DAQ-2025-001086

1

DAQC-198-25
Site ID 15545 (B4)
MEMORANDUM

TO: STACK TEST FILE – WASHINGTON CITY CORPORATION – Generation Facility –
Washington County

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Kyle Greenberg, Environmental Scientist

DATE: February 19, 2025

SUBJECT: Sources: Three (3) Caterpillar Natural Gas Engines/Generators
Location: 4250 East Telegraph Street, Washington, Washington County, UT
Contact: Jake Bennett: 435-272-2637
Tester: Montrose Air Quality Services, LLC
Site ID #: 15545
Permit/AO #: DAQE-AN155450001-16, dated January 8, 2016
Subject: Review of Pretest Protocol dated February 14, 2025

On February 18, 2025, DAQ received a protocol for the testing of three (3) Caterpillar Natural Gas
Engines/Generators at the Washington City Corporation Generation Facility in Washington County, UT.
Testing will be performed on April 1-3, 2025, to determine compliance with the emission limits found in
DAQE-AN155450001-16 condition II.B.2.

PROTOCOL CONDITIONS:

1. Method 1 used to determine sample traverses: OK
2. Method 2 used to determine stack gas velocity and volumetric flow rate: OK
3. Method 3A used to determine O2 and CO2 concentrations of the gas stream: OK
4. Method 4 used to determine moisture content: OK
5. Method 7E used to determine NOx emissions: OK
6. Method 10 used to determine CO emissions: OK

DEVIATIONS: None.

CONCLUSION: The protocol appears to be acceptable to determine the emission rates
of NOx and CO.

RECOMMENDATION: It is recommended that the methods proposed in the Pretest Protocol
be accepted in order to determine compliance with the emission limits
of the AO.

ATTACHMENTS: Washington City Corporation’s Pretest Protocol.
4 ' - ) - "
Source Test Protocol for 2025 Compliance
Emissions Testing
Three (3) Caterpillar G3520C Engine/Generators
Washington City Corporation
4250 East Telegraph Street
Washington, Utah 84780
Prepared For:
Washington City Corporation
111 North 100 East
Washington, Utah 84780
Prepared By:
Montrose Air Quality Services, LLC
6823 South 3600 West
Spanish Fork, UT 84660
For Submission To:
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GP081AS-049044-PP-948
Proposed Test Dates: April 1st through 3rd, 2025
Test Plan Submittal Date: February 14th, 2025
Washington City Corporation, Washington, Utah Power Plant 2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
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 14, 2025
Name: Joby Dunmire Title: Reporting QC Specialist III
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: February 14, 2025
Name: Beckie Hawkins Title: District Manager
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Washington City Corporation, Washington, Utah Power Plant 2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol

Table of Contents
Section Page
1.0Introduction ........................................................................................................ 5
1.1Summary of Test Program ............................................................................. 5
1.2Applicable Regulations and Emission Limits ...................................................... 6
1.3Key Personnel .............................................................................................. 7
2.0Plant and Sampling Location Descriptions................................................................ 8
2.1Process Description, Operation, and Control Equipment ..................................... 8
2.2Flue Gas Sampling Locations .......................................................................... 8
2.3Operating Conditions and Process Data ........................................................... 8
2.4Plant Safety ................................................................................................. 9
2.4.1Safety Responsibilities .......................................................................... 9
2.4.2Safety Program and Requirements ....................................................... 10
3.0Sampling and Analytical Procedures ..................................................................... 11
3.1Test Methods ............................................................................................. 11
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary Sources ...... 11
3.1.2 EPA Method 2, Determination of Stack Gas Velocity and Volumetric Flow
Rate (Type S Pitot Tube) .................................................................... 11
3.1.3 EPA Method 4, Determination of Moisture Content in Stack Gas ............... 12
3.1.4 EPA Methods 3A, 7E, and 10, Determination of Oxygen, Carbon Dioxide,
Nitrogen Oxides, and Carbon Monoxide Concentrations in Emissions from
Stationary Sources (Instrumental Analyzer Procedures) ......................... 14
3.2Process Test Methods .................................................................................. 15
4.0Quality Assurance and Reporting .......................................................................... 16
4.1QA Audits .................................................................................................. 16
4.2Quality Control Procedures .......................................................................... 16
4.2.1Equipment Inspection and Maintenance ................................................ 16
4.2.2Audit Samples ................................................................................... 16
4.3Data Analysis and Validation ........................................................................ 16
4.4Quality Statement ...................................................................................... 17
4.5Reporting .................................................................................................. 17
4.5.1Example Report Format ...................................................................... 17
4.5.2Example Presentation of Test Results ................................................... 18

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List of Appendices
A Supporting Information ...................................................................................... 20
A.1 UDEQ Permits ........................................................................................... 21
A.2 Accreditation Information ........................................................................... 29
“S” Field Work Safety Plan ....................................................................................... 31
List of Tables
1-1 Summary of Test Program and Proposed Schedule .................................................. 5
1-2 Reporting Units and Emission Limits ...................................................................... 6
1-3 Test Personnel and Responsibilities ....................................................................... 7
2-1 Sampling Locations ............................................................................................. 8
4-1 Example Emissions Results ................................................................................. 19
List of Figures
3-1 US EPA Methods 1, 2, and 4 Sampling Train .......................................................... 13
3-2US EPA Methods 3A, 7E and 10 Sampling Train...................................................... 15
4-1Typical Report Format ........................................................................................ 18
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Washington City Corporation, Washington, Utah Power Plant 2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
1.0 Introduction
1.1 Summary of Test Program
Washington City Corporation contracted Montrose Air Quality Services, LLC (Montrose) to
perform a compliance emissions test program on sources listed in Table 1-1 at their power
plant located in Washington, Utah.
The tests are being conducted to determine compliance with the applicable emission limits
listed in Sections II.B.2.a, II.B.2.b, and II.B.2.c of the facility’s Approval Order DAQE-
AN155450001-16, issued by the Utah Department of Environmental Quality (UDEQ).
The specific objectives are to:
x Determine the concentrations of NOX and CO in emissions from the exhaust of
natural gas-fired Caterpillar G3520C Engine #1.
x Determine the concentrations of NOX and CO in emissions from the exhaust of
natural gas-fired Caterpillar G3520C Engine #2.
x Determine the concentrations of NOX and CO in emissions from the exhaust of
natural gas-fired Caterpillar G3520C Engine #3.
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 Schedule1
Proposed
Test Dates
Unit ID/
Source Name Activity/Parameters Test Methods
No. of
Runs
Duration
(Minutes)
April 1-3,
2025
CAT G3520C
Engine #1
Perform testing for
NOX and CO
EPA 1, 2, 3A,
4, 7E, and 10 3 ~60
minutes
CAT G3520C
Engine #2
Perform testing for
NOX and CO
EPA 1, 2, 3A,
4, 7E, and 10 3 ~60
minutes
CAT G3520C
Engine #3
Perform testing for
NOX and CO
EPA 1, 2, 3A,
4, 7E, and 10 3 ~60
minutes
1 The test schedule is subject to change, based on process operation and availability.
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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.
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 reporting units and emission limits, which are
taken from the Title V operating permit are presented in Table 1-2.
Table 1-2
Reporting Units and Emission Limits
Unit ID/
Source Name Parameter Reporting Units Emission Limit
Emission Limit
Reference2
CAT G3520C
Engine #1
NOx and CO tons per year 30.6
UDEQ AO DAQE-
AN155450001-
16, §IIB.2.a(1)
and §IIB.2.a(2)
CAT G3520C
Engine #2
CAT G3520C
Engine #3
2 The emission limit is a combined limit for all three engines.
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Washington City Corporation, Washington, Utah Power Plant 2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: Washington City Corporation
4250 East Telegraph Street
Washington, Utah 84780
Contact: Jake Bennett
Role: Environmental Manager
Telephone: [phone]
Email: [e-mail]
Agency Information
Regulatory Agency: Utah Department of Environmental Quality, Division of Air Quality
Agency Contact: Chad Gilgen
Telephone: [phone]
Email: [e-mail]
Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Beckie Hawkins Cheyney Guymon
Title: District Manager Field Project Manager
Telephone: [phone] [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
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
2.0 Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Washington City Power operates a power generation facility in Washington, Utah. The
power is generated using three (3) Caterpillar 2055 kW natural-gas fired internal
combustion engine/generators, which in turn emit pollutants into the atmosphere. This
facility can generate power for its own customer use, or for use by other members of
UAMPS.
2.2 Flue Gas Sampling Locations
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 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Locations
Sampling
Location
Stack Inside
Diameter
(in.)
Distance from Nearest Disturbance Number of Traverse
PointsDownstream EPA
“B” (in./dia.)
Upstream EPA
“A” (in./dia.)
CAT G3520C
Engine #1 19.5 180/9.2 120/6.2 Volumetric Flow Rate:
16 (8/port)
CAT G3520C
Engine #2 19.5 180/9.2 120/6.2 Volumetric Flow Rate:
16 (8/port)
CAT G3520C
Engine #3 19.5 180/9.2 120/6.2 Volumetric Flow Rate:
16 (8/port)
Sample locations 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.
2.3 Operating Conditions and Process Data
Emission tests are performed while the sources/units and air pollution control devices are
operating at representative conditions. As per UDEQ AO DAQE-AN155450001-16, §II.B.2.f,
“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. [40 CFR Part 60, R307-150, R307-401]”
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
x Engine load, brake horsepower (bhp) or kilowatts (kW)
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
2.4 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.
2.4.1 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.
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:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms.
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Washington City Corporation, Washington, Utah Power Plant
2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
o Safe access to the platforms and test ports, including any scaffolding or
man lifts.
o Sufficient utilities to perform all necessary testing.
o A diesel generator will provide power as requested by site manager.
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.
2.4.2 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
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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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
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 Method 1, Sample and Velocity Traverses for Stationary
Sources
EPA Method 1 is used to assure that representative measurements of volumetric flow rate
are obtained by dividing the cross-section of the stack or duct into equal areas, and then
locating a traverse point within each of the equal areas. Acceptable sample locations must
be located at least two stack or duct equivalent diameters downstream from a flow
disturbance and one-half equivalent diameter upstream from a flow disturbance.
3.1.2 EPA Method 2, Determination of Stack Gas Velocity and
Volumetric Flow Rate (Type S Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA
Method 1. The molecular weight of the gas stream is determined from independent
measurements of O2, CO2, and moisture. The stack gas volumetric flow rate is calculated
using the measured average velocity head, the area of the duct at the measurement plane,
the measured average temperature, the measured duct static pressure, the molecular
weight of the gas stream, and the measured moisture.
Pertinent information regarding the performance of the method is presented below:
x Method Options:
o S-type pitot tube coefficient is 0.84
o Shortridge multimeter may be used to measure velocity
o A dry molecular weight of 30.0 lb/lb-mole may be used to calculate gas
volumetric flow rate for combustion sources.
The sampling apparatus is detailed in Figure 3-1.
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Washington City Corporation, Washington, Utah Power Plant
2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
3.1.3 EPA Method 4, Determination of Moisture Content in Stack
Gas
EPA Method 4 is used to measure the moisture content of gas streams. Gas is sampled
through a probe and impinger train. Moisture is removed using a series of pre-weighed
impingers containing methodology-specific liquids and silica gel immersed in an ice water
bath. The impingers are weighed after each run to determine the percent moisture.
Pertinent information regarding the performance of the method is presented below:
o Condensed water is measured gravimetrically.
o Since it is theoretically impossible for measured moisture to be higher
than psychrometric moisture, the psychrometric moisture is also
calculated, and the lower moisture value is used in the calculations.
o Minimum Required Sample Volume: 21 scf
o Method Options:
o EPA Approved Alternative Method 009 (ALT-009) is used as an
alternative to a two-point post-test meter box calibration. This
procedure uses a calculation to check the meter box calibration
factor rather than requiring a physical post-test meter box
calibration using a standard dry gas meter. The average calculated
meter box percent (%) error must result in a percent error within
±5% of Y. If not, a full calibration is performed, and the results are
presented using the Y factor that yields the highest emissions.
o EPA Approved Alternative Method 011 (ALT-011) is used as an
alternative to the EPA Method 2 two-point thermocouple
calibration. This procedure involves a single-point in-field check
using a reference thermometer to confirm that the thermocouple
system is operating properly. The temperatures of the
thermocouple and reference thermometers shall agree to within ±2
°F.
The typical sampling system is detailed in Figure 3-1.
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Figure 3-1
US EPA Methods 1, 2, and 4 Sampling Train
MANOMETER
BY-PASS VALVE
(fine adjust)
AIR TIGHT
PUMP
VACUUM GAUGE
MAIN
VALVE
(coarse adjust)
THERMOCOUPLES
DRY GAS
METER
ORIFICE
GAS
EXIT
VACUUM
LINE
VACUUM
LINE
ADAPTOR
ICE
BATH
100 mL
CONDENSING
REAGENT
(standard tip)
100 mL
CONDENSING
REAGENT
(modified/no tip)
Empty
(modified/no tip)200-300g
Silica Gel
(modified/no tip)
THERMOCOUPLE
SAMPLE LINE
PROBE
MANOMETER
THERMOCOUPLE
TYPE “S”
PITOT
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
3.1.4 EPA Methods 3A, 7E, and 10, Determination of Oxygen,
Carbon Dioxide, Nitrogen Oxides, and Carbon Monoxide
Concentrations in Emissions from Stationary Sources
(Instrumental Analyzer Procedures)
Concentrations of O2, CO2, 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 may be used to report emissions on a dry
basis.
x Sampling may be performed using a dilution probe.
x A paramagnetic analyzer is used to measure O2.
x A nondispersive infrared analyzer is used to measure CO2.
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 .
x Minimum Required Sample Duration: 60 minutes
The typical sampling system is detailed in Figure 3-2.
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Figure 3-2
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
STACK
GAS
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 Protocol
Calibration Gases
MASS FLOW CONTROLLER /
CALIBRATION GAS MANIFOLD
3.2 Process Test Methods
The applicable regulations do not require process samples to be collected during this test
program.
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
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 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).
4.5 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
60 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.
4.5.1 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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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
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 Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information
4.5.2 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 target analyte and
compare them to their respective emissions limits.
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Washington City Corporation, Washington, Utah Power Plant
2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Table 4-1
Example Emissions Results
Parameter/Units Run 1 Run 2 Run 3 Average
Date XX XX XX
Time XX XX XX
Sampling & Flue Gas Parameters
sample duration, minutes XX XX XX XX
O2, % volume dry XX XX XX XX
CO2, % volume dry XX XX XX XX
flue gas temperature, °F XX XX XX XX
moisture content, % volume XX XX XX XX
volumetric flow rate, dscfm XX XX XX XX
Nitrogen Oxides (NOX) Emissions
ppmvd XX XX XX XX
lb/hr XX XX XX XX
g/kW-hr (and/or g/bhp-hr) XX XX XX XX
tons per year (ton/yr)XX XX XX XX
Carbon Monoxide (CO) Emissions
ppmvd XX XX XX XX
lb/hr XX XX XX XX
g/kW-hr (and/or g/bhp-hr) XX XX XX XX
tons per year (ton/yr)XX XX XX XX
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Appendix A
Supporting Information
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Appendix A.1
UDEQ Permit
21 of 45 GP081AS-049044-PP-94821 of 45 GP081AS-049044-PP-948
DAQE-AN155450001-16
January 8, 2016
Kelly Carlson
Washington City Corporation
111 North 100 East
Washington, UT 84780
Dear Mr. Carlson:
Re: Approval Order: Separation of DAQE-AN124160010-13 into Two Sources
Project Number: N15545-0001
The attached document is the Approval Order for the above-referenced project. Future correspondence
on this Approval Order should include the engineer's name as well as the DAQE number as shown on the
upper right-hand corner of this letter. The project engineer for this action is John Jenks, who may be
reached at [phone].
Sincerely,
Bryce C. Bird
Director
BCB:JJ:jc
cc: Southwest Utah Public Health Department
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
22 of 45 GP081AS-049044-PP-94822 of 45 GP081AS-049044-PP-948
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
APPROVAL ORDER: Separation of DAQE-AN124160010-13 into
Two Sources
Prepared By: John Jenks, Engineer
Phone: [phone]
Email: [e-mail]
APPROVAL ORDER NUMBER
DAQE-AN155450001-16
Date: January 8, 2016
Washington City Corporation
Generation Facility
Source Contact:
Kelly Carlson, Director
Phone: [phone]
Email: [e-mail]
Bryce C. Bird
Director
23 of 45 GP081AS-049044-PP-94823 of 45 GP081AS-049044-PP-948

Abstract

On September 8, 2015, the City of Hurricane submitted a request to separate its existing AO, DAQE-
AN124160010-13, into two sources. The City of Hurricane would hold the AO for and be responsible for
only the generation equipment located in and owned by the City of Hurricane.

On September 22, 2015, UDAQ received confirmation from Washington City. In its confirmation letter,
Washington City agreed that it would become holder of the AO for and responsible for the remaining
generation equipment. This equipment being located in and owned by Washington City.

The Washington City subsite was added in 2013 as part of the City of Hurricane's existing AO. At the
time this was a minor modification to an existing minor source. Although merely a change in ownership
of this previously permitted equipment, Washington City has requested a change in permitted emissions
of CO based on the listed emission factor used in the calculation. UDAQ agrees with this increase;
however, the increase subjects the change to public review and comment as a modification. There is no
change in control equipment (BACT), equipment location, fuel type, potential use or load, or other
assumptions such as stack height has been made as a result of this administrative change to the permit.
This permitting action represents the creation of the new Washington City source and site, consisting of
the equipment formerly listed under the Washington City Subsite in DAQE-AN124160010-13.

One minor typographical error has been corrected. A monitoring system previously mislabeled as
"Scandia" has now been correctly listed as "SCADA" in the equipment list and requirements. This site is
subject to the provisions of 40 CFR 60 Subpart JJJJ and 40 CFR 63 Subpart ZZZZ.

As a result of the AO separation, this new source's PTE becomes equal to that of the modification
authorized in 2013. Total emissions for this source in tons per year (tpy) are as follows: PM10 1.8, PM2.5
(a subset of PM10) 1.8, NOx 30.6, SO2 0.2, CO 30.6, VOC 5.5 and HAPs 5.1. This source is minor for
GHG emissions at 1,133 tpy as CO2e.

This air quality AO authorizes the project with the following conditions and failure to comply with any of
the conditions may constitute a violation of this order. This AO is issued to, and applies to the following:

Name of Permittee:

Washington City Corporation
111 North 100 East
Washington, UT 84780
Permitted Location:

Washington City Corporation-Washington City
Generation Facility
4250 East Telegraph Street
Washington, UT 84780

UTM coordinates: 283400.98 m Easting, 4114839.41 m Northing, UTM Zone 12
SIC code: 4911 (Electric Services)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
24 of 45 GP081AS-049044-PP-94824 of 45 GP081AS-049044-PP-948
DAQE-AN155450001-16
Page 3

request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All maintenance
performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and
Monitoring. [R307-150]

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Washington City Generation Facility

II.A.2 Three (3) Natural Gas-Fired Generator Sets
Site:Washington Generation Station
Manufacturer: Caterpillar
Rating: 2889 bhp (2055 kW) each
Model: Lean Burn w/ Oxidation Catalyst
Stack Height: 35 feet from the base of the building

II.B Requirements and Limitations

II.B.1 Conditions on Permitted Source

II.B.1.a Visible emissions from all natural gas fired engines shall not exceed 10% opacity. Opacity
observations of emissions from stationary sources shall be conducted according to 40 CFR 60,
Appendix A, Method 9. [R307-401-8]

II.B.1.b Natural gas-fired generators are each limited to 4500 hours per rolling 12-month period.
Operating time shall be kept on a daily basis by recording results from the hour meter on the
engine in a log book. [R307-401-8]

II.B.1.c The owner/operator shall check the SCADA performance monitor system monthly or every
500 hours, whichever comes first. All settings shall be recorded and the records shall be
maintained. [R307-150-1(5)((a)), R307-401-8(1)((a))]

II.B.2 Emission Limitations and Stack Testing Requirements

II.B.2.a 1. Combined emissions of NOx from the three (3) natural gas-fired engines shall not
exceed 30.6 tons per rolling 12-month period.

2. Combined emissions of CO from the three (3) natural gas-fired engines shall not
exceed 30.6 tons per rolling 12-month period. [R307-401-8]

II.B.2.b To determine compliance with a rolling 12-month total the owner/operator shall calculate a
25 of 45 GP081AS-049044-PP-94825 of 45 GP081AS-049044-PP-948
DAQE-AN155450001-16
Page 4

new 12-month total by the twentieth day of each month using data from the previous 12
months. Records of consumption/production shall be kept for all periods when the plant is in
operation. The records of emissions shall be kept on a daily basis. Hours of operation shall be
determined by supervisor monitoring and maintaining of an operations log. [R307-401]

II.B.2.c NOx and CO emissions calculations for the entire plant shall be calculated as follows:

Monthly Emissions Rate Calculation:
M=(hrs of operation/month) x (Engine kW produced) x [(EF* g/kW-hr)/(453.6 g/lb)]

Annual Emissions Rate Calculation:
A=(Sum: M) (1ton/2000lbs)

*Average hourly emissions factors for NOx or CO for each engine shall be the value from the
latest engine test results. For the period prior to the emission testing, the following emissions
factors (EF) shall be used:

1 g/kW-hr for NOx, and 1 g/kW-hr for CO

Emissions totals from three (3) natural gas-fired engines should be kept in table format, listing:
month, operating hours, and emissions, for each individual engine. [R307-401]

II.B.2.d Stack testing to show compliance with the NOx and CO emission limitations shall be
performed within the next five years of the most recent stack test for each generator and then
every five years thereafter. The Director may require testing at any time. [R307-165]

II.B.2.e At least 30 days prior to conducting any emission testing required under any part of UAC,
R307, the owner or operator shall notify the Director of the date, time and place of such testing
and, if determined necessary by the Director, the owner or operator shall attend a pretest
conference. 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 Director prior to
performing the test(s). The source test protocol shall outline the proposed test methodologies,
stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by
the Director. The pretest conference shall include representation from the owner/operator, the
tester, and the Director. The emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other methods as approved by 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. [R307-165]

II.B.2.f NOx:
The measurement method will follow Appendix A, Method 7, 7A, 7B, 7C, 7D or 7E or as
outlined in the test protocol.

CO:
The measurement method will follow Appendix A, Method 10.

The volumetric flow rate will be determined from Appendix A, Method 2.

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.

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. [40
CFR 60, R307-150, R307-401]

26 of 45 GP081AS-049044-PP-94826 of 45 GP081AS-049044-PP-948
DAQE-AN155450001-16
Page 5
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.
NSPS (Part 60), A: General Provisions
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source
PERMIT HISTORY
This AO is based on the following documents:
Is Derived From Source Submitted NOI dated September 8, 2015
Incorporates Additional Information Received dated September 22, 2015
ADMINISTRATIVE CODING
The following information is for UDAQ internal classification use only:
Washington County
CDS B
MACT (Part 63), Title V (Part 70) Area Source, Attainment Area, NSPS (Part 60)
27 of 45 GP081AS-049044-PP-94827 of 45 GP081AS-049044-PP-948
DAQE-AN155450001-16
Page 6
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
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Washington City Corporation, Washington, Utah Power Plant
2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Appendix A.2
Accreditation Information
29 of 45 GP081AS-049044-PP-94829 of 45 GP081AS-049044-PP-948
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
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2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
Appendix “S”
Field Work Safety Plan
31 of 45 GP081AS-049044-PP-94831 of 45 GP081AS-049044-PP-948
SITE SAFETY PLAN BOOKLET
Project: _____________________
Customer: ___________________
Location: ____________________
Units: _______________________
Client Project Manager: ______________________
Revision Date:June 29th, 2023
32 of 45 GP081AS-049044-PP-948
PROJ-049044
Washington City Corporatio
Washington, Utah
CAT G3520C Engines #1, #2, #3
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.
33 of 45 GP081AS-049044-PP-948
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
34 of 45 GP081AS-049044-PP-948
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
35 of 45 GP081AS-049044-PP-948
X PROJ-015268/Apr. 5,6, 19, 2022C. Guymon
ICEs
0-25 ppm CO; 0-500 ppm NOx
Washington City Corporation PROJ-049044
April 1st, 2nd, 3rd, 2025 Cheyney Guymon
NOx, CO Testing on Three (3) CAT G3520C Engines
Jake Bennett [phone]
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
36 of 45 GP081AS-049044-PP-948
X
X
Hoisted or hand carried
Joby Dunmire January 6, 2025
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
37 of 45 GP081AS-049044-PP-948
Washington City Corporation
Joby Dunmire
Jake Bennett April1,2,3,2025
Cheyney Guymon
WCC Power Plant, Washington, UT
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
38 of 45 GP081AS-049044-PP-948
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
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2
3
4
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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
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1
2
4
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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
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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
42 of 45 GP081AS-049044-PP-948
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.
43 of 45 GP081AS-049044-PP-948
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

44 of 45 GP081AS-049044-PP-948
Washington City Corporation, Washington, Utah Power Plant
2025 Three (3) CATG 3520C Engine/Generators Source Test Protocol
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: Beckie Hawkins
Title: District Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: [phone]
Name: Cheyney Guymon
Title: Client Project Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: [phone]
45 of 45 GP081AS-049044-PP-94845 of 45 GP081AS-049044-PP-948