HomeMy WebLinkAboutDAQ-2025-0013381
DAQC-230-25
Site ID 10884 (B1)
MEMORANDUM
TO: FILE – HEBER LIGHT & POWER COMPANY
THROUGH: Harold Burge, Major Source Compliance Section Manager
FROM: Robert Haynes, Environmental Scientist III
DATE: February 28, 2025
SUBJECT: FULL COMPLIANCE EVALUATION, SM80, Wasatch County,
FRS # UT0000004905100006
INSPECTION DATE: February 27, 2025
SOURCE LOCATION: 735 West 300 South, Heber City, UT 84032
SOURCE CONTACT(S): Jason Norlen - General Manager
435-654-2913, jnorlen@heberpower.com
Emily Brandt - Energy Resource Manager
435-671-0662, ebrandt@heberpower.com
OPERATING STATUS: Operational-plant on standby
PROCESS DESCRIPTION: Heber Light and Power operates an electric power
generation plant in Heber. The source uses internal
combustion natural gas and diesel fuel engines to power
generators that produce electricity. These generators are
only operated during hours of peak demand and
emergency episodes. All power generated at the source
is sold directly to the existing power grid. All generators
are operated on a test run basis at least once per week for
about an hour. Generators operate at full load any time
they are needed. All generator parameters are monitoring
in real-time and logged in the control room database.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN108840013-24
(dated January 29, 2024)
SOURCE EVALUATION:
Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
Status: This is a statement of fact.
2
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
Status: In compliance. No limits appear to have been exceeded.
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
Status: In compliance. No modifications have been made to equipment or processes.
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request,
and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
Status: In compliance. All requested records were made available at the time of inspection
or in a follow-up email. Records are maintained for the appropriate time.
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]
Status: In compliance. Records confirm compliance for this inspection cycle.
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
Status: In compliance. Heber confirmed that no breakdowns or opacity exceedances
occurred since prior to the last inspection.
I.7 The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and Monitoring. [R307-150]
Status: In compliance. Emission inventories are due April 15 of each year following the
calendar year an inventory is required. The 2023 inventory was submitted on May 9, 2024,
due to the employee responsible for this task leaving the company prior to submission.
Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Plant Wide Power Plant II.A.2 Engine Generator Manufacturer Caterpillar Maximum output rating 1350 kW Fuel type Natural gas CO Emissions control Oxidation catalyst
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II.A.3 Engine Generator Manufacturer Caterpillar
Maximum output rating 1350 kW
Fuel type Natural gas CO Emissions control Oxidation catalyst
II.A.4 Engine Generator Manufacturer Caterpillar
Maximum output rating 1850 kW
Fuel type Natural gas CO Emissions control Oxidation catalyst
II.A.5 Engine Generator (NEW) Manufacturer Caterpillar
Maximum output rating 1550 kW
Fuel type Natural gas
II.A.6 Engine Generator
Manufacturer Caterpillar
Maximum output rating 1850 kW
Fuel type Natural gas
CO Emissions control Oxidation catalyst
II.A.7 Engine Generator
Manufacturer Caterpillar
Maximum output rating 1850 kW
Fuel type Natural gas
CO Emissions control Oxidation catalyst
II.A.8 Engine Generator
Manufacturer Caterpillar
Maximum output rating 1750 kW
Fuel type Natural gas
CO Emissions control Oxidation Catalyst
II.A.9 Engine Generator
Manufacturer Caterpillar
Maximum output rating 2200 kW
Fuel type Natural gas
CO Emissions control Oxidation catalyst and SCR
II.A.10 Engine Generator (NEW)
Manufacturer Caterpillar
Maximum output rating 2631 kW
Fuel type Natural gas
CO Emissions control Oxidation catalyst and SCR
II.A.11 Engine Generator (NEW)
Manufacturer Caterpillar
Maximum output rating 2550 kW
Fuel type Natural gas
CO Emissions control Oxidation catalyst and SCR
II.A.12 Research and Development Engines
Various Diesel and Natural Gas Engines
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II.A.13 Backup Emergency Generators (2) 1. Maximum Rating: 60 kW, Fuel: Diesel
2. Maximum Rating: 80 kW, Fuel: Diesel
II.A.14 Various Portable Engines
Maximum rating: 50 kW each
Included for informational purposes
Status: In compliance. II.A.3 is no longer at the facility. II.A.4 is not yet installed (anticipate
installation April or May of 2025). II.A.12 and II.14 do not currently have any on location.
II.B Requirements and Limitations
II.B.1 Limitation and Test Procedures
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points shall not exceed the following values:
A. All diesel fired engines - 20% opacity
B. All natural gas fired engines - 10% opacity
[R307-201, R307-401-8]
Status: In compliance. No visible emissions have been reported.
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
Status: This is a statement of fact.
II.B.1.b The owner/operator shall not exceed to following operational hours per rolling 12-month period,
from each unit as designated below: Unit #1, and #2 4,000 hours combined
Unit #4, 7, and 8 7,800 hours combined
Unit #5 5,200 hours Unit #11 5,200 hours
Unit #12, 13, 14 15,600 hours combined
R&D NG Engine 8,000 hours combined Diesel R&D 5,000 hours combined
“combined” refers to the sum of hours amongst all units within an engine group, as listed above.
[R307-401-8]
Status: In compliance. The 12 month rolling totals ending January 21, 2025 are:
Unit #1, and 2 1,155 hours combined
Unit #4, 7, and 8 1,438 hours combined
Unit #5 2,188 hours
Unit #11 2,310 hours
Unit #12, 13, and 14 7,672 hours combined
R&D NG Engine 0 hours combined (None installed over the past 12 months)
Diesel R&D 0 hours combined (None installed over the past 12 months)
II.B.1.c The owner/operator shall maintain a log recording each unit's operational hours. The log shall
include the unit name and hours operated per month. The owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months.
[R307-401-8]
Status: In compliance. Records confirm compliance.
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II.B.1.d There shall not be more than six (6) R&D generators installed at the Heber Power Plant site. A report shall be submitted to DAQ before the engine generators are installed. The report shall
include the manufactures expected emission levels, the expected hours of operation and the
length of time that the engines will be operating. The following conditions shall apply to the R&D engine generators:
A. The engine generators shall have not been manufactured more than 24-months prior
to installation. B. An engine generator shall not exceed 24-months of operation.
[R307-401-8]
Status: In compliance. No R&D generators were installed.
II.B.1.d.1 A report describing the results of the test operations of each engine generator tested shall be submitted to the Director, attention New Source Review Section, within 45 days after the engine
generator has finished operating. The report, at a minimum, shall include the hp and kW rating,
power produced, pollution control equipment used on the engine generator, total hours of
operation on the engine, the power produced, NOx and CO emissions measured, and a summary
of the emissions testing results along with calculated factors. [R307-401-8]
Status: This condition is reviewed by the DAQ NSR Section.
II.B.1.e The owner/operator shall ensure that each engine listed under II.A.2 - II.A.12 vents exhaust gases
vertically unrestricted with an attached stack height of no less than 53' feet. All stacks shall be
installed within 18-months of the issuance of this AO and comply with condition I.8 of this AO.
[R307-401-8, R307-410-4]
Status: In compliance. All constructed stacks are at least 53 feet in height.
II.B.2 Stack Testing Requirements
II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from the
following units:
Location Pollutant lb/hr
Unit #1 NOx 4.06
CO 1.0
Unit #2 NOx 4.06
CO 1.0
Unit #4 NOx 5.35
CO 1.0
Unit #5 NOx 3.00
CO 1.0
Unit #7 NOx 5.35
CO 1.0
Unit #8 NOx 5.35
CO 1.0
NG R&D Units (Each) NOx 5.50
CO 1.0
Diesel R&D NOx 2.5
CO 1.0
Unit #11 3516H NOx 4.75
CO 1.0
Unit #12 3520H NOx 0.54
CO 1.0
Unit #13 3520DSL NOx 0.54
CO 1.0
Unit #14 NOx 0.54
CO 1.0
[R307-401-8]
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II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]
II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]
II.B.2.b.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]
II.B.2.b.2 Test Frequency
The owner/operator shall conduct a stack test on each emission unit within whichever of the
following parameters occurs first; 3 years or 8,760 hours of unit operation after the date of the
most recent stack test of each listed emission unit. The Director may require the owner/operator
to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.2.b.3 Initial Test
The owner/operator shall conduct an initial stack test on Unit #14 within 180 days after startup of
each emission unit. [R307-165-2]
II.B.2.b.4 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.2.b.5 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]
II.B.2.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]
II.B.2.c.1 Standard Conditions
A. Temperature - 68 °F (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.2.c.2 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]
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II.B.2.c.3 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]
Status: In compliance. Stack test results are summarized below:
Unit DAQC # Test Date Pollutant DAQ Results
(lb/hr)
Test Results
(lb/hr)
Limit
(lb/hr)
1 C-1043-24 8/20/2024 NOX 3.30 3.3 4.06
5 C-202-23 12/8/2022 NOX 1.96 1.961 2.39
7 C-008-25 11/26/2024 NOX 4.37 4.37 5.35
8 C-1043-24 8/21/2024 NOX 3.23 3.2 5.35
11 C-745-24 6/6/2024 NOX 4.53 4.53 4.75
12 C-745-24 6/5/2024 NOX 0.12 0.12 0.54
13 C-202-23 11/6/2022 NOX 6.10 6.084 6.78
14 C-745-24 6/4/2024 NOX 0.039 0.039 0.54
1 C-1043-24 8/20/2024 CO 0.05 0.048 1.0
5 C-202-23 12/8/2022 CO 0.208 0.205 0.3
7 C-008-25 11/26/2024 CO 0.05 0.048 1.0
8 C-1043-24 8/21/2024 CO 0.07 0.071 1.0
11 C-745-24 6/6/2024 CO 0.064 0.064 1.0
12 C-745-24 6/5/2024 CO 0.47 0.47 1.0
13 C-202-23 11/6/2022 CO 0.24 0.241 0.3
14 C-745-24 6/4/2024 CO 0.41 0.41 1.0
II.B.3 Monitoring
II.B.3.a The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the temperature of each oxidation catalyst. The monitoring device shall be accurate within plus or minus 25 degrees Fahrenheit. The temperature shall not exceed 1300 degrees Fahrenheit. Continuous recording for the monitoring device is not required. However, daily records of readings shall be maintained. [R307-401-8] Status: In compliance. The source has installed continuous recording devices on all Caterpillar generators. The source conducts regular maintenance to ensure the monitoring devices are accurate. The source indicated the generators are equipped with an auto-shutoff function that engages when catalyst temperature reaches 1,250 °F. Oxidation catalysts and temperature monitors were installed to meet 40 CFR 63 Subpart ZZZZ. Temperature logs were observed on the computer to confirm compliance. II.B.4 Emergency Engine Requirements
II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ] Status: In compliance. Records are kept and confirm compliance.
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II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following: a. The date the emergency engine was used
b. The duration of operation in hours
c. The reason for the emergency engine usage [R307-401-8, 40 CFR 63 Subpart ZZZZ]
Status: In compliance. A spreadsheet was used to log hours and was available for review.
II.B.4.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each emergency engine. [R307-401-8]
Status: In compliance. Checked latest receipts to confirm diesel fuel meets the listed
standard are used as fuel in the engines.
II.B.4.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
Status: In compliance. It was confirmed that only ULSD is used in the engines.
II.B.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]
Status: In compliance. Records are maintained that confirm compliance.
EMISSION INVENTORY: 2023 emission inventory (Received May 9, 2024):
Pollutants Tons/Year
PM10 1.25
PM2.5 1.25
SOX 0.07
NOx 29.3
VOC 14.7
CO 0.74
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: The source is considered in compliance with the conditions of
Approval Order DAQE-AN108840013-24, dated January 29,
2024, at the time of inspection.
COMPLIANCE ASSISTANCE: None.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal.
ATTACHMENTS: VEO sheet