 GP081AS-046248-PP-922-R1
Page 1 of 1
001AS-SAFETY-FM-3
Extended Hours Safety Audit
Project Number: Date: Time:
When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate
the condition of the crew, and the safety of the work environment.
Permission to proceed into extended work hours must come from a District Manager (DM) or Regional Vice
President (RVP). Technical RVPs can authorize moving forward, if they are in the field or if they are
managing the project.
1.Hold test crew meeting Test crew initials:
The test leader should look for signs of the following in their crews:
x Irritability
x Lack of motivation
x Headaches
x Giddiness
x Fatigue
x Depression
x Reduced alertness, lack of concentration and
memory
The test leader should assess the environmental and hazardous concerns:
x Temperature and weather
x Lighting
x Working from Heights
x Hoisting
x PPE (i.e. respirators, etc.)
x Pollutant concentration in ambient air (SO2,
H2S, ect.)
x Reason for extended hours
x Reason for delay
ƒProduction limitations
x Impending Weather
3.Contact the client
The PM, DM or RVP must discuss with client any identified safety concerns, the client’s needs and
mutually agree on how to proceed. Discussion should also include the appropriate rest period
needed before the next day’s work shift can begin. The DM and/or a RVP must be informed on the
final decision.
Final Outcome:
Approver:
During this time, they can come to an agreement on how to proceed. Itemsto discuss include:
extended work period. If the DM is the acting PM on the job site, they must contact the RVP.
The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the
Notify DM or RVP2.
42 of 44 GP081AS-046248-PP-922-R1
Page 1 of 1

001AS-SAFETY-FM-5

Heat Stress Prevention Form

This form is to be used when the Expected Heat Index is above 91° F, and is to be kept with project
documentation.

Project Manager (PM): Expected High Temp:
Date(s): Expected Heat Index:

1. Review the signs of Heat Exhaustion and Heat Stroke

2. If Heat Index is above 91° F:
x Provide cold water and/or sports drinks to all field staff (avoid caffeinated drinks and energy
drinks which can increase core temperature).
o Bring no less than one gallon of water per employee
x If employee(s) are dehydrated, on blood pressure medication or not acclimated to heat,
ensure they are aware of the heightened risk for heat illness
x Provide cool head bands/vests/etc.
x Have ice available to employees
x Implement work shift rotations and breaks, particularly for employees working in direct
sunlight.
x Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable
temporary structures.
x PM should interview each field staff periodically to evaluate for signs of heat illness

3. If Heat Index is above 103° F:
x Employees must stop for drinks and breaks every hour (about 4 cups/hour)
x Employees are not permitted to work alone for more than one hour at a time without a
break offering shade and drinks
x Employees should wear cool bands and vests if working outside more than one hour at a
time
x PM should interview each field staff every 2 hours to evaluate for signs of heat illness

43 of 44 GP081AS-046248-PP-922-R1
Utah Association of Municipal Power Systems (UAMPS), Payson, Utah2025 Nebo Power Generating Station EU #2 New CEMS Certification RATA Test Plan
This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.
Name: Cheyney Guymon
Title: Field Project Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: [phone]
Name: Beckie Hawkins
Title: District Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: [phone]
44 of 44 GP081AS-046248-PP-922-R1