DAQ-2024-008089

DAQE-AN108190009-24

{{$d1 }}

Mike Pool
Springville City Corporation
450 West 600 North
Springville, UT 84663
[e-mail]

Dear Mr. Pool:

Re: Approval Order: Modification to Approval Order DAQE-AN108190008-17 to Update
Equipment List and Control Equipment
Project Number: N108190009

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on July 27,
2023. Springville City Corporation must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is John Jenks, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received
on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:JJ:jg

cc: Utah County Health Department
EPA Region 8

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

May 8, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN108190009-24
Modification to Approval Order DAQE-AN108190008-17
to Update Equipment List and Control Equipment

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Springville City Corporation - Whitehead Power Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

May 8, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN108190009-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Springville City Corporation Springville City Corporation - Whitehead Power
Plant

Mailing Address Physical Address
450 West 600 North 450 West 700 North
Springville, UT 84663 Springville, UT 84663

Source Contact UTM Coordinates
Name: Mike Pool 447400 m Easting
Phone: [phone] 4447250 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12

SIC code 4911 (Electric Services)

SOURCE INFORMATION
General Description
Springville Power Corporation (Springville) operates the Whitehead Power Plant. The facility is a minor
source, a municipal power plant. Following completion of this permitting project, the plant will consist of
two (2) Enterprise engines (K-1 and K-2), five (5) Caterpillar G3520H engines (K-3 through K-7) and
one (1) 6 MMBtu.hr natural gas boiler.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Provo UT PM2.5 NAA
Utah County
Airs Source Size: SM

Applicable Federal Standards
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
DAQE-AN108190009-24
Page 4

Project Description
Springville is requesting changes to its existing AO as follows:

-Addition of units K-3-K-5 with new Caterpillar G3520H 4-stroke natural gas engines equipped with both
selective catalytic reduction (SCR) and oxidation catalysts (OC).
-Units K-6 and K-7 are being equipped with SCR and OC.
-Only two (2) Enterprise units will remain in service (K-1 and K-2).

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -31533 60262.00
Carbon Monoxide -34.17 18.43
Nitrogen Oxides -19.60 45.40
Particulate Matter - PM10 0.89 4.19
Particulate Matter - PM2.5 0.89 4.19
Sulfur Dioxide 0.04 0.24
Volatile Organic Compounds 13.47 26.37

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 17320
Generic HAPs (CAS #GHAPS) 660 7800
Change (TPY) Total (TPY)
Total HAPs 8.99 12.56

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
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]

DAQE-AN108190009-24
Page 5

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. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Springville City Corporation
White Head Power Plant

II.A.2 B-1
Boiler
Fuel: Natural gas
Rating: 6.0 MMBtu/hr

II.A.3 Engines K-1 and K-2
Enterprise DGSRV-16-4 engine generators
Fuel: Dual fuel (diesel and natural gas)
Rating: 5.5 MW/hr

II.A.4 K-3 through K-7
Engine Type: Four (4) stroke lean burn
Fuel: Natural gas
Control: SCR and OC
Rating: 3422 hp

II.A.5 Cooling Towers

DAQE-AN108190009-24
Page 6

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a Visible emissions from any point or stationary fugitive emission source associated with the
installation or control facilities shall not exceed 10% opacity, with the exception of an initial
start-up period of 15 minutes. [R307-401-8]

II.B.1.b The owner/operator shall use the specified fuel mixtures as primary fuel in the following
equipment:

A. No less than 99% natural gas in the K-1 and K-2 engine/generators, except
during a period of 30 minutes for start-up or shutdown.

B. Natural gas 100% of the time in the 6.0 MMBTU/hr boiler.

C. Natural gas 100% of the time in the K-3 through K-7 engine/generators.

The engine/generators (K-1 and K-2) may be operated using diesel fuel only
during the initial startup mode, shutdown mode or during natural gas
curtailment. Hours of operation during natural gas curtailment shall be limited
to 72 hours per calendar year. The owner/operator shall notify the Director
within 24 hours of natural gas being curtailed, the reason for the curtailment, and
the expected length of the curtailment.

[R307-401, R307-401-8]

DAQE-AN108190009-24
Page 7

II.B.1.c Stack testing to demonstrate compliance with daily and rolling 12-month emission limitations
shall be performed in accordance with the following:

A. Sample Location: The emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing methods acceptable to the Director. Occupational Safety and Health
Administration (OSHA)-approvable access shall be provided to the test location.

B. Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2, or other
EPA-approved testing methods acceptable to the Director.

C. NOx: 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing
methods acceptable to the Director.

D. CO: 40 CFR 60 Appendix A, Method 10, 10B, or other EPA-approved testing
methods acceptable to the Director.

E. Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant
concentration as determined by the appropriate methods above shall be
multiplied by the volumetric flow rate and any necessary conversion factors to
give the results in the specified units of the emission limitation. A stack test
protocol shall be provided at least 30 days prior to the test. A pretest conference
shall be held if directed by the Director.

F. The production rate during all compliance testing shall be no less than 90% of
the maximum production rate achieved in the previous three (3) years. If the
desired production rate is not achieved at the time of the test, the maximum
production rate shall be 110% of the tested achieved rate, but not more than the
maximum allowable production rate. This new allowable maximum production
rate shall remain in effect until successfully tested at a higher rate. The
owner/operator shall request a higher production rate when necessary. Testing at
no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is
successful. This process may be repeated until the maximum allowable
production rate is achieved.

G. Stack testing on each internal combustion engine shall be performed once every
8,760 hours of operation of that engine, but no less frequently than once every
three (3) years, whichever condition is met first.

[40 CFR 60 Subpart JJJJ, R307-165]

DAQE-AN108190009-24
Page 8

II.B.2 K-1, K-2, K-3, K-4, K-5, K-6, and K-7 Engine Requirements
II.B.2.a Emissions to the atmosphere from the engine generators K-1 and K-2 shall each not exceed the
following rates and concentrations:

NOx 18.01 lb/hr
CO 2.5 lb/hr

Emissions to the atmosphere from the engine generators K-3 through K-7 shall each not exceed
the following rates and concentrations:

NOx 0.07 g/hp-hr
CO 0.108 g/hp-hr

Stack testing to show compliance with the above emission limitations shall be performed as
outlined in condition II.B.1.c.

[R307-165, R307-401-8]

II.B.2.b NOx emissions from the operation of all engines and boilers at the plant shall not exceed 1.68
tons per day and 45.4 tons per rolling 12-month period.

CO emissions from the operation of all engines and boilers at the plant shall not exceed 1.15 tons
per day and 18.5 tons per rolling 12-month period.

Stack testing to show compliance with the above emission limitations shall be performed as
outlined in condition II.B.1.c.

[R307-165, R307-401-8]

II.B.2.c Internal combustion engine emissions shall be calculated using the emission factors generated
from the most recent stack test. Emissions totals from all engines shall be kept in table format,
listing the month operating hours, and emissions, for each individual engine. Stack testing shall
be performed as outlined in condition II.B.1.c.

A day is equivalent to the time period from midnight to the following midnight.
Emissions shall be calculated for NOx and CO for each individual engine with the following
equations:

Daily Rate Calculation:
D = (X * H)

Where:
X = lb/hr rate for each generator (based on the most recent stack test for that generator).
H = total hours of operation for that generator each day (recorded by hour meter)
D = daily output of pollutants in lbs/day

Monthly Rate Calculation:
The emissions (lb/hr) for each pollutant shall be calculated by summing the daily emissions for
each month.

Annual Rate Calculation:
The annual emissions shall be calculated by summing the emissions from each of the previous
12-months. The lb per rolling 12-month rate shall be divided by 2000 pounds per ton to
calculate tons per rolling 12-month period of emissions. The rolling 12-month total shall be
calculated by the twentieth day of each month.

[R307-170, R307-401-8]

DAQE-AN108190009-24
Page 9

II.B.2.d The sulfur content of any diesel burned shall not exceed 15 ppm by weight for fuels used in the
duel fuel engines.

The sulfur content shall be determined by ASTM Method D-4294-89 or an approved equivalent.
Certification of diesel fuel sulfur content shall be either by Springville City's own testing or test
reports from the fuel marketer.

[R307-401]

II.B.2.e Startup of engines K-3 through K-7 shall occur only between 8 a.m. and 11 a.m. Normal
(non-startup) operation is not restricted.

Compliance with the operating hour limit shall be shown by maintaining a log of the time that
the engine starts and ends operation.

[R307-410]

II.B.2.f The stack heights of each engine (K-1 through K-7) shall be no less than 60 feet, as measured
from ground level. [R307-410]

II.B.3 Boiler Requirements
II.B.3.a The boiler shall not exceed 5,000 hours of operation per rolling 12-month period. [R307-401]

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of operation shall be kept for all periods when the plant is in operation. An hour meter
shall determine the hours of operation. [R307-401]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN108190008-17 dated November 28, 2017
Is Derived From NOI dated July 27, 2023

DAQE-AN108190009-24
Page 10

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 Environmental Protection Agency 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 - Title 40 of the Code of Federal Regulations 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 Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
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

DAQE-IN108190009-24

April 1, 2024

Mike Pool
Springville City Corporation
450 West 600 North
Springville, UT 84663
[e-mail]

Dear Mr. Pool:

Re: Intent to Approve: Modification to Approval Order DAQE-AN108190008-17 to Update
Equipment List and Control Equipment
Project Number: N108190009

The attached document is the Intent to Approve (ITA) for the above-referenced project. The Intent to
Approve is subject to public review. Any comments received shall be considered before an Approval
Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the
actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this Intent to Approve should include the engineer's name, John Jenks, as well
as the DAQE number as shown on the upper right-hand corner of this letter. John Jenks, can be reached
at [phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Utah County Health Department
DJ Law, EPA Region 8

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — - A F v A ? A C @ E w C E ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN108190009-24
Modification to Approval Order DAQE-AN108190008-17 to
Update Equipment List and Control Equipment

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Springville City Corporation - Whitehead Power Plant

Issued On
April 1, 2024

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}

* ) ' & — - A F v A ? A C @ E w C E ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-IN108190009-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Springville City Corporation Springville City Corporation - Whitehead Power
Plant

Mailing Address Physical Address
450 West 600 North 450 West 700 North
Springville, UT 84663 Springville, UT 84663

Source Contact UTM Coordinates
Name: Mike Pool 447400 m Easting
Phone: [phone] 4447250 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12

SIC code 4911 (Electric Services)

SOURCE INFORMATION
General Description
Springville Power Corporation (Springville) operates the Whitehead Power Plant. The facility is a minor
source, a municipal power plant. Following completion of this permitting project, the plant will consist of
two (2) Enterprise engines (K-1 and K-2), five (5) Caterpillar G3520H engines (K-3-K-7) and one (1) (6
MMBtu.hr.) natural gas boiler.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Provo UT Particulate matter less than 2.5 microns in size NAA
Utah County
Airs Source Size: SM

Applicable Federal Standards
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
DAQE-IN108190009-24
Page 4

Project Description
Springville is requesting changes to its existing Approval Order as follows:

-Addition of units K-3-K-5 with new Caterpillar G3520H 4-stroke natural gas engines equipped with both
selective catalytic reduction (SCR) and oxidation catalyst (OC).
-Units K-6 and K-7 are being equipped with SCR and OC.
-Only two (2) Enterprise units will remain in service (K-1 and K-2).

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (Tons
per year)
Total (Tons
per year)
CO2 Equivalent -31533 60262.00
Carbon Monoxide -34.17 18.43
Nitrogen Oxides -19.60 45.40
Particulate Matter - Particulate matter less than 10 microns in size 0.89 4.19
Particulate Matter - PM2.5 0.89 4.19
Sulfur Dioxide 0.04 0.24
Volatile Organic Compounds 13.47 26.37

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 17320
Generic Hazardous air pollutant(s) (CAS #GHAPS) 660 7800
Change (Tons
per year)
Total (Tons
per year)
Total HAPs 8.99 12.56

PUBLIC NOTICE STATEMENT

The Notice of Intent for the above-referenced project has been evaluated and has been found to be
consistent with the requirements of Utah Administrative Code R307. Air pollution producing sources
and/or their air control facilities may not be constructed, installed, established, or modified prior to the
issuance of an Approval Order by the Director.

A 30-day public comment period will be held in accordance with Utah Administrative Code R307-401-7.
A notification of the intent to approve will be published in The Daily Herald on April 2, 2024. During the
public comment period the proposal and the evaluation of its impact on air quality will be available for
the public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with Utah Administrative Code R307-401-7. The hearing will
be held as close as practicable to the location of the source. Any comments received during the public
comment period and the hearing will be evaluated. The proposed conditions of the Approval Order may
be changed as a result of the comments received.

DAQE-IN108190009-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality Approval Order authorizing the project with the following
recommended conditions and that failure to comply with any of the conditions may constitute a violation
of the AO.

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

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

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

I.4 All records referenced in this Approval Order 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 Approval Order 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 Approval Order shall be recorded.
[R307-401-4]

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

I.7 The owner/operator shall comply with Utah Administrative Code R307-150 Series. Emission
Inventories. [R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This Approval Order may become
invalid if construction is not commenced within 18 months from the date of this Approval
Order or if construction is discontinued for 18 months or more. To ensure proper credit when
notifying the Director, send the documentation to the Director, attn.: New Source Review
Section. [R307-401-18]

DAQE-IN108190009-24
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality Approval Order authorizing the project with the following
recommended conditions and that failure to comply with any of the conditions may constitute a violation
of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Springville City Corporation
White Head Power Plant

II.A.2 B-1
Boiler
Fuel: Natural gas
Rating: 6.0 MMBtu/hr

II.A.3 Engines K-1 & K-2
Enterprise DGSRV-16-4 engine generators
Fuel: Dual fuel (diesel and natural gas)
Rating: 5.5 MW/hr

II.A.4 K-3 through K-7
Engine Type: Four (4) stroke lean burn
Fuel: Natural gas
Control: SCR and oxidation catalyst
Rating: 3422 hp

II.A.5 Cooling Towers

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality Approval Order authorizing the project with the following
recommended conditions and that failure to comply with any of the conditions may constitute a violation
of the AO.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a Visible emissions from any point or stationary fugitive emission source associated with the
installation or control facilities shall not exceed 10% opacity, with the exception of an initial
start-up period of 15 minutes. [R307-401-8]

DAQE-IN108190009-24
Page 7

II.B.1.b The owner/operator shall use the specified fuel mixtures as primary fuel in the following
equipment:

A. No less than 99% natural gas in the K-1 and K-2 engine/generators, except
during a period of 30 minutes for start-up or shutdown.

B. Natural gas 100% of the time in the 6.0 MMBTU/hr boiler.

C. Natural gas 100% of the time in the K-3 through K-7 engine/generators.

The engine/generators (K-1 and K-2) may be operated using diesel fuel only during the initial
startup mode, shutdown mode, or during natural gas curtailment. Hours of operation during
natural gas curtailment shall be limited to 72 hours per calendar year. The owner/operator shall
notify the Director within 24 hours of natural gas being curtailed, the reason for the curtailment,
and the expected length of the curtailment.

[R307-401, R307-401-8]

DAQE-IN108190009-24
Page 8

II.B.1.c Stack testing to demonstrate compliance with daily and rolling 12-month emission limitations
shall be performed in accordance with the following:

A. Sample Location: The emission point shall be designed to conform to the
requirements of Title 40 of the Code of Federal Regulations 60, Appendix A,
Method 1, or other EPA-approved testing methods acceptable to the Director.
Occupational Safety and Health Administration (OSHA)-approvable access shall
be provided to the test location.

B. Volumetric Flow Rate: Title 40 of the Code of Federal Regulations 60,
Appendix A, Method 2, or other EPA-approved testing methods acceptable to
the Director.

C. NOx: Title 40 of the Code of Federal Regulations 60 Appendix A, Method 7E, or
other EPA-approved testing methods acceptable to the Director.

D. CO: Title 40 of the Code of Federal Regulations 60 Appendix A, Method 10,
10B, or other EPA-approved testing methods acceptable to the Director.

E. Calculations: To determine mass emission rates (lb/hr, etc.), the pollutant
concentration as determined by the appropriate methods above shall be
multiplied by the volumetric flow rate and any necessary conversion factors to
give the results in the specified units of the emission limitation. A stack test
protocol shall be provided at least 30 days prior to the test. A pretest conference
shall be held if directed by the Director.

F. The production rate during all compliance testing shall be no less than 90% of
the maximum production rate achieved in the previous three (3) years. If the
desired production rate is not achieved at the time of the test, the maximum
production rate shall be 110% of the tested achieved rate, but not more than the
maximum allowable production rate. This new allowable maximum production
rate shall remain in effect until successfully tested at a higher rate. The
owner/operator shall request a higher production rate when necessary. Testing at
no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is
successful. This process may be repeated until the maximum allowable
production rate is achieved.

G. Stack testing on each internal combustion engine shall be performed once every
8,760 hours of operation of that engine, but no less frequently than once every
three (3) years, whichever condition is met first.

[40 Code of Federal Regulations 60 Subpart JJJJ, R307-165]

DAQE-IN108190009-24
Page 9

II.B.2 K-1, K-2, K-3, K-4, K-6, and K-7 Engine Requirements
II.B.2.a Emissions to the atmosphere from the engine generators K-1 and K-2 shall each not exceed the
following rates and concentrations:

NOx 18.01 lb/hr
CO 2.5 lb/hr

Emissions to the atmosphere from the engine generators K-3 through K-7 shall each not exceed
the following rates and concentrations:

NOx 0.07 g/hp-hr
CO 0.108 g/hp-hr

Stack testing to show compliance with the above emission limitations shall be performed as
outlined in condition II.B.1.c.

[R307-165, R307-401-8]

II.B.2.b NOx emissions from the operation of all engines and boilers at the plant shall not exceed 1.68
tons per day and 45.4 tons per rolling 12-month period.

CO emissions from the operation of all engines and boilers at the plant shall not exceed 1.15 tons
per day and 18.5 tons per rolling 12-month period.

Stack testing to show compliance with the above emission limitations shall be performed as
outlined in condition II.B.1.c.

[R307-165, R307-401-8]

DAQE-IN108190009-24
Page 10

II.B.2.c Internal combustion engine emissions shall be calculated using the emission factors generated
from the most recent stack test. Emissions totals from all engines shall be kept in table format,
listing month, operating hours, and emissions, for each individual engine. Stack testing shall be
performed as outlined in condition II.B.1.c.

A day is equivalent to the time period from midnight to the following midnight.
Emissions shall be calculated for NOx and Carbon monoxide for each individual engine with the
following equations:

Daily Rate Calculation:
D = (X * H)

Where:
X = lb/hr rate for each generator (based on the most recent stack test for that generator)
H = total hours of operation for that generator each day (recorded by hour meter)
D = daily output of pollutant in lbs/day

Monthly Rate Calculation:

The emissions (lb/hr) for each pollutant shall be calculated by summing the daily emissions for
each month.

Annual Rate Calculation:

The annual emissions shall be calculated by summing the emissions from each of the previous
12-months. The lb per rolling 12-month rate shall be divided by 2000 pounds per ton to
calculate tons per rolling 12-month period emissions. The rolling 12-month total shall be
calculated by the twentieth day of each month.

[R307-170, R307-401-8]

II.B.2.d The sulfur content of any diesel burned shall not exceed 15 ppm by weight for fuels used in the
duel fuel engines.

The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of diesel fuel sulfur content shall be either by Springville City's own testing or test
reports from the fuel marketer.

[R307-401]

II.B.2.e Startup of engines K-3 through K-7 shall occur only between 8 AM and 11 AM. Normal (non-
startup) operation is not restricted.

Compliance with the operating hour limit shall be shown by maintaining a log of the time that
the engine starts and ends operation.

[R307-410]

II.B.2.f The stack heights of each engine (K-1 through K-7) shall be no less than 60 feet, as measured
from ground level. [R307-410]

II.B.3 Boiler Requirements
II.B.3.a The boiler shall not exceed 5,000 hours of operation per rolling 12-month period. [R307-401]

DAQE-IN108190009-24
Page 11

II.B.3.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of operation shall be kept for all periods when the plant is in operation. An hour meter
shall determine hours of operation. [R307-401]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN108190008-17 dated November 28, 2017
Is Derived From Source Submitted Notice of Intent dated July 27, 2023

DAQE-IN108190009-24
Page 12

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 Environmental Protection Agency 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 - Title 40 of the Code of Federal Regulations 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 Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
National
Ambient Air
Quality
Standards
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
Particulate
matter less than
10 microns in
size
Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
Potential to emit 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
Tons per year Tons per year
UAC Utah Administrative Code
DAQE-IN108190009-24
Page 13

VOC Volatile organic compounds

DAQE-NN108190009-24

April 1, 2024

The Daily Herald
Legal Advertising Dept
1555 N 200 W
Provo, UT 84601

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald (Account
Number: 00032838) on April 2, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Utah County
cc: Mountainland Association of Governments

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN108190009-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Springville City Corporation
Location: Springville City Corporation - Whitehead Power Plant – 450 West 700 North,
Springville, UT
Project Description: Springville Power Corporation is requesting changes to its existing Approval
Order as follows:
-Addition of units K-3-K-5 with new Caterpillar G3520H 4-stroke natural gas
engines equipped with both selective catalytic reduction (SCR) and oxidation
catalyst (OC).
-Units K-6 and K-7 are being equipped with SCR and OC.
-Only two (2) Enterprise units will remain in service (K-1 and K-2).

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before May 2, 2024 will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this
notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: April 2, 2024

{{#s=Sig_es_:signer1:signature}}

4/3/24, 9:32 AM utahlegals.com/(S(5ledariamq0m3ckpvotkvcgu))/DetailsPrint.aspx?SID=5ledariamq0m3ckpvotkvcgu&ID=181857
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Daily Herald
Publication Name:
Daily Herald
Publication URL:
Publication City and State:
Provo, UT
Publication County:
Utah
Notice Popular Keyword Category:
Notice Keywords:
springville
Notice Authentication Number:
202404031030438940201
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Notice URL:
Back
Notice Publish Date:
Tuesday, April 02, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Springville City Corporation Location: Springville City Corporation - Whitehead
Power Plant - 450 West 700 North, Springville, UT Project Description: Springville Power Corporation is requesting changes to its existing
Approval Order as follows: -Addition of units K-3-K-5 with new Caterpillar G3520H 4-stroke natural gas engines equipped with both selective
catalytic reduction (SCR) and oxidation catalyst (OC). -Units K-6 and K-7 are being equipped with SCR and OC. -Only two (2) Enterprise units
will remain in service (K-1 and K-2). The completed engineering evaluation and air quality impact analysis showed the proposed project
meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order
pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are
available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written
comments received by the Division at this same address on or before May 2, 2024 will be considered in making the final decision on the
approval/disapproval of the proposed project. Email comments will also be accepted at [e-mail]. If anyone so requests to the
Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-
1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was
raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully
consider the substance and significance of the issue. Date of Notice: April 2, 2024 Legal Notice 12702 Published in the Daily Herald on April
2, 2024
Back
DAQE-

RN108190009
March 19, 2024

Mike Pool
Springville City Corporation
450 West 600 North
Springville, UT 84663
[e-mail]

Dear Mike Pool,

Re: Engineer Review:
Modification to Approval Order DAQE-AN108190008-17 to Update Equipment List and Control
Equipment
Project Number: N108190009

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Springville City
Corporation should complete this review within 10 business days of receipt.

Springville City Corporation should contact John Jenks at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
John Jenks at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the
DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period,
the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ
Director.

If Springville City Corporation does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Springville City Corporation has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.

Approval Signature _____________________________________________________________
(Signature & Date)

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
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N108190009
Owner Name Springville City Corporation
Mailing Address 450 West 600 North
Springville, UT, 84663

Source Name Springville City Corporation- Whitehead Power Plant
Source Location 450 West 700 North
Springville, UT 84663

UTM Projection 447400 m Easting, 4447250 m Northing
UTM Datum NAD27
UTM Zone UTM Zone 12
SIC Code 4911 (Electric Services)

Source Contact Mike Pool
Phone Number [phone]
Email [e-mail]

Billing Contact Mike Pool
Phone Number 801-489-2750
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted July 27, 2023
Date of Accepted Application January 24, 2024

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 2
SOURCE DESCRIPTION

General Description
Springville Power Corporation (Springville) operates the Whitehead Power Plant. The facility is
a minor source, municipal power plant. Following completion of this permitting project the plant
will consist of two Enterprise engines (K-1 and K-2) five Caterpillar G3520H engines (K-3-K-7)
and one 6 MMBtu.hr natural gas boiler.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in , Provo UT PM2.5 NAA,
Utah County
Airs Source Size: SM

Applicable Federal Standards
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

Project Proposal
Modification to Approval Order DAQE-AN108190008-17 to Update Equipment List and Control
Equipment

Project Description
Springville Power Corporation is requesting changes to its existing AO as follows:
Addition of units K-3-K-5 with new Caterpillar G3520H 4-stroke natural gas engines equipped
with both selective catalytic reduction (SCR) and oxidation catalyst (OC).
Units K-6 and K-7 are being equipped with SCR and OC.
Only two Enterprise units will remain in service (K-1 and K-2).

EMISSION IMPACT ANALYSIS
Although the source was not subject to modeling under R307-410, the source did conduct modeling which was
reviewed by UDAQ. The results of the modeling is included in modeling memorandum DAQE-
MN108190009-23, which is included in the source file for this project. The modeling showed no violations of
the NO2 NAAQS. Startup times for engines K-3 through K-7 were established as 8:00 AM through 11:00 AM.
Operation outside of startup was not limited. [Last updated March 19, 2024]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 3
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -31533 60262.00
Carbon Monoxide -34.17 18.43
Nitrogen Oxides -19.60 45.40
Particulate Matter - PM10 0.89 4.19
Particulate Matter - PM2.5 0.89 4.19
Sulfur Dioxide 0.04 0.24
Volatile Organic Compounds 13.47 26.37

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 17320
Generic HAPs (CAS #GHAPS) 660 7800
Change (TPY) Total (TPY)
Total HAPs 8.99 12.56

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Engines K-3 through K-7
Springville is proposing an emission factor of 0.07 g/hp-hr NOx for the five new engines by adding
an SCR. UDAQ has reviewed the available control options for these engines and has not found a
lower emission rate for similar equipment. Therefore, the proposed limit of 0.07 g/hp-hr NOx
meets BACT for the new engines.

The proposed CO limit for the five engines is 0.108 g/hp-hr CO. In addition to good combustion
techniques, the five new engines have SCRs and OCs. The OC/SCRs will reduce the CO and
formaldehyde emissions by 93% and 75%. VOCs will be reduced by 50%. UDAQ has reviewed
these proposed controls as well and agrees with Springville's determination. BACT for the five
new engines is the inclusion of SCR and OC, verified by emission testing on NOx and CO. [Last
updated March 19, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

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
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]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 5
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. Emission Inventories. [R307-
150]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Springville City Corporation
White Head Power Plant

II.A.2 B-1
Boiler
Fuel: Natural gas
Rating: 6.0 MMBtu/hr

II.A.3 Engines K-1 & K-2
Enterprise DGSRV-16-4 engine generators
Fuel: Dual fuel (diesel and natural gas)
Rating: 5.5 MW/hr

II.A.4 K-3 through K-7
Engine Type: Four (4) stroke lean burn
Fuel: Natural gas
Control: SCR and oxidation catalyst
Rating: 3422 hp

II.A.5 Cooling Towers

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 6
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a Visible emissions from any point or stationary fugitive emission source associated with the
installation or control facilities shall not exceed 10% opacity, with the exception of an initial
start-up period of 15 minutes. [R307-401-8]

II.B.1.b
NEW
The owner/operator shall use the specified fuel mixtures as a primary fuel in the following
equipment:

A. No less than 99% natural gas in the K-1 and K-2 engine/generators, except during a period
of 30 minutes for start-up or shutdown

B. Natural gas 100% of the time in the 6.0 MMBTU/hr boiler

C. Natural gas 100% of the time in the K-3 through K-7 engine/generators

The engine/generators (K-1 and K-2) may be operated using diesel fuel only during the initial
startup mode, shutdown mode or during natural gas curtailment. Hours of operation during
natural gas curtailment shall be limited to 72 hours per calendar year. The owner/operator
shall notify the Director within 24 hours of natural gas being curtailed, the reason for the
curtailment, and the expected length of the curtailment. [R307-401, R307-401-8]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 7
II.B.1.c Stack testing to demonstrate compliance with daily and rolling 12-month emission limitations
shall be performed in accordance with the following:

A. Sample Location: The emission point shall be designed to conform to the requirements of
40 CFR 60, Appendix A, Method 1, or other EPA-approved testing methods acceptable to the
Director. Occupational Safety and Health Administration (OSHA) approvable access shall be
provided to the test location.

B. Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing
methods acceptable to the Director.

C. NOx: 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing methods
acceptable to the Director.

D. CO: 40 CFR 60 Appendix A, Method 10, 10B, or other EPA-approved testing methods
acceptable to the Director.

E. Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors to give the results in the specified units of the emission
limitation. A stack test protocol shall be provided at least 30 days prior to the test. A pretest
conference shall be held if directed by the Director.

F. The production rate during all compliance testing shall be no less than 90% of the
maximum production rate achieved in the previous three (3) years. If the desired production
rate is not achieved at the time of the test, the maximum production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate. The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum allowable production rate is achieved.

G. Stack testing on each internal combustion engine shall be performed once every 8,760
hours of operation of that engine, but no less frequently than once every three (3) years,
whichever condition is met first. [40 CFR 60 Subpart JJJJ, R307-165]

II.B.2 K-1, K-2, K-3, K-4, K-6, and K-7 Engine Requirements
II.B.2.a
NEW
Emissions to the atmosphere from the engine generators K-1 and K-2 shall each not exceed
the following rates and concentrations:
NOx 18.01 lb/hr
CO 2.5 lb/hr

Emissions to the atmosphere from the engine generators K-3 through K-7 shall each not
exceed the following rates and concentrations:
NOx 0.07 g/hp-hr
CO 0.108 g/hp-hr

Stack testing to show compliance with the above emission limitations shall be performed as
outlined in condition II.B.1.c. [R307-165, R307-401-8]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 8
II.B.2.b
NEW
NOx emissions from the operation of all engines and boilers at the plant shall not exceed 1.68
tons per day and 45.4 tons per rolling 12-month period.

CO emissions from the operation of all engines and boilers at the plant shall not exceed 1.15
tons per day and 18.5 tons per rolling 12-month period.

Stack testing to show compliance with the above emission limitations shall be performed as
outlined in condition II.B.1.c. [R307-165, R307-401-8]

II.B.2.c Internal combustion engine emissions shall be calculated using the emission factors generated
from the most recent stack test. Emissions totals from all engines shall be kept in table
format, listing month, operating hours, and emissions, for each individual engine. Stack
testing shall be performed as outlined in condition II.B.1.c.

A day is equivalent to the time period from midnight to the following midnight.
Emissions shall be calculated for NOx and CO for each individual engine with the following
equations:
Daily Rate Calculation:
D = (X * H)

Where:
X = lb/hr rate for each generator (based on the most recent stack test for that generator)
H = total hours of operation for that generator each day (recorded by hour meter)
D = daily output of pollutant in lbs/day

Monthly Rate Calculation:

The emissions (lb/hr) for each pollutant shall be calculated by summing the daily emissions
for each month.

Annual Rate Calculation:

The annual emissions shall be calculated by summing the emissions from each of the previous
12-months. The lb per rolling 12-month rate shall be divided by 2000 pounds per ton to
calculate tons per rolling 12-month period emissions. The rolling 12-month total shall be
calculated by the twentieth day of each month. [R307-170, R307-401-8]

II.B.2.d The sulfur content of any diesel burned shall not exceed 15 ppm by weight for fuels used in
the duel fuel engines.

The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of diesel fuel sulfur content shall be either by Springville City's own testing or
test reports from the fuel marketer. [R307-401]

II.B.2.e
NEW
Startup of engines K-3 through K-7 shall occur only between 8 AM and 11 AM. Normal
(non-startup) operation is not restricted.

Compliance with the operating hour limit shall be shown by maintaining a log of the time that
the engine starts and ends operation. [R307-410]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 9
II.B.2.f
NEW
The stack heights of each engine (K-1 through K-7) shall be no less than 60 feet, as measured
from ground level. [R307-410]

II.B.3 Boiler Requirements
II.B.3.a
NEW
The boiler shall not exceed 5,000 hours of operation per rolling 12-month period. [R307-401]

II.B.3.a.1
NEW
To determine compliance with a rolling 12-month total the owner/operator shall calculate a
new 12-month total by the twentieth day of each month using data from the previous 12
months. Records of operation shall be kept for all periods when the plant is in operation. An
hour meter shall determine hours of operation. [R307-401]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 10
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN108190008-17 dated November 28, 2017
Is Derived From Source Submitted NOI dated July 27, 2023

REVIEWER COMMENTS

1. Comment regarding Change in Conditions:
This project results in the following changes in permit conditions (modified from the current 2017
Approval Order, DAQE-AN108190008-17):

• Permit Condition II.A.2 - The 2.5 MMBtu/hr boiler is removed.
• Permit Condition II.A.3 - This now includes only K-1 and K-2 at 5.50 MW/hr.
• Permit Condition II.A.4 - Has been updated to reflect the 5 CAT Natural gas SCR controlled 4
stroke lean burn (3422 hp)
• Permit Condition II.B.1.b -K-3 and K-4 have been eliminated from Part A (K-1 and K-2 remains).
Part C should include K-3 through K-7
• Permit Condition II.B.2.a - The hourly NOx limits for K-1-K-2 engines is set to 18.01 lb/hr (CO is
unchanged). K-3-K-7 now have a NOx limit of 0.07 g/hp-hr and a CO limit of 0.108 g/hp-hr.
• Permit Condition II.B.2.b - The annual tpy limit of NOx and CO should be updated to 45.4 tpy and
18.5, respectively.
• Permit Condition II.B.2.e - K-3-K-7 updated to account for startup times 8:00AM to 11:00AM.
Other limitations should be removed.
• Permit Condition II.B.2.f - Stack heights for all engines K-1-K-7 should be at least 60 feet from
ground level.
[Last updated March 19, 2024]

2. Comment regarding Change in emissions:
The change in equipment (new engines K-3 through K-7) and the removal of the digester gas boiler
and one Enterprise engine results in changes in total emissions as shown in the summary of
emissions table. Total HAP emissions have increased, primarily acetaldehyde, acrolein, methanol
and formaldehyde. [Last updated March 14, 2024]

Engineer Review N108190009: Springville City Corporation- Whitehead Power Plant
March 19, 2024
Page 11
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
LB/YR Pounds per year
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

DAQE-MN108190009-23

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler

DATE: October 5, 2022

SUBJECT: Modeling Analysis Review for the Notice of Intent for Springville City Corporation –
Whitehead Power Plant, Utah County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Springville City Corporation (Applicant) is seeking an approval order for their Whitehead Power
Plant located in Utah County, Utah.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

III. MODELING METHODOLOGY

A. Applicability

Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a
modified approval order. The emission rates for NOx triggered the requirement to model under
R307-410. Modeling was performed by the Applicant.

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
JK
DAQE- MN108190009-23
Page 2
B. Assumptions

1. Topography/Terrain

The Plant is at an elevation of 4530 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12

b. Approximate Location:

UTM (NAD83): 447,400 meters East
4,447,250 meters North

2. Urban or Rural Area Designation

After a review of the appropriate 7.5-minute quadrangles, it was concluded the area is
“rural” for air modeling purposes.

3. Ambient Air

It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash

The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Spanish Fork, UT UDAQ: 2016-2020
Upper Air – Salt Lake Airport, UT NWS: 2016-2020

6. Background

The background concentrations were based on concentrations measured in Spanish Fork,
Utah.

7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.

DAQE- MN108190009-23
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Springville City Corporation – Whitehead Power Plant
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
K1 447292 4447525 18.0101 78.884 8760
K2 447291 4447513 18.0101 78.884 8760
K3 447287 4447504 0.5280 2.024 7665
K4 447286 4447494 0.5280 2.024 7665
B1 447292 4447519 0.5880 2.575 8760
K6 447293 4447469 0.5280 2.024 7665
K7 447289 4447469 0.5280 2.024 7665
K5 447297 4447469 0.5280 2.024 7665
K4_START 447286 4447494 1.3470 0.737 1095
K5_START 447297 4447469 1.3470 0.737 1095
K6_START 447293 4447469 1.3470 0.737 1095
K7_START 447289 4447469 1.3470 0.737 1095
K3_START 447287 4447504 1.3470 0.737 1095

Pacificorp - Lakeside Power Plant
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
LS2_CT1 435900 4464946 130.0007 569.403 8760
LS2_CT2 435900 4464989 130.0007 569.403 8760
LSAB001 435869 4464888 1.0410 4.560 8760
LS1GT01 435890 4464750 130.0007 569.403 8760
LS1GT02 435890 4464788 130.0007 569.403 8760
LS1AB01 435885 4464771 1.0410 4.560 8760
LS1DP01 435932 4464789 0.0555 0.243 8760
LSSG001 435804 4464934 17.1385 75.067 8760
LS1SG01 435797 4464686 19.7092 86.326 8760
LS1FP01 435920 4464724 3.6445 15.963 8760

DAQE- MN108190009-23
Page 4
Total 562.6326 2464.3306
McWane Ductile
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Nox
(m) (m) (lb/hr) (tons/yr) hrs/year
PACPIPE 446185 4449965 33.0002 144.541 8760

Total 33.0002 144.5408
10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (ft)
K1 POINT 4531.1 18.3 60.0 629 33.56 1.07
K2 POINT 4530.4 18.3 60.0 629 33.56 1.07
K3 POINT 4529.5 18.3 60.0 662 24.32 0.61
K4 POINT 4529.3 18.3 60.0 662 24.32 0.61
B1 POINT 4530.8 17.7 58.0 583 50.75 0.54
K6 POINT 4530.2 18.3 60.0 662 24.32 0.61
K7 POINT 4530.0 18.3 60.0 662 24.32 0.61
K5 POINT 4530.4 18.3 60.0 662 24.32 0.61
PACPIPE POINT 4500.1 36.6 120.0 321 20.90 1.00
K4_START POINT 4529.3 18.3 60.0 662 24.32 0.61
K5_START POINT 4530.4 18.3 60.0 662 24.32 0.61
K6_START POINT 4530.2 18.3 60.0 662 24.32 0.61
K7_START POINT 4530.0 18.3 60.0 662 24.32 0.61
K3_START POINT 4529.5 18.3 60.0 662 24.32 0.61
LS2_CT1 POINT 4547.2 45.7 149.9 356 20.42 5.79
LS2_CT2 POINT 4547.2 45.7 149.9 356 20.42 5.79
LSAB001 POINT 4547.2 18.3 60.0 500 12.60 1.10
LS1GT01 POINT 4545.1 45.7 149.9 350 12.70 5.80
LS1GT02 POINT 4546.0 45.7 149.9 350 12.70 5.80
LS1AB01 POINT 4545.4 15.2 49.9 492 12.60 1.10
LS1DP01 POINT 4547.1 6.1 20.0 727 5.10 0.60
LSSG001 POINT 4547.2 6.1 20.0 858 57.50 0.30
LS1SG01 POINT 4544.0 6.1 20.0 797 50.30 0.30
LS1FP01 POINT 4545.8 6.1 20.0 730 9.70 0.30

DAQE- MN108190009-23
Page 5

IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the
NAAQS. The predicted total concentrations are less than the NAAQS.

Air Pollutant Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2 1-Hour 151.6 7.5 10.4 14.4 176.4 188 99.65%

V. PERMIT CONDITIONS

The following suggested permit language should be included under the Terms and Conditions in the
AO:

• Startup times for engine K3, K4, K5, K6 and K7 shall only occur between the hours of 8:00 am
and 11:00 am.

JK:jg

Springville Power Corporation
Notice of Intent

Modification to Approval Order
DAQE-AN108190008-17

Prepared for:
Springville Power Corporation
450 West 700 North
Springville, Utah 84663
Contact: Shawn Black
801-420-1607

Prepared by:
Stantec Consulting Services, Inc
727 East Riverpark Lane Suite 150
Boise ID 83706-4089
Contact: Eric Clark
208-388-4324

July 26, 2023
Sign-off Sheet

The conclusions in the Report titled Springville Power Corporation – Notice of Intent are Stantec’s
professional opinion, as of the time of the Report, and concerning the scope described in the
Report. The opinions in the document are based on conditions and information existing at the time
the scope of work was conducted and do not take into account any subsequent changes. The
Report relates solely to the specific project for which Stantec was retained and the stated purpose
for which the Report was prepared. The Report is not to be used or relied on for any variation or
extension of the project, or for any other project or purpose, and any unauthorized use or reliance is
at the recipient’s own risk.
Stantec has assumed all information received from Springville Power Corporation (th e “Client”) and
third parties in the preparation of the Report to be correct. While Stantec has exercised a customary
level of judgment or due diligence in the use of such information, Stantec assumes no responsibility
for the consequences of any error or omission contained therein.
This Report is intended solely for use by the Client in accordance with Stantec’s contract with the
Client. While the Report may be provided by the Client to applicable authorities having jurisdiction
and to other third parties in connection with the project, Stantec disclaims any legal duty based
upon warranty, reliance or any other theory to any third party, and will not be liable to such third
party for any damages or losses of any kind that may result.

Prepared by
(signature)
Eric Clark , PE , Project Engineer

Reviewed by
(signature)
Shantanu Kongara, Engineering Consultant

SPRINGVILLE POWER CORPORATION NOTICE OF INTENT

Table of Contents
EXECUTIVE SUMMARY .................................................................................................................... I
1.0 INTRODUCTION ............................................................................................................... 1.1
1.1 OVERVIEW ....................................................................................................................... 1.1
1.2 EMISSION SOURCES........................................................................................................ 1.1
2.0 REGULATORY APPLICABILITY ......................................................................................... 2.1
2.1 NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) .......................................... 2.1
2.2 TITLE V (PART 70) OPERATING PERMIT .......................................................................... 2.2
2.3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
(NESHA PS) ....................................................................................................................... 2.2
2.4 NEW SOURCE REVIEW (NSR) REQUIREMENTS .............................................................. 2.2
2.5 NEW SOURCES PERFORMANCE STANDARDS (NSPS) ................................................. 2.3
2.6 ACID RAIN REQUIREMENTS............................................................................................ 2.3
2.7 RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL RELEASE
PREVENTION.................................................................................................................... 2.3
2.8 STATE RULES ..................................................................................................................... 2.3
2.8.1 General Requirements .................................................................................2.4
2.8.2 General Requirements – Breakdowns .......................................................2.4
2.8.3 Emission Inventories ......................................................................................2.4
2.8.4 Permit: New and Modified Sources............................................................2.4
3.0 EMISSIONS SUMMARY .................................................................................................... 3.1
3.1 EMISSION CALCULATIONS ............................................................................................. 3.1
3.2 EMISSION OFFSET CREDITS ............................................................................................. 3.2
4.0 REQUESTED CHANGES TO 2017 APPROVAL ORDER .................................................... 4.1
5.0 AIR POLLUTION CONTROL EQUIPMENT INFORMATION............................................... 5.1
6.0 AMBIENT AIR QUALITY ANALYSIS .................................................................................. 6.1
LIST OF TABLES
Table 1 Hourly Emission Estimates ............................................................................................ 1.2
Table 2 Annual Emission Rates ................................................................................................. 1.2
Table 3 Regulatory Applicability Summary ............................................................................ 2.1
Table 4 Total Net Change in Emissions ................................................................................... 3.1
LIST OF APPENDICES
APPENDIX A NOI APPLICATION FORMS ...........................................................................A.1
APPENDIX B LAYOUT MAP ................................................................................................. B.1
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT

APPENDIX C EMISSIONS INVENTORY ............................................................................... C.1
APPENDIX D SOURCE SIZE DETERMINATION ....................................................................D.1
APPENDIX E OFFSET REQUIREMENTS................................................................................. E.1
APPENDIX F MANUFACTURER SPECIFICATIONS...............................................................F.1
APPENDIX G DISPERSION MODELING REPORT ................................................................ G.1
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
i

Executive Summary
Springville Power Corporation (Springville) is filing this Notice of Intent (NOI) for a modification to
their current Approval Order (AO). Requested changes include the addition of units K3-K5 with
new Caterpillar G3520H 4-stroke natural gas engines equipped with both selective catalytic
reduction (SCR) and oxidation catalyst (OC). Units K6 and K7 are being equipped with a SCR
and OC. Additionally, only two Enterprise units will remain (K1 and K2). Emissions associated with
the Caterpillar engines are derived from representative specification sheets from Wheeler
Machinery and Safety Power (manufacturer of the SCR and OC). Enterprise K1 and K2 were
most recently tested in 2021. The worst-case three-test average emission factor amongst the two
is assumed to be representative of both units and scaled up as a safety factror. This includes
both nitrogen oxides (NOx) and carbon monoxide (CO).
Updated 1-hr nitrogen dioxide (NO2) modeling was also conducted to account for a new
configuration at the plant. Units K 5 through K7 will be moved to the south side of the generation
building. Additionally, K4 is moved 7 feet to the south from its current location. Lastly, Springville
owns the property to the south o f 700 N orth. The property boundary has been adjusted to the
incorporate those parcels. In accordance with the Utah County assessor, three parcels are
owned by Springville that comprise approximately 13.23 acres. These parcels are now excluded
from ambient air (700 North remains part of ambient air). The 2.5 MMBtu/hr digester gas boiler
will be removed from the facility and should be removed from the permit.
All engines are covered by 40 CFR Part 60, Subpart JJJJ (Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines) or 40 CFR 63, Subpart ZZZZ (National Emission
Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines).
Springville will continue to be classified as a minor facility (area source) regarding hazardous air
pollutant (HAP) thresholds of 10 tpy of a single HAP and 25 tpy for all aggregated HAP emissions.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Introduction
July 26, 2023
u:\203723274\05_report_deliv \del iverables\springville_noi_draft_072523.docx 1.1

1.0 INTRODUCTION
1.1 OVERVIEW
The Whitehead Power Plant is located in Utah County, a non-attainment area for particulate
matter of 2.5 microns or less (PM2.5) and ozone (marginal). The county is also in maintenance for
PM10. All other pollutants are in attainment. At the emission levels described in this NOI, the
facility remains a minor source.
The facility will now consist of two Enterprise engines (K1&K2), five Caterpillar G3520H engines
(K3-K7), and one 6 MMBtu/hr natural gas boiler. Table 1 below identifies the hourly emission rates
for all emission units.
1.2 EMISSION SOURCES
The maximum annual hour usage was estimated to establish the potential emissions. Tables 1
and 2 illustrate the projected hourly and annual emission rates for all engines. All engine emi ssion
rates listed in Table 1 are based on 2021 performance test results for the Enterprise engines and
manufacturer information for the Caterpillar engines . The Enterprise engines have the capacity
of running on diesel fuel 1% of the time during typical operations. The NOx factors are from test
data and account for the 1% diesel. Current CO permit limits of 2.5 lb/hr is proposed to be
maintained for the Enterprise engines. All other pollutant emission factors are established via AP-
42 Sections 3.2 and 3.4 and are illustrated in the following equation example. VOC and HAP are
reduced by 50% based on the OC equipment. The maximum horsepower assumed for both
Enterprise engines is 7,370 hp (5,500 kW).
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑃𝑃𝑃𝑃2.5/10 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀=�9.99𝐸𝐸−3 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀∗0.99�+�7.0𝐸𝐸−4 𝑙𝑙𝑙𝑙ℎ𝐸𝐸−ℎ𝐸𝐸÷ 7,000 𝑀𝑀𝐸𝐸𝑀𝑀ℎ𝐸𝐸−ℎ𝐸𝐸∗106 𝑀𝑀𝐸𝐸𝑀𝑀𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀∗0.01�=1.09𝐸𝐸−2 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑉𝑉𝑉𝑉𝑉𝑉𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀=��1 .18𝐸𝐸−1 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀∗0.99�+�6 .42𝐸𝐸−4 𝑙𝑙𝑙𝑙ℎ𝐸𝐸−ℎ𝐸𝐸÷ 7,000 𝑀𝑀𝐸𝐸𝑀𝑀ℎ𝐸𝐸−ℎ𝐸𝐸∗106 𝑀𝑀𝐸𝐸𝑀𝑀𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀∗0.01��∗.50 =5.89𝐸𝐸−2 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑆𝑆𝑉𝑉2 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀=�5.88𝐸𝐸−4 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀∗0.99�+�1.21𝐸𝐸−5 𝑙𝑙𝑙𝑙ℎ𝐸𝐸−ℎ𝐸𝐸÷ 7,000 𝑀𝑀𝐸𝐸𝑀𝑀ℎ𝐸𝐸−ℎ𝐸𝐸∗106 𝑀𝑀𝐸𝐸𝑀𝑀𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀∗0.01�=5.99𝐸𝐸−4 𝑙𝑙𝑙𝑙𝑃𝑃𝑃𝑃𝑀𝑀𝐸𝐸𝑀𝑀
Conversely, all Caterpillar engine emissions are derived from specification data from the
manufacturer. The CAT G3520H units are 3,422 hp each. Note that K6 and K7 will be
incrementally scaled up when the SCR is added with a software update (2,403 kW to 2,554 kW or
3,422 hp). Each engine has an uncontrolled emission rate of 1 g/hp-hr for NOx, but the SCR
controls all NOx by 93% resulting in an emission factor of 0.07 g/hp-hr. Similarly, CO is controlled
by 93% with an uncontrolled rate of 1.54 g/hp-hr (controlled at 0.108 g/hp-hr). VOC emissions
and all other trace organic hazardous pollutants are controlled at 50% by the OC. The lone
exception being formaldehyde that is controlled at 75%. Controlled VOC emission factors are
0.125 g/hp-hr. Lastly, AP-42 Section 3.2 factors are applied for PM2.5/10 and SO2. The values are
9.99E-03 and 5.88E-04 lb/MMBtu, respectively.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Introduction
July 26, 2023
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The currently permitted 6 MMBtu/hr natural gas boiler remains unchanged and all emission
factors are derived from AP-42, Section 1.4.
Table 1 Hourly Emission Estimates
Emission
Source Description NOx CO PM 2.5/10 VOC SO2 Total
HAPs
lb/hr
K1 Enterprise
DGSRV-16-4 18.01 2.50 0.56 3.04 0.03 1.86
K2 Enterprise
DGSRV-16-4 18.01 2.50 0.56 3.04 0.03 1.86
K3 CAT G3520H 0.53 0.81 0.20 0.94 0.01 0.59
K4 CAT G3520H 0.53 0.81 0.20 0.94 0.01 0.59
K5 CAT G3520H 0.53 0.81 0.20 0.94 0.01 0.59
K6 CAT G3520H 0.53 0.81 0.20 0.94 0.01 0.59
K7 CAT G3520H 0.53 0.81 0.20 0.94 0.01 0.59
B1 NG Boiler
(6 MMBtu/hr) 0.59 0.49 0.04 0.03 2.94E-06 0.01

Table 2 provides the estimated tons per year emissi ons based on proposed annual operating
hours.
Table 2 Annual Emission Rates
Source Description Annual
Hours NOx CO PM 2.5/10 VOC SO2 Total
HAPs hr/yr T/yr
K1 Enterprise 2,000 18.01 2.50 0.56 3.04 0.03 3.72
K2 Enterprise 2,000 18.01 2.50 0.56 3.04 0.03 3.72
K3 CAT 3520H 6,000 1.58 2.44 0.59 2.83 0.03 1.76
K4 CAT 3520H 6,000 1.58 2.44 0.59 2.83 0.03 1.76
K5 CAT 3520H 6,000 1.58 2.44 0.59 2.83 0.03 1.76
K6 CAT 3520H 6,000 1.58 2.44 0.59 2.83 0.03 1.76
K7 CAT 3520H 6,000 1.58 2.44 0.59 2.83 0.03 1.76
B1 Boiler 5,000 1.47 1.24 0.22 0.08 0.01 0.03
Total 45.40 18.43 4.19 20.30 0.24 12.56
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Regulatory APPLICABILITY
July 26, 2023
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2.0 REGULATORY APPLICABILITY
A review of state and local air quality regulations is provided in Table 3. Each regulation is
described in the following sections.
Table 3 Regulatory Applicability Summary
Program Description Regulatory Citation Applicable
2.1 National Ambient Air Quality Standards
(NAAQS)- (dispersion modeling) 40 CFR Part 50 Yes
2.2 Title V Operating Permit 40 CFR Part 70 No
2.3 Air Pollutants (NESHAPs) 40 CFR Parts 61, 63 Yes
2.4 New Source Review (NSR) 40 CFR Part 52 No
2.5 New Source Performance Standards
(NSPS) 40 CFR Part 60 Yes
2.6 Acid Rain Requirements 40 CFR Parts 72–78 No
2.7 Risk Management Programs for Chemical
Accidental Release Prevention 40 CFR Part 68 No
2.8. State Rules
2.8.1 General Requirements UAC [R307-101] Yes
2.8.2 General Requirements - Breakdowns UAC [R307-107] Yes
2.8.3 Emission Inventories UAC [307-150] Yes
2.8.4 Permit Requirements for New and
Modified Sources UAC [307-401] Yes
2.1 NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
Primary National Ambient Air Quality Standards (NAAQS) are identified in 40 CFR Part 50 and
define levels of air quality, which the United States Environmental Protection Agency (USEPA)
deems necessary to protect the public health. Secondary NAAQS define levels of air quality,
which the USEPA judges necessary to protect public welfare from any known or anticipated
adverse effects of a pollutant. Examples of public welfare include protecting wildlife, buildings,
national monuments, vegetation, visibility, and property values from degradation due to
excessive emissions of criteria pollutants.
Specific standards for the following pollutants have been promulgated by USEPA: PM10, SO2,
NOx, CO, ozone, lead, and PM2.5 . Springville emits PM 10, PM2.5, SO2, NOx, CO, and VOCs, a
precursor to ozone. The modification is a net decrease in most emissions. Those that do increase
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Regulatory APPLICABILITY
July 26, 2023
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do not exceed any modeling thresholds. However, 1-hr NO2 modeling was conducted based on
past experience with UDAQ modeling staff regarding this facility and substantial changes to the
layout. For details refer to Appendix G.
2.2 TITLE V (PART 70) OPERATING PERMIT
Title V of the Clean Air Act (CAA) created the federal operating permit program. These
permitting requirements are codified in 40 CFR Part 70. These permits are required for major
sources with a PTE (considering federally enforceable limitations) greater than 100 tpy for any
criteria pollutant, 25 tpy for all hazardous air pollutants (HAPs) in aggregate, or 10 tpy of any
single HAP. Springville is a minor source because the potential to emit of all criteria emissions
does not exceed 100 tons per year, no r are the HAPs thresholds exceeded. Therefore, a Title V
Operating permit is not needed.
2.3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR
POLLUTANTS (NESHAPS)
There are two sets of National Emissions Standards for Hazardous Air Pollutants (NESHAPs). The
first NESHAP regulations were developed under the auspices of the original CAA. These
standards are codified in 40 CFR Part 61 and address a limited number of pollutants and
industries. 40 CFR Part 61 regulations do not apply to the Springville facility.
New er regulations are codified in 40 CFR Part 63 under the authority of the 1990 Clean Air Act
Amendments (CAAA). These standards regulate HAP emissions from specific source categories
and typically affect only major sources of HAPs, however some affect mino r sources of HAPs.
Part 63 regulations are frequently called Maximum Achievable Control Technology (MACT)
standards. Major HAP sources have the PTE 10 tpy or more of any single HAP or 25 tpy or more of
all combined HAP emissions. At the Springville faci lity, potential emissions of individual HAPs will
be less than 10 tpy and combined HAP emissions will be less than 25 tpy. A review of all potential
NESHAPS concluded that subpart ZZZZ is applicable to Springville.
Both K1 and K2 engines are subject to Sub part ZZZZ as they were constructed prior to June 12,
2006. All the CAT engines are also subject to 40 CFR Part 60, Subpart JJJJ. These engines meet
the Subpart ZZZZ requirements by complying with 40 CFR 60, Subpart JJJJ requirements as stated
in section 40 CFR 63.6590(c).
2.4 NEW SOURCE REVIEW (NSR) REQUIREMENTS
Utah County is designated as a non-attainment area for PM2.5 and ozone (marginal). The county
is also in maintenance for PM10. All other pollutants are in attainment.
The prevention of significant deterioration (PSD) regulations codified in 40 CFR Part 52 apply to:
(1) a new major source that has the potential to emit 100 tons per year or more for any criteria
pollutant for a facility that is one of the 28 industrial source categories listed in 40 CFR §
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Regulatory APPLICABILITY
July 26, 2023
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52.21(b)(1)(i)(a); or (2) a new major source that has the potential to emit 250 tons per year or
more if the facility is not on the list of industrial source categories; or (3) a modification to an
existing major source that results in a net emission increase greater than a PSD significant
emission rate as specified in 40 CFR § 52.21 (b)(23)(i); or (4) a modification to an existing minor
source that is major in itself. The proposed permitting action does not trigger any PSD actions.
2.5 NEW SOURCES PERFORMANCE STANDARDS (NSPS)
New Source Performance Standards (NSPS) in 40 CFR Part 60 are applicable to new, modified, or
reconstructed stationary sources that meet or exceed specified applicability thresholds. 40 CFR
Part 60, Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines) is applicable to Springville due to the proposed five Caterpillar G3520H engines.
Springville will comply with all applicable requirements of the subpart.
2.6 ACID RAIN REQUIREMENTS
The acid rain requirements codified in 40 CFR Parts 72-78 apply only to utilities and other facilities
that combust fossil fuel and generate electricity for wholesale or retail sale. The Title IV Acid Rain
Program is for sources that use coal as a source of combustion and sources that produce over
25 MW of power. 40 CFR Part 72, Subpart 7, of the Acid Rain Program outlines exemption criteria
for new sources. A unit with a name plate of 25 MW or less, does not burn any coal or coal-
derived fuels and burns gaseous fuel with a sulfur content less than 0.05 percent. The largest unit
at the Springville facility is 7 MW (and will not operate greater than 5.5 MW). All units burn
exclusively low-sulfur natural gas or diesel (1% of the Enterprise units). Consequently, the acid
rain requirements do not apply to the Springville facility.
2.7 RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL
RELEASE PREVENTION
The Springville facility is not subject to the Chemical Accidental Release Prevention Program and
will not be required to develop a Risk Management Plan (RMP). Facilities that produce, process,
store, or use any regulated toxic or flammable substance in excess of the thresholds listed in 40
CFR Part 68 must develop a n RMP. The facility does not store any regulated toxic or flammable
substances in excess of the applicable thresholds. A n RMP is not necessary for this facility.
2.8 STATE RULES
The Utah Division of Administrative Rules (DAR) promulgates several emissions regulations that
apply to Springville in addition to those listed above.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Regulatory APPLICABILITY
July 26, 2023
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2.8.1 General Requirements
Utah Administrative Code (UAC) R307-101 provides general definitions, terms, abbreviations and
references applicable to the upcoming Approval Order. Springville will comply with this
requirement and refer to the rules where necessary.
2.8.2 General Requirements – Breakdowns
UAC R307-107 indicates the applicable general requirements for breakdown events.
Breakdowns will be reported within 24 hours of an incident with a written description of the
event. Springville will comply with the procedures and requirements outlined in R307-107 and
submi t the necessary information and reports to UDAQ related to excess emissions due to
startup, shutdown, scheduled maintenance, safety measures, upsets, and breakdowns.
2.8.3 Emission Inventories
UAC R307-150 establishes requirements for emission inventory submitta ls. Springville will comply
with this rule where appropriate.
2.8.4 Permit: New and Modified Sources
UAC R307-401 establishes the permitting requirements for any new and modified sources.
Springville will comply with any permitting requirements as defined in the rule and that applies to
the approval o rder.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Emissions Summary
July 26, 2023
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3.0 EMISSIONS SUMMARY
3.1 EMISSION CALCULATIONS
Emissions from all engines are calculated based on engines performance test results,
manufacturer specifications and AP-42 emission factors. NOx performance test data was
established in 2021 for each Enterprise engin e with a safety factor (increased to 1.485 g/kW-hr,
1.108 g/hp-hr). CO emissions are assumed to remain consistent with the current AO. 0.18 g/kW-hr
was applied in 2017 at 6,000 kW equated to 2.38 lb/hr and rounded to 2.5 lb/hr. At the proposed
5,500 kW maximum, 2.5 lb/hr corresponds to 0.206 g/kW-hr (0.154 g/hp-hr). All other pollutants
(PM10, SO2, VOC and HAPs) estimates were derived using AP -42, Section 3.2 and 3.4 for natural
gas-fired and diesel-fired engines combination based on a 99%/1% ratio .
The comparison of current (2017 AO) permitted emissions to projected PTE emissions from all
sources is given in Table 4. The primary changes are the NOx reduction from the Enterprise units,
the replacement of all K3-K7 units with new SCR-controlled cleaner CAT engines. It is unclear to
Springville and Stantec why the currently permitted VOC and especially the HAP emissions were
very low. Stantec requested an emissions inventory from UDAQ p rior to submittal, but that was
received in a format that allowed for no AO emission validation for pollutants other than NOx
and CO. Therefore, very conservative AP -42 emission factors were applied. If the same emission
factors were applied for the current AO with the assumption that the K1-K4 (all Enterprise)
operate 2,000 hr/yr, the expected VOC emissions would be 14.45 tpy. This is three 7,000 kW/hr
units and one at 5.1 kW/hr. Similarly, total HAP emissions expected for K1-K4 would be 7.11 tpy.
These va lues excluded engines K6 and K7 (2,403 kW uncontrolled). While it is unknown fully how
the AO values were derived, it is very likely that VOC/HAP increase illustrated in Table 4 is far
smaller if not a reduction in reality based on the proposed emissions. Regardless, NOx and CO
emissions, pollutant of most concern in the current AO are being reduced significantly.
Table 4 Total Net Change in Emissions
Source
Total Facility
Current Emission
Rate1
(tpy)
Total Facility
Proposed Emission
Rate
(tpy)
Change
(tpy)
PM2.5 3.30 4.19 0.89
PM10 3.30 4.19 0.89
NOx 65.00 45.40 -19.60
SO2 0.20 0.24 0.04
CO 52.60 18.43 -34.17
VOC 12.90 20.30 7.40
HAPs 0.90 12.56 11.66
1. PTE from DAQE -AN108190008-17 issued November 28th, 2017.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Emissions Summary
July 26, 2023
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3.2 EMISSION OFFSET CREDITS
Emission offset credits were evaluated based on the UDAQ Minor Source Offset Determination
Flow Chart 1. The project is not located in Davis or Salt Lake County. Therefore, ozone offsets are
not required. Because the facility is located in Utah County, PM10 offset evaluation is necessary.
The combined increase (change) of NOx + CO + PM10 equals -19.60 + -34.17 + 0.89 = -52.88 tpy.
As a result, offsets are not required.

1 https://documents.deq.utah.gov/air -quality/permitting/operati ng-permits/DAQ-2014-022649.pdf
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Requested Changes to 2017 Approval Order
July 26, 2023
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4.0 REQUESTED CHANGES TO 2017 APPROVAL ORDER
Springville Power is requesting that the following permit conditions be modified from the current
2017 Approval Order, DAQE-AN108190008-17.
• Permit Condition II.A.2 – The 2.5 MMBtu/hr boiler should be removed .
• Permit Condition II.A.4 – This should include only K1 and K2 at 5.50 MW/hr.
• Permit Condition II.A.5/6 – Should be updated to reflect the 5 CAT Natural gas SC R
co ntro lled 4 stroke lean burn (3422 hp)
• Permit Condition II.B .1.b –K3 and K4 should be eliminated from Part A (K1 and K2
remains). Part C should include K3 through K7
• Permit Condition II.B.2.a – The hourly NOx limits for K1-K2 engines is proposed to be set to
18.01 lb/hr (CO is unchanged). If necessary, K3-K7 should have a NOx limit of 0.07 g/hp-hr
and a CO limit of 0.108 g/hp-hr.
• Permit Condition II.B.2.b – If necessary, the annual tpy limit of NOx and CO should be
updated to 45.4 tpy and 18.5, respectively.
• Permit Condition II.B.2.e – K3-K7 should be updated account for startup times 8:00AM to
11:00AM (See Appendix G for details). Other limitations should be removed.
• Permit Condition II.B.2.f – Stack heights for all engines K1-K7 should be at least 60 feet
from ground level.

SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Air Pollution Control Equipment Information
July 26, 2023
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5.0 AIR POLLUTION CONTROL EQUIPMENT INFORMATION
Natural Gas-fired Generators
The UDAQ currently has established the general BACT guidelines for NOx emissions from internal
combustions engines to be ≤1.0 g/hp-hr or compliant with 40 CFR Part 60 Subpart JJJJ Table 1
standards for non-emergency SI units. The new (K3-K7)engines covered in this NOI are below this
emissions level due to the SCR technology associated with the Caterpillar engines. These
engines will meet the BACT requirement for NOx without additional pollution control devices
being installed. Additionally, the BACT Clearinghouse was evaluated. Several determinations
were evaluated for Process Code 17.130 or natural gas internal combustion engines with greater
than 600 hp.
The State of Michigan issued a recent determination for a non -emergency unit on May 22, 2019,
to Mi chigan State University. The NOx BACT was set to 0.5 g/hp -hr. Other determinations in
California (2017 Gold Coast Packaging) and Kansas (2016 Mid-Kansas Electric Company) issued
limits of 5.0 ppmv and 2.13 lb/hr, respectively. Lastly, a determination in 2013 for the South Texas
Electric Cooperative issued a NOx limit of 0.084 g/hp -hr. As illustrated in the emission calculations
(Appendix C), Springville is proposing an emission factor of less than all of the above at 0.07
g/hp-hr for the five new engines adding an SCR. Therefore, the proposed limit meets BACT for
NOx.
Subpart JJJJ limits CO and VOC to 2.0 and 0.7 g/hp-hr, respectively. The determinations above
also limited CO and VOC to the following:
• Michigan State: CO 0.3 g/hp-hr; VOC 11 lb/hr
• Gold Coast Packaging: CO 54 ppmv; VOC 25 ppmv
• Mid-Kansas Electric Company: CO 3.86 lb/hr; VOC 5.82 lb/hr
• South Texas Electric Coop: CO 0.3 g/hp-hr; VOC 0.3 g/hp-hr
The five new engines adding the SCR will meet all of the previous BACT determinations and
Subpart JJJJ standards. The proposed limit amongst the five is 0.108 g/hp-hr for CO and 0.125
g/hp-hr for VOC. In addition to good combustion techniques, and the five instal led SCRs, OCs
will also be installed. The OC/SCRs will reduce the CO and formaldehyde emissions by 93% and
75%. VOCs will be reduced by 50%. Manufacturer specifications regarding the OC/SCR control is
available in Appendix F.

SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Ambient Air Quality Analysis
July 26, 2023
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6.0 AMBIENT AIR QUALITY ANALYSIS
1-hr NO2 modeling was conducted. Refer to Appendix G for specific details. Hazardous
pollutants were not modeled because all engines are subject to NESHAP federal regulations. Per
Utah Division of Air Quality correspondence with Dave Prey, HAP modeling is exempted when
subject to any 40 CFR Part 63 Subpart (June 2, 2021, email from D. Prey)

APPENDICES

SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix A NOI Application Forms
July 26, 2023
A.1

Appendix A NOI APPLICATION FORMS

Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2)
4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD)
9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced
3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]
A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
7/26/17
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2.Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3.Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5.Condition(s) Changing:
6.Description of Permit/Process Change**
7. New or modified materials and quantities used in process. **
Material Quantity Annually
8.New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
2.5 MMBtu/hr boiler removed
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Utah Division of Air Quality
New Source Review Section Company_______________________
Site/Source_____________________
Form 11 Date___________________________
Internal Combustion Engines
Equipment Information
1. Manufacturer: __________________________
Model no.: __________________________
The date the engine was constructed or
reconstructed ________________________
2. Operating time of Emission Source:
average maximum
______ Hours/day ______ Hours/day
Days/week Days/week
______ Weeks/year ______ Weeks/year
3. Manufacturer's rated output at baseload, ISO hp or Kw
Proposed site operating range _____________________________ hp or Kw
Gas Firing
4. Are you operating site equipment on pipeline quality natural gas: □ Yes □ No
5. Are you on an interruptible gas supply:
□Yes □ No
If "yes", specify alternate fuel:
_______________________________
6. Annual consumption of fuel:
_____________________________ MMSCF/Year
7. Maximum firing rate:
_____________________________ MMBTU/hr
8. Average firing rate:
_____________________________ MMBTU/hr
Oil Firing
9. Type of oil:
Grade number □ 1 □ 2 □ 4 □ 5 □ 6 Other specify ___________
10. Annual consumption: ______________ gallons 11. Heat content:______________ BTU/lb or
______________ BTU/gal
12. Sulfur content:___________% by weight 13. Ash content: ____________% by weight
14. Average firing rate: gal/hr 15. Maximum firing rate: gal/hr
16. Direction of firing: □ horizontal □ tangential □ other: (specify)
Page 1 of 4 
Page 2 of 4 
Internal Combustion Engine
Form 11 (Continued)
Operation
17. Application:
□Electric generation
______ Base load ______ Peaking
□Emergency Generator
□Driving pump/compressor
□Exhaust heat recovery
□Other (specify) ________________________
18. Cycle
□Simple cycle
□Regenerative cycle
□Cogeneration
□Combined cycle
Emissions Data
19. Manufacturer’s Emissions in grams per hour (gr/hp-hr): _______ NOX _______ CO ______ VOC
_______ Formaldehyde
20. Attach manufacturer's information showing emissions of NOx, CO, VOC, SOx, CH2O, PM10, PM 2.5 , CO2, CH4 and N2O
for each proposed fuel at engine loads and site ambient temperatures representative of the range of proposed
operation. The information must be sufficient to determine maximum hourly and annual emission rates. Annual
emissions may be based on a conservatively low approximation of site annual average temperature. Provide emissions
in pounds per hour and except for PM10 and PM2.5 parts per million by volume (ppmv) at actual conditions and corrected
to dry, 15% oxygen conditions.
Method of Emission Control:
□Lean premix combustors □Oxidation catalyst □ Water injection □ Other (specify)____________
□Other low-NOx combustor □SCR catalyst □Steam injection
Additional Information
21. On separate sheets provide the following:
A.Details regarding principle of operation of emission controls. If add-on equipment is used, provide make and
model and manufacturer's information. Example details include: controller input variables and operational
algorithms for water or ammonia injection systems, combustion mode versus engine load for variable mode
combustors, etc.
B. Exhaust parameter information on attached form.
C. All calculations used for the annual emission estimates must be submitted with this form to be deemed
complete.
D.All formaldehyde emissions must be modeled as per Utah Administrative Code R307-410-5 using
SCREEN3.
E. If this form is filled out for a new source, forms 1 and 2 must be submitted also.
Based on SCR/OC control

Page 4 of 4 
INTERNAL COMBUSTION ENGINE
FORM 11 (continued)
EMISSION SOURCES

Review of applications and issuance of permits will be expedited by supplying all necessary information requested on this form.

AIR CONTAMINANT DATA EMISSION POINT DISCHARGE PARAMETERS
STACK SOURCES (7) EMISSION POINT
(1)
CHEMICAL COMPOSITION
OF TOTAL STREAM
AIR
CONTAMINANT
EMISSION RATE

UTM COORDINATES OF
EMISSION PT. (6) EXIT DATA
NUMBER NAME
COMPONENT OR AIR
CONTAMINANT NAME
(2)

CONC.
(%V) (3)

LB/HR
(4)

TONS/YR
(5)

ZONE

EAST
(METERS)

NORTH
(METERS)

HEIGHT
ABOVE
GROUND
(FT)

HEIGHT
ABOVE
STRUCT.
(FT)

DIA.
(FT)

VELO.
(FPS)

TEMP.
(OF)

GROUND ELEVATION OF FACILITY ABOVE MEAN SEA LEVEL _______________ feet.
UTAH AIR CONSERVATION BOARD STANDARD CONDITIONS ARE 68O F AND 14.7 PSIA.

General Instructions for this form.
1. Identify each emission; point with a unique number for this plant site on plot plan, previous permits and emission inventory questionnaire. Limit emission point number to 8 character spaces. For each
emission point use as many lines as necessary to list air contaminant data. Typical emission point names are: heater, vent, boiler, tank, reactor, separator, baghouse, fugitive, etc. Abbreviations are OK.
2. Typical component names are: air, H2O, nitrogen, oxygen, CO2, CO, NOx, SOx, hexane, particulate matter (PM10 and PM2.5), etc. Abbreviations are OK.
3. Concentration data is required for all gaseous components. Show concentration in volume percent of total gas stream.
4. Pounds per hour. (#/hr) is maximum emission rate expected by applicant.
5. Tons per year (T/Y) is annual maximum emission rate expected by applicant, which takes into account process operating schedule.
6. As a minimum applicant must furnish a facility plot plan drawn to scale showing a plant benchmark, latitude and longitude correct to the nearest second for the benchmark, and all emission points dimensioned
with respect to the benchmark. Please show emission point UTM coordinates if known.
7. Supply additional information as follows if appropriate:
(a) Stack exit configuration other than a round vertical stack. Show length and width for a rectangular stack. Indicate if horizontal discharge with a note.
(b) Stack's height above supporting or adjacent structures if structure is within three "stack heights above ground" of stack.

SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix B Layout MAP
July 26, 2023
B.1

Appendix B LAYOUT MAP
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix C Emissions Inventory
July 26, 2023
C.1

Appendix C EMISSIONS INVENTORY
Springville Power Summary
Total
NOx 65.00
CO 52.60
PM2.5 3.30
PM10 3.30
SO2 0.20
VOC 12.90
HAPs 0.90
CO2e 91,795
* From the abstract of DAQE‐AN108190008‐17
NOx 45.40
CO 18.43
PM2.5 4.19
PM10 4.19
SO2 0.24
VOC 20.30
HAPs 12.56
CO2e 60,262
NOx ‐19.60
CO ‐34.17
PM2.5 0.89
PM10 0.89
SO2 0.04
VOC 7.40
HAPs 11.66
CO2e ‐31,533
Pre Project Emissions (tpy)
Post Project Emissions (tpy)
Emissions Change(tpy)
Springville Power NOI Modification
1of 4
Springville Power K1_K2
Rating (hp)7370 hp (5500 kW)
Operational Hours 2000 hr/yr
Engine Type
Number of Units 2
Criteria Pollutants g/hp‐hr lb/MMBtu lb/hr Tons/yr Reference
NOx* 1.108 36.01 36.01
CO 0.154 5.00 5.00
PM10** 1.09E‐02 1.12 1.12
PM2.5** 1.09E‐02 1.12 1.12
VOC*** 5.89E‐02 6.07 6.07
SO2 5.99E‐04 0.06 0.06
HAP 3.72 3.72 See Below
* NOx is the average of three test runs completed in 2021
** PM2.5/10 AP_42, Section 3.2
*** VOC and HAPs are controlled by 50% by the OC
Hazard Pollutant lb/hr Tons/yr Reference
1,1,2,2‐Tetrachloroethane 4.00E‐05 2.06E‐03 2.06E‐03
1,1,2‐Trichloroethane 3.18E‐05 1.64E‐03 1.64E‐03
1,3‐Butadiene 2.67E‐04 1.38E‐02 1.38E‐02
1,3‐Dichloropropane 2.64E‐05 1.36E‐03 1.36E‐03
2,2,4‐Trimethylpentane 2.50E‐04 1.29E‐02 1.29E‐02
2‐Methylnaphthalene 3.32E‐05 1.71E‐03 1.71E‐03
Acenaphthene 1.25E‐06 6.45E‐05 6.45E‐05
Acenaphthylene 5.53E‐06 2.85E‐04 2.85E‐04
Acetaldehyde 8.36E‐03 4.31E‐01 4.31E‐01
Acrolein 5.14E‐03 2.65E‐01 2.65E‐01
Benzene 4.40E‐04 2.27E‐02 2.27E‐02
Benzo(b)fluoranthene 1.66E‐07 8.56E‐06 8.56E‐06
Benzo(e)pyrene 4.15E‐07 2.14E‐05 2.14E‐05
Benzo(g,h,i)perylene 4.14E‐07 2.14E‐05 2.14E‐05
Biphenyl 2.12E‐04 1.09E‐02 1.09E‐02
Carbon Tetrachloride 3.67E‐05 1.89E‐03 1.89E‐03
Chlorobenzene 3.04E‐05 1.57E‐03 1.57E‐03
Chloroform 2.85E‐05 1.47E‐03 1.47E‐03
Chrysene 6.93E‐07 3.58E‐05 3.58E‐05
Ethylbenzene 3.97E‐05 2.05E‐03 2.05E‐03
Ethylene Dibromide 4.43E‐05 2.29E‐03 2.29E‐03
Fluoranthene 1.11E‐06 5.73E‐05 5.73E‐05
Fluorene 5.67E‐06 2.93E‐04 2.93E‐04
Formaldehyde 5.28E‐02 2.72E+00 2.72E+00
Methanol 2.50E‐03 1.29E‐01 1.29E‐01
Methylene Chloride 2.00E‐05 1.03E‐03 1.03E‐03
Hexane 1.11E‐03 5.73E‐02 5.73E‐02
Naphthalene 7.44E‐05 3.84E‐03 3.84E‐03
PAH 2.69E‐05 1.39E‐03 1.39E‐03
Phenanthrene 1.04E‐05 5.37E‐04 5.37E‐04
Phenol 2.40E‐05 1.24E‐03 1.24E‐03
Pyrene 1.36E‐06 7.02E‐05 7.02E‐05
Styrene 2.36E‐05 1.22E‐03 1.22E‐03
Tetrachloroethane 2.48E‐06 1.28E‐04 1.28E‐04
Toluene 4.08E‐04 2.10E‐02 2.10E‐02
Vinyl Chloride 1.49E‐05 7.69E‐04 7.69E‐04
Xylene 1.84E‐04 9.49E‐03 9.49E‐03
GHG Pollutant g/MMBtu lb/hr Tons/yr GWP Reference*
CO2 402 13,063 13,063 1
CH4 1 1.87E‐01 1.87E‐01 25
N2O 0.1 1.87E‐02 1.87E‐02 298
CO2e 13,073 13,073
*https://www.epa.gov/system/files/documents/2023‐03/ghg_emission_factors_hub.pdf; CO2 is 402 g/hp‐hr
EPA GHG Emission 
Factors * CAT data
Current Diesel/Natural Gas Engines
4‐Stroke lean burn
Manufacturer Data 
or AP‐42 Table 3.2‐2
lb/MMBtu
Manufacturer Data 
or AP‐42 Table 3.2‐2
2 of 4
Springville Power K3‐K7
Rating (hp)3422 hp 2553.73134
Operational Hours 6000 hr/yr
Engine Type
Number of Units 5
Criteria Pollutants g/hp‐hr lb/MMBtu lb/hr Tons/yr Reference
NOx* 0.07 2.64 7.92
CO* 0.108 4.07 12.20
PM10** 9.99E‐03 0.98 2.95
PM2.5** 9.99E‐03 0.98 2.95
VOC*** 0.125 4.72 14.15
SO2 5.88E‐04 0.06 0.17
HAP 2.94 8.81 See Below
* NOx is controlled to 0.07 g/bhp‐hr with the SCR included. CO is 93% controlled with OC and SCR
** PM2.5/10 AP_42, Section 3.2
***  VOC and HAPs are controlled by 50%  per CAT OC/SCR, respectively. All HAP are trace organic compounds
Hazard Pollutant lb/hr Tons/yr Reference
1,1,2,2‐Tetrachloroethane 4.00E‐05 1.97E‐03 5.91E‐03
1,1,2‐Trichloroethane 3.18E‐05 1.57E‐03 4.70E‐03
1,3‐Butadiene 2.67E‐04 1.31E‐02 3.94E‐02
1,3‐Dichloropropane 2.64E‐05 1.30E‐03 3.90E‐03
2,2,4‐Trimethylpentane 2.50E‐04 1.23E‐02 3.69E‐02
2‐Methylnaphthalene 3.32E‐05 1.63E‐03 4.90E‐03
Acenaphthene 1.25E‐06 6.16E‐05 1.85E‐04
Acenaphthylene 5.53E‐06 2.72E‐04 8.17E‐04
Acetaldehyde 8.36E‐03 4.12E‐01 1.24E+00
Acrolein 5.14E‐03 2.53E‐01 7.59E‐01
Benzene 4.40E‐04 2.17E‐02 6.50E‐02
Benzo(b)fluoranthene 1.66E‐07 8.17E‐06 2.45E‐05
Benzo(e)pyrene 4.15E‐07 2.04E‐05 6.13E‐05
Benzo(g,h,i)perylene 4.14E‐07 2.04E‐05 6.12E‐05
Biphenyl 2.12E‐04 1.04E‐02 3.13E‐02
Carbon Tetrachloride 3.67E‐05 1.81E‐03 5.42E‐03
Chlorobenzene 3.04E‐05 1.50E‐03 4.49E‐03
Chloroform 2.85E‐05 1.40E‐03 4.21E‐03
Chrysene 6.93E‐07 3.41E‐05 1.02E‐04
Ethylbenzene 3.97E‐05 1.95E‐03 5.86E‐03
Ethylene Dibromide 4.43E‐05 2.18E‐03 6.54E‐03
Fluoranthene 1.11E‐06 5.47E‐05 1.64E‐04
Fluorene 5.67E‐06 2.79E‐04 8.38E‐04
Formaldehyde 2.10E‐01 1.98E+00 5.94E+00
Methanol 2.50E‐03 1.23E‐01 3.69E‐01
Methylene Chloride 2.00E‐05 9.85E‐04 2.95E‐03
Hexane 1.11E‐03 5.47E‐02 1.64E‐01
Naphthalene 7.44E‐05 3.66E‐03 1.10E‐02
PAH 2.69E‐05 1.32E‐03 3.97E‐03
Phenanthrene 1.04E‐05 5.12E‐04 1.54E‐03
Phenol 2.40E‐05 1.18E‐03 3.55E‐03
Pyrene 1.36E‐06 6.70E‐05 2.01E‐04
Styrene 2.36E‐05 1.16E‐03 3.49E‐03
Tetrachloroethane 2.48E‐06 1.22E‐04 3.66E‐04
Toluene 4.08E‐04 2.01E‐02 6.03E‐02
Vinyl Chloride 1.49E‐05 7.34E‐04 2.20E‐03
Xylene 1.84E‐04 9.06E‐03 2.72E‐02
* Formaldehyde is from Safety Power (75%); also EF is in g/hp‐hr
GHG Pollutant g/MMBtu lb/hr Tons/yr GWP Reference*
CO2 401 15,126 45,378 1
CH4 1 2.17E‐01 6.51E‐01 25
N2O 0.1 2.17E‐02 6.51E‐02 298
CO2e 15,138 45,413
*https://www.epa.gov/system/files/documents/2023‐03/ghg_emission_factors_hub.pdf; CO2 is 401 g/hp‐hr
Engine fuel consumption is 5756 btu/bhp‐hr
EPA GHG Emission 
Factors * CAT data
Proposed New Natural Gas Engines (Controlled)
4‐Stroke lean burn
Manufacturer Data 
or AP‐42 Table 3.2‐2
lb/MMBtu
Manufacturer Data 
or AP‐42 Table 3.2‐2
3 of 4
Springville Power Boiler NG
Equipment Details
Rating 6 MMBtu/hour
Operational Hours 5,000 hours/year
Firing Normal
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year) Reference
NOX 100 0.59 1.47
CO 84 0.49 1.24
PM10 7.6 0.04 0.11
PM2.5 7.6 0.04 0.11
SO2 0.6 0.00 0.01
VOC 5.5 0.03 0.08
Lead 0.0005 0.00 0.00
HAP 0.01 0.03 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year) Reference
CO2 (mass basis)1 120,000 706 1,765
Methane (mass basis) 25 2.3 0.01 0.03
N2O (mass basis)298 2.2 0.01 0.03
CO2e 1,775
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year) Reference
2‐Methylnaphthalene 2.40E‐05 1.41E‐07 3.53E‐07
3‐Methylchloranthrene 1.80E‐06 1.06E‐08 2.65E‐08
7,12‐Dimethylbenz(a)anthracene 1.60E‐05 9.41E‐08 2.35E‐07
Acenaphthene 1.80E‐06 1.06E‐08 2.65E‐08
Acenaphthylene 1.80E‐06 1.06E‐08 2.65E‐08
Anthracene 2.40E‐06 1.41E‐08 3.53E‐08
Benz(a)anthracene 1.80E‐06 1.06E‐08 2.65E‐08
Benzene 2.10E‐03 1.24E‐05 3.09E‐05
Benzo(a)pyrene 1.20E‐06 7.06E‐09 1.76E‐08
Benzo(b)fluoranthene 1.80E‐06 1.06E‐08 2.65E‐08
Benzo(g,h,i)perylene 1.20E‐06 7.06E‐09 1.76E‐08
Benzo(k)fluoranthene 1.80E‐06 1.06E‐08 2.65E‐08
Chrysene 1.80E‐06 1.06E‐08 2.65E‐08
Dibenzo(a,h)anthracene 1.20E‐06 7.06E‐09 1.76E‐08
Dichlorobenzene 1.20E‐03 7.06E‐06 1.76E‐05
Fluoranthene 3.00E‐06 1.76E‐08 4.41E‐08
Fluorene 2.80E‐06 1.65E‐08 4.12E‐08
Formaldehyde 7.50E‐02 4.41E‐04 1.10E‐03
Hexane 1.80E+00 1.06E‐02 2.65E‐02
Indeno(1,2,3‐cd)pyrene 1.80E‐06 1.06E‐08 2.65E‐08
Naphthalene 6.10E‐04 3.59E‐06 8.97E‐06
Phenanathrene 1.70E‐05 1.00E‐07 2.50E‐07
Pyrene 5.00E‐06 2.94E‐08 7.35E‐08
Toluene 3.40E‐03 2.00E‐05 5.00E‐05
Arsenic 2.00E‐04 1.18E‐06 2.94E‐06
Beryllium 1.20E‐05 7.06E‐08 1.76E‐07
Cadmium 1.10E‐03 6.47E‐06 1.62E‐05
Chromium 1.40E‐03 8.24E‐06 2.06E‐05
Cobalt 8.40E‐05 4.94E‐07 1.24E‐06
Manganese 3.80E‐04 2.24E‐06 5.59E‐06
Mercury 2.60E‐04 1.53E‐06 3.82E‐06
Nickel 2.10E‐03 1.24E‐05 3.09E‐05
Selenium 2.40E‐05 1.41E‐07 3.53E‐07
AP‐42 Table 1.4‐4
Manufacturer Data
or AP‐42 Table 1.4‐1
AP‐42 Table 1.4‐2
Natural Gas-Fired Boilers & Heaters
AP‐42 Table 1.4‐2
&
Table A‐1 to
Subpart A of Part 98
AP‐42 Table 1.4‐3
Emission Factor
(lb/10^6 scf)
Page 4 of 4
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix D Source Size Determination
July 26, 2023
D.1

Appendix D SOURCE SIZE DETERMINATION
*Meaning the source categories listed in R307-415-3 (2) “Major Source” (b)(i – xxvii)
**”Non-fugitive emissions" means those emissions which could reasonably pass through a stack, chimney, vent, or
other functionally equivalent opening (R307-401-2 “Fugitive emissions”).

This document is intended for guidance and educational purposes only. It is not intended to include all possible
scenarios. The DAQ NSR Section should be contacted for site specific requirements.

Will annual potential
emissions be less than 5
tons for any criteria
pollutant, 500 pounds for
any HAP, and 2,000 pounds
for all HAPs combined?
START
Will annual potential
emissions, including fugitives,
be less than 100 tons for any
criteria pollutant, 10 tons for
any HAP, 25 tons for all HAPs
combined, and 100,000 tons
for CO2 equivalents?
Is the source a
listed* source
category?
END
Are non-fugitive** annual
potential emissions less than
100 tons for any criteria
pollutant, 10 tons for any
HAP, 25 tons for all HAPs
combined, and 100,000 tons
for CO2 equivalents?
April 26, 2011

Source Type Determination

YES

NO YES

YES

NO

NO

YES

NO

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

GREG BELL
Lieutenant Governor

Department of
Environmental Quality

Amanda Smith
Executive Director

DIVISION OF AIR QUALITY
Bryce Bird
Acting Director

Source is a Small Source
(AO not required. Source may
register as a small source, but
registration is not required)
Source is a
Minor Source
Source is a Title V Major Source.
PSD may apply; contact a DAQ NSR
Engineer for details.

Springville is considered a Minor Source as annual potentials are below 100 tons for all criteria
pollutants, 10 tons for any single HAP, 25 tons for all combined HAPs and 100,000 tonnes CO2e.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix E Offset Requirements
July 26, 2023
E.1

Appendix E OFFSET REQUIREMENTS
Offset requirements are not necessary. Please see Section 3.2 of the application for details.
SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix F Manufacturer Specifications
July 26, 2023
F.1

Appendix F MANUFACTURER SPECIFICATIONS
HIGH ALTITUDE/AMBIENT
CAT LOW PRESSURE
WITH AIR FUEL RATIO CONTROL
Nat Gas
2.0-5.0
84.7
905
4536
85
3457 bhp@1500rpm
1.0
4160-13800
RATING STRATEGY:
FUEL SYSTEM:
SITE CONDITIONS:
FUEL:
FUEL PRESSURE RANGE(psig): (See note 1)
FUEL METHANE NUMBER:
FUEL LHV (Btu/scf):
ALTITUDE(ft):
INLET AIR TEMPERATURE(°F):
STANDARD RATED POWER:
POWER FACTOR:
VOLTAGE(V):
ENGINE SPEED (rpm):1500
COMPRESSION RATIO:12.1
AFTERCOOLER TYPE:SCAC
AFTERCOOLER - STAGE 2 INLET (°F):118
AFTERCOOLER - STAGE 1 INLET (°F):192
JACKET WATER OUTLET (°F):210
ASPIRATION:TA
COOLING SYSTEM:JW+OC+1AC, 2AC+GB
CONTROL SYSTEM:ADEM4 W/ IM
EXHAUST MANIFOLD:DRY
COMBUSTION:LOW EMISSION
NOx EMISSION LEVEL (g/bhp-hr NOx):1.0
SET POINT TIMING:22
RATING NOTES LOAD 100%100%75%50%
GENSET POWER (WITH GEARBOX, WITHOUT FAN)(2)(3)ekW 2470 2467 1850 1233
GENSET POWER (WITH GEARBOX, WITHOUT FAN)(2)(3)kVA 2470 2467 1850 1233
ENGINE POWER (WITHOUT GEARBOX, WITHOUT FAN)(3)bhp 3426 3422 2578 1733
INLET AIR TEMPERATURE °F 77 85 85 85
GENERATOR EFFICIENCY (2)%97.4 97.4 97.0 96.2
GENSET EFFICIENCY (ISO 3046/1)(4)(5)%44.2 44.2 43.1 40.8
THERMAL EFFICIENCY (4)(6)%41.5 41.5 42.8 45.6
TOTAL EFFICIENCY (4)(7)%85.7 85.7 85.9 86.4
MAXIMUM
RATING
SITE RATING AT MAXIMUM
INLET AIR TEMPERATURE
ENGINE DATA
GENSET FUEL CONSUMPTION (ISO 3046/1)(8)Btu/ekW-hr 7718 7719 7913 8359
GENSET FUEL CONSUMPTION (NOMINAL)(8)Btu/ekW-hr 7984 7985 8186 8648
ENGINE FUEL CONSUMPTION (NOMINAL)(8)Btu/bhp-hr 5755 5756 5874 6153
AIR FLOW (@inlet air temp, 14.7 psia)(WET)(9)ft3/min 6308 6393 4762 3191
AIR FLOW (WET)(9)lb/hr 27968 27932 20804 13943
FUEL FLOW (60°F, 14.7 psia)scfm 363 363 279 196
INLET MANIFOLD PRESSURE (10)in Hg(abs)135.1 134.9 101.3 69.1
EXHAUST TEMPERATURE - ENGINE OUTLET (11)°F 732 732 793 898
EXHAUST GAS FLOW (@engine outlet temp, 14.5 psia)(WET)(12)ft3/min 15059 15043 11800 8596
EXHAUST GAS MASS FLOW (WET)(12)lb/hr 28963 28925 21567 14481
MAX INLET RESTRICTION (13)in H2O 14.35 14.33 10.05 7.31
MAX EXHAUST RESTRICTION (13)in H2O 19.86 19.82 11.25 5.37
EMISSIONS DATA - ENGINE OUT
NOx (as NO2)(14)(15)g/bhp-hr 1.00 1.00 1.00 1.00
CO (14)(15)g/bhp-hr 1.54 1.54 1.47 1.43
THC (mol. wt. of 15.84)(14)(15)g/bhp-hr 2.29 2.29 2.38 2.31
NMHC (mol. wt. of 15.84)(14)(15)g/bhp-hr 0.32 0.32 0.33 0.32
NMNEHC (VOCs) (mol. wt. of 15.84)(14)(15)(16)g/bhp-hr 0.25 0.25 0.26 0.25
HCHO (Formaldehyde)(14)(15)g/bhp-hr 0.21 0.21 0.22 0.22
CO2 (14)(15)g/bhp-hr 401 401 408 418
EXHAUST OXYGEN (14)(17)% DRY 9.7 9.7 9.4 8.9
HEAT REJECTION
LHV INPUT (18)Btu/min 328623 328244 252393 177746
HEAT REJ. TO JACKET WATER (JW)(19)Btu/min 34132 34115 29238 23968
HEAT REJ. TO ATMOSPHERE (INCLUDES GENERATOR)(19)Btu/min 7979 7974 6880 5735
HEAT REJ. TO LUBE OIL (OC)(19)Btu/min 12549 12543 11272 9699
HEAT REJECTION TO EXHAUST (LHV TO 248°F)(19)Btu/min 62102 62061 52233 42127
HEAT REJ. TO A/C - STAGE 1 (1AC)(19)(21)Btu/min 27284 27213 14998 5271
HEAT REJ. TO A/C - STAGE 2 (2AC)(19)(21)Btu/min 16295 16269 11418 6387
HEAT REJECTION FROM GEARBOX (GB)(19)Btu/min 1148 1146 864 581
PUMP POWER (20)Btu/min 859 859 859 859
COOLING SYSTEM SIZING CRITERIA
TOTAL JACKET WATER CIRCUIT (JW+OC+1AC)(22)Btu/min 86500 88009
TOTAL STAGE 2 AFTERCOOLER CIRCUIT (2AC+GB)(22)Btu/min 19878 20322
HEAT REJECTION TO EXHAUST (LHV TO 248°F)(22)Btu/min 68313 68267
A cooling system safety factor of 0% has been added to the cooling system sizing criteria.
MINIMUM HEAT RECOVERY
TOTAL JACKET WATER CIRCUIT (JW+OC+1AC)(23)Btu/min 66678 66591
TOTAL STAGE 2 AFTERCOOLER CIRCUIT (2AC+GB)(23)Btu/min 16571 16544
HEAT REJECTION TO EXHAUST (LHV TO 248°F)(23)Btu/min 50551 48799
CONDITIONS AND DEFINITIONS
Engine rating obtained and presented in accordance with ISO 3046/1, adjusted for fuel, site altitude and site inlet air temperature. 100% rating at maximum inlet air temperature
is the maximum engine capability for the specified fuel at site altitude and maximum site inlet air temperature. Maximum rating is the maximum capability at the specified
aftercooler inlet temperature for the specified fuel at site altitude and reduced inlet air temperature. Refer to product O&M manual for details on additional lower load capability.
No overload permitted at rating shown.
For notes information consult page three.
GENSET - WITHOUT RADIATOR
Page 1 of 4Data generated by GERP Web Version 2.2.0.42
Ref. Dta Set EM2181-01-001, Printed 15Feb2023
PREPARED BY: Shane Minor, Wheeler Machinery Co.
GAS ENGINE SITE SPECIFIC TECHNICAL DATAG3520H
Springville

Safety Power Inc
26-5155 Spectrum Way
Mississauga, On L4W 5A1
Canada
www.safetypower.com
Page 5 of 24
Confidential
99002010 Rev12.2
clean essential energy
DESIGN PARAMETERS
The design of the Safety Power emissions reduction system is based on the following conditions.
Note: NOx is calculated as NO2.
Table 1 – Engine Data
Engine Type: CAT G3520H
Application Stand-by
Engine Power 2467 ekW
Exhaust Temperature 732 °F
Design Exhaust Flow Rate 15043 (CFM)
Fuel Type Pipe Line NG

Table 2 – Emissions Data at Full Engine Load
Engine Option Emissions Catalyst Inlet Emissions
Requirement Catalyst Outlet
CAT G3520H
NOx (g/HP-h) 1.00 0.07 0.07
CO 1.54 (g/HP-h) 93 (% reduction) 93 (% reduction)
VOC 0.25 (g/HP-h) 50 (% reduction) 50 (% reduction)
HCHO 0.21 (g/HP-h) 75 (% reduction) 75 (% reduction)

Notes: (1) The EPA does not treat methane and ethane as VOC’s. Safety Power can achieve a stated reduction of VOC’s based on the EPA
definition assuming that the VOC’s manifest themselves as propene. (2) all emissions reductions are based on an average at st eady state
using SCAQMD method 100.1 for NOx and SCAQMD/EPA methods 25.1/25.3 for CO and VOC’s or mutually agreed test method approved in
writing. (3) if NMHC/VOC data isn’t provided 0.6 g/hp-hr is to be assumed (unless otherwise stated).

Table 3 – SCR System Data
Engine Option CAT G3520H
Max. Ammonia Slip @ 15% O2 8 ppm
Urea Consumption - 32.5% solution (+/- 15%) 1.6 USG/hr
System Pressure Loss 11.0" WC
System Inlet/Outlet ANSI Flange Inches 22/22

SPRINGVILLE POWER CORPORATION NOTICE OF INTENT
Appendix G Dispersion Modeling Report
July 26, 2023
G.1

Appendix G DISPERSION MODELING REPORT

Air Quality Modeling Report –
Springville Power Corporation –
Notice of Intent

Springville Power Corporation
1-hr NO2 Modeling

Prepared for:
Utah Dept. of Environmental Quality
Division of Air Quality
PO Box 144820
Salt Lake City, Utah 84114-482
Phone: [phone]

Prepared by:
Stantec Consulting Services
727 East Riverpark Lane, Suite 150
Boise, ID 83706
Contact: Eric Clark
Ph: 208-388-4324

July 26, 2023
Sign-off Sheet

The conclusions in the Report titled Air Quality Modeling Report – Springville Power Corporation –
Notice of Intent are Stantec’s professional opinion, as of the time of the Report, and concerning the
scope described in the Report. The opinions in the document are based on conditions and
information existing at the time the scope of work was conducted and do not take into account any
subsequent changes. The Report relates solely to the specific project for which Stantec was retained
and the stated purpose for which the Report was prepared. The Report is not to be used or relied on
for any variation or extension of the project, or for any other project or purpose, and any unauthorized
use or reliance is at the recipient’s own risk.
Stantec has assumed all information received from Springville Power Corporation (the “Client”) and
third parties in the preparation of the Report to be correct. While Stantec has exercised a customary
level of judgment or due diligence in the use of such information, Stantec assumes no responsibility
for the consequences of any error or omission contained therein.
This Report is intended solely for use by the Client in accordance with Stantec’s contract with the
Client. While the Report may be provided by the client to applicable authorities having jurisdiction
and to other third parties in connection with the project, Stantec disclaims any legal duty based
upon warranty, reliance or any other theory to any third party, and will not be liable to such third
party for any damages or losses of any kind that may result.

Prepared by
(signature)
Eric Clark, Project Engineer, PE

Reviewed by
(signature)
Shantanu Kongara, Engineering Consultant

Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Table of Contents
1.0 PURPOSE .......................................................................................................................... 1.1
1.1 PROCESS DESCRIPTION ................................................................................................. 1.1
2.0 MODEL DESCRIPTION/JUSTIFICATION .......................................................................... 2.1
3.0 EMISSION AND SOURCE DATA ...................................................................................... 3.1
3.1 EMISSION SOURCES........................................................................................................ 3.1
3.1.1 Engines And Boiler ........................................................................................3.2
3.2 SOURCE CHARACTERIZATION....................................................................................... 3.2
3.2.1 Operational Schedule .................................................................................3.2
3.2.2 Point Sources .................................................................................................3.2
4.0 RECEPTOR NETWORK ...................................................................................................... 4.3
5.0 ELEVATION DATA ............................................................................................................ 5.4
6.0 METEOROLOGICAL DATA .............................................................................................. 6.4
7.0 LAND USE CLASSIFICATION ........................................................................................... 7.1
8.0 BACKGROUND CONCENTRATIONS .............................................................................. 8.1
9.0 RESULTS ............................................................................................................................ 9.2
9.1 APPLICABLE LIMITS ......................................................................................................... 9.2
9.2 IMPACT ............................................................................................................................ 9.2
9.2.1 NO2 Results.....................................................................................................9.2
LIST OF TABLES
Table 3-1 Generator Emissions ................................................................................................ 3.2
Table 3-2 Source Stack Parameter s ....................................................................................... 3.3
Table 9-1 PM10 Modeling Results ............................................................................................. 9.2

AIR QUALITY MODELING REPORT – Sp ring ville Power Corporation – Notice of Intent
Purpose
July 26, 2023
Power

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1.0 PURPOSE
This air quality modeling report documents the methodology used to prepare an air quality
analysis in support of a Utah Division of Air Quality (UDAQ) Notice of Intent (NOI) application for
a modification to their current A pproval Order (AO). The facility will now consist of two Enterprise
natural gas/diesel engines (K1&K2), five Caterpillar G3520H engines (K3-K7) and a 6 MMBtu/hr
natural gas boiler. UDAQ modeling personnel performed 1-hr NO2 analysis for the current AO in
2017. The proposed changes outlined in the NOI and in the section below prompted a
reassessment of 1-hr NO2 impacts associated with the project.
All pertinent, updated modeling-related files are provided in electronic format. This includes
AERMAP terrain information, BPIP downwash files, NED data and meteorological/background
data.
1.1 PROCESS DESCRIPTION
Springville Power currently consists of four Enterprise engines (three 7.0 MW, one 5.1 MW), two
2,403 kW 4-stroke lean burn natural gas engines and two boilers (2.5 and 6.0 MMBtu/hr). The
proposed changes will remove two of the Enterprise units (one 7.0 MW and the 5.1 MW), remove
the 2.5 MMBtu/hr boiler. The two remaining Enterprise engines will not exceed 5.5 MW and
emissions will be based on worst-case average 2021 test results amongst the two units plus a
safety factor . Unit K1 underwent three NOx test runs on December 1, 2021, with the average of
the three being 1.254 g/kW-hr, but scaled up to 1.485 g/kW-hr. This value was applied for both
Unit K1 and K2 emission calculations. Additionally, three new Caterpillar G3520H 4-stroke lean
burn natural gas units (K3-K5) will be added. Units K6 and K7 will remain and upscaled with new
software to account for new control equipment. Each of the Caterpillar engines will be
equipped with an oxidation catalyst and selective catalytic reduction (SCR). The 6.0 MMBtu/hr
boiler remains unchanged.
Three of the CAT engines (K5-K7) will be placed along the south side of the generation p lant. The
new CAT K4 will be equipped with a SCR/OC and moved 7 feet to the south from the
Enterprise’s current location. The new CAT K3 will also be equipped as a SCR/OC but remain in
the same location as the former Enterprise unit. A nearby facility, Pacific pipeline, was included
in the modeling analysis at the request of UDAQ. This was included from 2017 UDAQ modeling
conducted at the facility and has been applied without modification. Lastly, Springville owns the
property to the south of 700 N o rth. The property boundary has been adjusted to the incorporate
those parcels. In accordance with the Utah County assessor, three parcels are owned by
Springville that comprise approximately 13.23 acres. These parcels are now excluded from
ambient air (700 North remains part of ambient air). For details, refer to Appendix B of the Notice
of Intent.

Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Model Description/Justification
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2.0 MODEL DESCRIPTION/JUSTIFICATION
AERMOD is one of the most frequently used regulatory dispersion models in the United States
since it replaced ISCST3. Based on EPA guidance, AERMOD (version 22112) is the most
appropriate of the EPA-approved models, given the site’s physical characteristics and the
facility emission sources. AERMOD was applied as recommended in EPA’s Guideline on Air
Quality Models and consistent with guidance in UDAQ’s Modeling Guidelines. The BPIP Prime
building downwash algorithm was applied for the facility.
Terrain data were processed consistent with the approved model protocol and EPA guidance
for AERMAP. The United States Geological Survey (USGS) National Viewer was used to obtain
appropriate National Elevation Dataset (NED) data to establish proper elevations. Five years of
meteorological data from the Spanish Fork Airport (2004-2008) was provided by UDAQ for this
analysis. The model receptor network and model domain remain have been updated to reflect
the new property boundary, but the general configuration remains similar to past modeling
analyses for Springville Power.
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Emission And Source Data
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3.0 EMISSION AND SOURCE DATA
The maximum annual hour usage was estimated to establish the potential emissions. Table 1
illustrates the projected NOX emission rates for all engines. All engine emission rates listed in Table
1 are based on 2021 performance test results for the Enterprise engines and manufacturer
information for the Caterpillar engines. The Enterprise engines have the capacity of running on
diesel fuel 1% of the time during typical operations. The NOx factors are from test data and
account for the 1% diesel. As stated above the worst-case average test results plus a safety
factor were 1.485 g/kw-hr. The maximum horsepower assumed for both Enterprise engines is
7,370 hp (5500 kW). This rate was applied to both units K1 and K2. 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑁𝑁𝑁𝑁2 𝑙𝑙𝑙𝑙ℎ𝐸𝐸=1.485 𝑔𝑔𝑘𝑘𝑘𝑘ℎ𝐸𝐸∗5,500 𝑘𝑘𝑘𝑘÷ 453 .6 𝑔𝑔𝑙𝑙𝑙𝑙=18 .01 𝑙𝑙𝑙𝑙ℎ𝐸𝐸
All Caterpillar engine emissions are derived from specification data from the manufacturer. The
CAT G3520H units are 3,422 hp each at the site el evation. Each engine is specified to emit 1
g/hp-hr for NOx, but the SCR controls all NOx by 93% or a factor of 0.07 g/hp-hr. However, due to
a potential SCR startup time of 7 minutes, potential emission rates vary. Startup times for the CAT
engines will occur only from 8:00 AM to 11:00 AM throughout the year. The startup emission rate is
calculated as follows: 𝐶𝐶𝐶𝐶𝐶𝐶 𝑆𝑆𝐸𝐸𝑆𝑆𝐸𝐸𝐸𝐸 𝑁𝑁𝑁𝑁2 𝑙𝑙𝑙𝑙ℎ𝐸𝐸=��1 .0 𝑔𝑔ℎ𝐸𝐸ℎ𝐸𝐸∗760 �+�0 .07 𝑔𝑔ℎ𝐸𝐸ℎ𝐸𝐸∗5360 ��∗3422ℎ𝐸𝐸∗𝑙𝑙𝑙𝑙453 .6𝑔𝑔=1.347 𝑙𝑙𝑙𝑙ℎ𝐸𝐸
All other hours are non-startup and are calculated with the 0.07g/hp -hr only, which equates to
0.528 lb/hr. The currently permitted 6 MMBtu/hr natural gas boiler remains unchanged and NOx
emissions are derived from AP-42, Section 1.4 and a natural gas heating value of 1,020 btu/scf. 𝐵𝐵𝐵𝐵𝐸𝐸𝑙𝑙𝐸𝐸𝐸𝐸 𝑁𝑁𝑁𝑁2 𝑙𝑙𝑙𝑙ℎ𝐸𝐸=6.0 𝑀𝑀𝑀𝑀𝐵𝐵𝐸𝐸𝑀𝑀ℎ𝐸𝐸∗100 𝑙𝑙𝑙𝑙𝑀𝑀𝑀𝑀𝐸𝐸𝑀𝑀𝑀𝑀∗𝑀𝑀𝑀𝑀𝐵𝐵𝐸𝐸𝑀𝑀1020 𝑀𝑀𝑀𝑀𝐸𝐸𝑀𝑀𝑀𝑀=0.588 𝑙𝑙𝑙𝑙ℎ𝐸𝐸
3.1 EMISSION SOURCES
Emissions sources at the Springville facility that were included in the model are listed below:

• Engine emissions
o CAT and Enterprise
o CAT Start-up
• Boiler emissions

Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Emission And Source Data
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3.1.1 Engines And Boiler
Table 3-1 Generator Emissions
Model # Engine Type NO2 lb/hr
Rate
K1 Enterprise 18.01
K2 Enterprise 18.01
K3 CAT 3520H 0.528
K4 CAT 3520H 0.528
K5 CAT 3520H 0.528
K6 CAT 3520H 0.528
K7 CAT 3520H 0.528
K3START CAT startup 1.347
K4START CAT startup 1.347
K5START CAT startup 1.347
K6START CAT startup 1.347
K7START CAT startup 1.347
B1 6.0 MMBtu/hr Boiler 0.588

3.2 SOURCE CHARACTERIZATION
All emission sources are characterized as point sources. The following sections outline the
rationale and basis for all parameters.
3.2.1 Operational Schedule
All units are assumed to operate simultaneously other than the CAT start-up hours. These only
operate from 8:00 AM to 11:00 AM daily.
3.2.2 Point Sources
There are thirteen point sources within Springville. All parameters shown below were either
derived from manufacturer specification sheets , calculations based on test data or consistent
with the 2017 modeling conducted by UDAQ. All parameters consistent with the boiler and the
two Enterprise engines are unchanged from the 2017 modeling other than the stack height of
the engines which were raised to 60 feet from ground level. All CAT parameters are directly from
the Safety Power data sheet (See Appendix F), or planned values as suggested by Wheeler
Power Systems (stack height and diameter).
Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Receptor network
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Table 3-2 Source Stack Parameters
Stack Stack Height
(ft)
Temperature
(°F)
Stack Diameter
(inches)
Flow Rate
(acfm)
K1
60
672.3 42 63,557
K2 672.3 42 63,557
K3 732 22 15,043
K4 732 22 15,043
K5 732 22 15,043
K6 732 22 15,043
K7 732 22 15,043
K3START 732 22 15,043
K4START 732 22 15,043
K5START 732 22 15,043
K6START 732 22 15,043
K7START 732 22 15,043
B1 58 590 21.3 24,627

4.0 RECEPTOR NETWORK
The facility is located in a rural area in Springville, Utah within Utah County . Consistent with
UDAQ Air Dispersion Modeling Guidance, the ambient air boundary used in this analysis is the
owned property boundary, which also serves as the Public Access B oundary (PAB). Springville
owns the area south of 700 No rth and can control access. Receptors along the PAB were
spaced at 25 meter increments. The PAB represents the limit of access by the public to the
project site. The receptor grid was established as follows:
• Receptors spaced at 25 meters along the PAB;
• Receptors spaced at 25 meters for the first 100 meters past the PAB;
• Receptors spaced at a density of one per 50 meters from 100 meters out to 350 meters
past the PAB;
• Receptors spaced at 100 meters from 350 out to 850 meters past the PAB ;
• Receptors spaced at 250 meters from 850 o ut to 1,850 meter s past the PAB ;
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Elevation Data
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• Receptors spaced at 500 meters from 1.85 kilometers out to 4.35 kilometers past the PAB;
and
• Receptors spaced at 1 kilometer from 4.35 kilometers out to 7.35 kilometers past the PAB .
5.0 ELEVATION DATA
All source base and receptor elevations were calculated from USGS NED data obtained via the
National Map Viewer website using the Bee-Line BEEST preprocessing system. A 1/3 arc second
NED file was used in the analysis input and output files from AERMAP and will be included
submitted with the report.
6.0 METEOROLOGICAL DATA
Preprocessed AERMOD -ready meteorological files were obtained via the UDA Q Guideline
website 1. The data files cover the years 2004 through 2008 from the Spanish Fork Airport. The
hourly average data is from the National Weather Service (NWS) Automated Surface Observing
System (ASOS). The data presented by UDA Q is model -ready and was used without alteration or
processing. Although these data originated from UDAQ, it will be included as part of this
submittal.

1 https://deq.utah.gov/air -quality/emissions-impact-assessment-guideline-preface
Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Land use Classification
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7.0 LAND USE CLASSIFICATION
AERMOD includes rural and urban algorithm options. These options affect the wind speed
profile, dispersion rates, and mixing-height formula used in calculating ground-level pollutant
concentrations. A protocol was developed by USEPA to classify an area as either rural or urban
for dispersion modeling purposes. The classification is based on average heat flux, land use, or
population density within a three-km radius from the plant site. Of these techniques, the USEPA
has specified that land use is the most definitive criterion (USEPA, 1987). The urban/rural
classification scheme based on land use is as follows:
The land use within the total area, A0, circumscribed by a 3-km circle about the source, is
classified using the meteorological land use typing scheme proposed by Auer (1978).
The classification scheme requires that more than 50% of the area, A0, be from the
following land use types in order to be considered urban for dispersion modeling
purposes: heavy industrial (I1); light-moderate industrial (I2); commercial (C1); single-
family compact residential (R2); and multi-family compact residential (R3). Otherwise, the
use of rural dispersion coefficients is appropriate.
The Springville facility is located in a light industrial area, at Springville, Utah surrounded by
residential areas to the south and east. To the north is light industrial and agriculture land to the
west. S ite and map reconnaissance showed that the area A 0 within a 3-km radius of the source is
likely at or slightly above the 50% urban land use criteria necessary for use of urban dispersion
coefficients. Thus, they were applied in the dispersion modeling. The estimated 2022 population 2
of Springville of 35,832 was implemented. Default roughness was assumed.

2 https://www.census.gov/quickfacts/springvillecityutah
Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Background Concentrations
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8.0 BACKGROUND CONCENTRATIONS
NO2
Starting in 2018, NO2 and ozone monitors were placed in Spanish Fork (AQS Site ID 49-049-5010).
The AERMOD Wizard tool associated with the BEEST software was used to obtain three years of
NO2 and ozone data from the monitor. The years are 2019-2021. 2022 was not selected because
the tool doesn’t have the full year available for download. The data was then processed with the
tool to establish the appropriate 1-hr background values for both NO2 and ozone. The ozone data
completeness by quarter was 98.86% or greater for each of the three years (NO2 was 98.90%).
The 1st high values were determined for the temporal array flag of MHRDOW7 (month hour of day,
seven days per week). This was selected to allow for the most representative values throughout
the evaluation period. This is fairly consistent with the 2017 UDAQ modeling that used hourly files.
AERMOD input SO format files are provided as are text files. Note the NO2 file had missing data on
Friday hour 5 and Sunday hour 5 for all months. Similarly, the ozone file had missing data for
Saturday hour 5 for all months, but December. The average of the preceding and following
concentrations was applied for the missing data.
The ozone limiting method was applied as part of this analysis, again to remain consistent with
2017 modeling.
NO2 In-Stack Ratio
Lastly, a representative NO2/NOx in-stack ratio of 0.1 for each Enterprise engine and the boiler
was applied to remain consistent with the 2017 UDAQ modeling. The 0.1 is also a reasonable
value for natural gas combustion on average per the EPA In-stack Ratio database 3.
Lastly, an average of three Caterpillar G3520 engines as referenced in the EPA In-stack Rati o
database was applied for the G3520H units. This number is 0.1625 from previously tested units by
the Oklahoma DEQ.

3 https://www.epa.gov/scram/nitrogen-dioxidenitrogen-oxide -stack-ratio-isr-database
Air Quality Modeling Report – Springville Power Corporation – Notice of Intent

Results
July 26, 2023
ce u:\203723274\05_report_deliv \deliverables\appendices\g - modeling report \rpt_1hr_no2_modeling_report_final.docx 9.2

9.0 RESULTS
The following sections outline the methods used to complete an ambient air impact analysis as a
result of the proposed Springville project.
9.1 APPLICABLE LIMITS
The air quality impact limits applicable to this analysis are the National Ambient Air Quality
Standards (NAAQS). NO2 uses the design value that is the 98th percentile averaged ov er three
years . That equates to a design value that is the 8th high over a five year period.
9.2 IMPACT
The tables shown below demonstrate that there is no exceedance of the 1-hr NO2 NAAQS
standards due to the proposed operation of the facility.
9.2.1 NO2 Results
Table 9-1 PM 10 Modeling Results
PM10 Averaging
Period
Background
Concentration
(µg/m3)1
Modeled
Impact
(µg/m3)3
Total
Concentration
(µg/m3)
NAAQS
(µg/m3)
% of
Standard
Springville 1-hr 2 OLM 170.9 170.9 188 90.9%
1. MHRDOW7 ozone and NO 2 backgrounds
2. 8th high design value
3. 2004-2008 Spanish Fork Met data