DAQ-2025-001365

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

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-226-25
Site ID 10096 (B5)

Michael Mosley
Sunnyside Cogeneration Associates
P.O. Box 159
Sunnyside, UT 84539

Dear Mr. Mosley:

Re: Sunnyside Cogeneration Associates (Sunnyside) – Pretest Protocol for Carbon Dioxide (CO2),
Flow, Nitrogen Oxides (NOx), Oxygen (O2), Sulfur Dioxide (SO2), and Carbon Monoxide
(CO) Relative Accuracy Test – Carbon County

The Utah Division of Air Quality (DAQ) reviewed Sunnyside’s pretest protocol dated February 18,
2025. The proposed test shall be performed under the following conditions:

Sunnyside’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Unit 1
NOx EcoChem MC3 425
O2 EcoChem MC3 425
SO2 EcoChem MC3 425

Montrose Air Quality Services will conduct a relative accuracy/performance specification test on
Sunnyside’s continuous monitoring system and an emission rate compliance demonstration.

Relative accuracy must be determined in the units of the emission standard or equivalent units of the
emission standard, i.e., tons/year shall be tested in pounds/hour.

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
June 10, 2025 Unit 1
CO Method 10 and 19
Flow Method 1, 2, 3A, 4
CO2 and O2 Method 3A
NOx Method 7E and 19
SO2 Method 6C and 19

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DAQC-226-25
Page 2

• Reference Method 1 - Sample and Velocity Traverses for Stationary Point Sources as
outlined in 40 CFR 60 Appendix A shall be used to determine the location and
number of sampling points as applicable.

• Reference Method 2 - Determination of Stack Gas Velocity and Volumetric Flow Rate
– (Type S Pitot Tube) as outlined in 40 CFR 60 Appendix A.

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide Concentrations
in Emissions from Stationary Point Sources – (Instrumental Analyzer Procedure) as
outlined in 40 CFR 60 Appendix A.

• Reference Method 4 - Determination of Moisture Content in Stack Gases as outlined in
40 CFR 60 Appendix A shall be used to determine the stack gas moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix
A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix
A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from Stationary
Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 19 - Determination of Sulfur Dioxide Removal Efficiency and
Particulate Matter, Sulfur Dioxide, and Nitrogen Oxides Emission Rates as outlined in
40 CFR 60 Appendix A.

• Deviations - The Director or the representative of the Director must be notified of and
approve deviations of the Reference Method test. Any deviation from these conditions
without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing contractor
from strict adherence to all applicable EPA methods, DAQ policies, Utah Air Quality
Rules (UAQR), and methods approved by the Director. Any deviation from EPA
methods, DAQ policies, UAQR, and methods approved by the Director must be
addressed separately and express written consent given prior to commencement of
testing.

• Field data (Point Source emission data and test data) shall be turned over to the DAQ
in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based on
Point Source continuous emission monitoring data and test data acquired by the staff
member of the DAQ during the test.

DAQC-226-25
Page 3

• All test reports must be submitted to the Director no later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with date
and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and maintained
process conditions representative of normal operations, and operated under such other
relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements and
information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by email at
[e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL:jl

cc: Southeast Utah Health Department
Montrose Air Quality Services
* $ . # ( ) - — A F v A ? A D @ D w ? C ˜
Rob Leishman Jr