DAQ-2025-001148

DAQE-AN140620003-25

{{$d1 }}

Bryant Shakespear
Garkane Energy Cooperative Inc.
1802 South 175 East
Kanab, UT 84741
[e-mail]

Dear Mr. Shakespear:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN0140620001-07 for a
10-Year Review and Permit Updates
Project Number: N140620003

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a
10-year administrative review of this source and its respective AO. Garkane Energy Cooperative
Inc. must comply with the requirements of this AO, all applicable state requirements (R307), and Federal
Standards.

The project engineer for this action is Dungan Adams, 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.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

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

February 26, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN140620003-25
Administrative Amendment to Approval Order
DAQE-AN0140620001-07 for a 10-Year Review
and Permit Updates

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Garkane Energy Cooperative Inc. - Todd Substation Portable Diesel
Generator

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

February 26, 2025
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 ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN140620003-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Garkane Energy Cooperative Inc. Garkane Energy Cooperative Inc. - Todd Substation Portable Diesel Generator

Mailing Address Physical Address
1802 South 175 East
Kanab, UT 84741
0.75 Miles North of US Highway 89 and SR14
Junction
Alton, UT 84710

Source Contact UTM Coordinates
Name: Bryant Shakespear 366,938 m Easting
Phone: [phone],151,272 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 4911 (Electric Services)

SOURCE INFORMATION
General Description
Garkane Energy Cooperative Inc. (Garkane) operates a portable diesel generator, a diesel storage tank,
and a transformer trailer at the Todd Substation in Kane County and at various locations in the State of
Utah. Garkane operates the generator set at the Todd Substation for up to 1,000 hours per year. Garkane
operates the generator set for up to 1,000 hours per year at each temporary relocation site.

NSR Classification
10-Year Review

Source Classification
Located in Attainment Area
Kane County
Airs Source Size: SM

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN140620003-25
Page 4

Project Description
This is a 10-year review for Garkane's portable diesel generator to update permit conditions, format, and
rule applicability.

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 1506.00
Carbon Monoxide 1.03
Nitrogen Oxides 26.35
Particulate Matter - PM10 0.25
Particulate Matter - PM2.5 0.25
Sulfur Dioxide 0.53
Volatile Organic Compounds 0.49

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 26
Change (TPY) Total (TPY)
Total HAPs 0.01

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-AN140620003-25
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]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Todd Substation / Portable Equipment
II.A.2 One (1) Diesel Generator Engine Rating: 2,593 hp (1,825 kW) II.A.3 One (1) Storage Tank Contents: Diesel Capacity: 1,200 gallons
II.A.4 One (1) Transformer Trailer *Listed for informational purposes only

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Temporary Relocation Requirements
II.B.1.a The owner/operator shall submit a Notice of Temporary Relocation and obtain a Temporary Relocation Approval Letter prior to operating a portable source at any location other than the Todd Substation. [R307-401-8]
DAQE-AN140620003-25
Page 6

II.B.1.a.1 Notices of Temporary Relocation shall include the following information: A. The address and driving directions of the proposed location B. A list of equipment to be operated at the proposed site C. A site diagram showing the general equipment location on site (to scale) and the distance to the nearest houses, barns, or commercial operations (to scale if the site boundary is located within one (1) mile of these buildings) D. The expected startup and completion dates for operating at the proposed location E. The additional emission control measures that the owner/operator proposes to adopt for each emission point at the proposed site F. A reference to this AO. [R307-401-8]
II.B.1.b The owner/operator shall operate and conduct its operations of the portable diesel generator set in
accordance with the terms and conditions of this AO and the terms and conditions of the Temporary Relocation Approval Letter issued by the Director for each relocation. In the case of
any discrepancy between the conditions of this AO and the Temporary Relocation Approval
Letter, the owner/operator shall comply with the site-specific requirements in the Temporary Relocation Approval Letter. [R307-401-8]

II.B.1.c The owner/operator may relocate any of the approved equipment listed in Section II.A to any location approved by a Temporary Relocation Approval Letter. A Temporary Relocation Approval Letter is not required to return the portable generator set back to the Todd Substation after a temporary relocation. [R307-401-8] II.B.1.d The owner/operator may temporarily relocate this portable source to any temporary location.
The temporary relocation shall not exceed 180 working days and shall not exceed 365
consecutive days. If a temporary relocation is expected to exceed 180 working days, the owner/operator shall submit an NOI in accordance with R307-401 for a permanent source and
obtain a valid AO prior to the end of the 180 working days. [R307-401-17]

II.B.1.d.1 The owner/operator shall keep and maintain the following records on site: A. The initial relocation date at each location B. Working days at each location C. Consecutive days at each location. [R307-401-17]
II.B.1.d.2 The owner/operator shall submit records of the working days at each site and the consecutive
days at each site to the Director at the end of each 180 calendar days. [R307-401-17]

II.B.1.e Temporary relocation sites listed in the Utah PM10 or PM2.5 State Implementation Plan (SIP) shall comply with the standards and adopt the control strategies listed in the PM10 or PM2.5 SIP for the stationary source in addition to the requirements of this AO and the Temporary Relocation Approval Letter. [R307-401-8]
DAQE-AN140620003-25
Page 7

II.B.1.f The owner/operator shall extend the exhaust stack of the generator to no less than six (6) feet above the top of the trailer when the generator is temporarily operating in a NAAQS non-attainment area. [R307-401-8] II.B.1.g The owner/operator shall not relocate adjacent or contiguous to an existing power generation
plant or to a source with a current AO issued by the Director. [R307-401-8]
II.B.2 Portable Diesel Generator Requirements II.B.2.a The owner/operator shall comply with the applicable requirements in 40 CFR 63 Subpart ZZZZ
and 40 CFR 60 Subpart IIII for all stationary engines. An engine is considered a stationary engine if the engine meets the definition of "stationary reciprocating internal combustion engine (RICE)" in 40 CFR 63.6675 or "stationary internal combustion engine" in 40 CFR 60.4219. In
determining whether an engine is considered a stationary engine, the time the engine remains at a location shall be considered. 40 CFR 1068.30 states that an engine is a stationary engine if:
A. The engine remains at a location for more than 12 consecutive months
B. The engine remains at a seasonal source during the full annual operating period of the
seasonal source. A seasonal source is a stationary source that remains in a single location on a permanent basis (i.e., at least two (2) years) and that operates at that single
location approximately three (3) months (or more) each year.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.2.b The owner/operator shall not exceed the following hours of operation of the diesel generator: A. 1,000 operating hours per rolling 12-month period at the Todd Substation B. 1,000 operating hours per rolling 12-month period at any temporary relocation site. [R307-401-8] II.B.2.b.1 The owner/operator shall maintain records of the actual hours of operation of the diesel generator
at the Todd Substation and at each temporary relocation site. The owner/operator shall record the
following:
A. Date
B. Start time

C. Stop time
D. Operating hours.
[R307-401-8]

II.B.2.c The owner/operator shall not allow visible emissions from the portable diesel generator to exceed 20% opacity. [R307-201-3]
II.B.2.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2.d The owner/operator shall only use #1 or #2 diesel fuel as fuel for the portable diesel generator. [R307-401-8]
II.B.2.d.1 The sulfur content of any diesel fuel burned in the portable diesel generator shall not exceed 15
ppm. [40 CFR 63 Subpart ZZZZ, R307-401-8]

DAQE-AN140620003-25
Page 8

II.B.2.d.2 The sulfur content of the diesel fuel burned shall be determined by ASTM Method D4294-89 or an approved equivalent. The Director may request a test of the sulfur content of the fuel at any time. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN0140620001-07 dated October 22, 2007 Is Derived From NOI dated June 19, 2024 Incorporates Additional Information dated November 15, 2024 Incorporates Additional Information dated December 11, 2024

DAQE-AN140620003-25
Page 9

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-

RN140620003 February 18, 2025 Bryant Shakespear
Garkane Energy Cooperative Inc. 1802 South 175 East Kanab, UT 84741
[e-mail] Dear Bryant Shakespear,
Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-AN0140620001-07 for a 10-Year Review and Permit Updates. Project Number: N140620003 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 (NSR) permitting program. Garkane Energy Cooperative Inc. should complete this review within 10 business days of receipt. Garkane Energy Cooperative Inc. should contact Dungan Adams at [phone] if there are questions
or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Garkane Energy Cooperative Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Garkane Energy Cooperative Inc. 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 N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N140620003 Owner Name Garkane Energy Cooperative Inc. Mailing Address 1802 South 175 East
Kanab, UT, 84741 Source Name Garkane Energy Cooperative Inc.- Todd Substation Portable
Diesel Generator Primary Source Location 0.75 Miles North of US Highway 89 and SR14 Junction Alton, UT 84710
UTM Projection 366,938 m Easting, 4,151,272 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4911 (Electric Services) Source Contact Bryant Shakespear Phone Number [phone] Email [e-mail] Billing Contact Bryant Shakespear
Phone Number [phone] Email [e-mail]
Project Engineer Dungan Adams, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 19, 2024 Date of Accepted Application December 23, 2024

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 2
SOURCE DESCRIPTION General Description
Garkane Energy Cooperative Inc. (Garkane) operates a portable diesel generator, diesel storage tank, and transformer trailer at the Todd Substation in Kane County and at various locations in the State of Utah. Garkane operates the generator set at the Todd Substation for up to 1,000 hours
per year. Garkane operates the generator set for up to 1,000 hours per year at each temporary relocation site. NSR Classification: 10 Year Review Source Classification Located in Attainment Area Kane County Airs Source Size: SM
Applicable Federal Standards MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines Project Proposal
Administrative Amendment to Approval Order DAQE-AN0140620001-07 for a 10-Year Review and Permit Updates. Project Description 10-Year Review for Garkane's portable diesel generator set to update permit conditions, format, and rule applicability.
EMISSION IMPACT ANALYSIS This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore,
modeling is not required. [Last updated December 23, 2024]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 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 1506.00 Carbon Monoxide 1.03
Nitrogen Oxides 26.35
Particulate Matter - PM10 0.25
Particulate Matter - PM2.5 0.25
Sulfur Dioxide 0.53
Volatile Organic Compounds 0.49 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 26
Change (TPY) Total (TPY)
Total HAPs 0.01

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

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Portable Diesel Generator
This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, a BACT analysis is not required. [Last updated December 23, 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] 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]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 5
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 NEW Todd Substation / Portable Equipment
II.A.2 NEW One (1) Diesel Generator Engine Rating: 2,593 hp (1,825 kW)
II.A.3
NEW
One (1) Storage Tank
Contents: Diesel Capacity: 1,200 gallons
II.A.4 NEW One (1) Transformer Trailer *Listed for informational purposes only
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): II.B REQUIREMENTS AND LIMITATIONS II.B.1 NEW Temporary Relocation Requirements
II.B.1.a NEW The owner/operator shall submit a Notice of Temporary Relocation and obtain a Temporary Relocation Approval Letter prior to operating a portable source at any location other than the Todd Substation. [R307-401-8]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 6
II.B.1.a.1 NEW Notices of Temporary Relocation shall include the following information:
A. The address and driving directions of the proposed location
B. A list of equipment to be operated at the proposed site C. A site diagram showing the general equipment location on site (to scale), and the
distance to the nearest houses, barns, or commercial operations (to scale if the site
boundary is located within one mile of these buildings) D. The expected startup and completion dates for operating at the proposed location
E. The additional emission control measures that the owner/operator proposes to adopt
for each emission point at the proposed site F. A reference to this AO. [R307-401-8] II.B.1.b NEW The owner/operator shall operate and conduct its operations of the portable diesel generator set in accordance with the terms and conditions of this AO and the terms and conditions of the
Temporary Relocation Approval Letter issued by the Director for each relocation. In the case of any discrepancy between the conditions of this AO and the Temporary Relocation Approval Letter, the owner/operator shall comply with the site-specific requirements in the
Temporary Relocation Approval Letter. [R307-401-8] II.B.1.c NEW The owner/operator may relocate any of the approved equipment listed in Section II.A to any location approved by a Temporary Relocation Approval Letter. A Temporary Relocation
Approval Letter is not required to return the portable generator set back to the Todd Substation after a temporary relocation. [R307-401-8]
II.B.1.d NEW The owner/operator may temporarily relocate this portable source to any temporary location. The temporary relocation shall not exceed 180 working days and shall not exceed 365 consecutive days. If a temporary relocation is expected to exceed 180 working days, the owner/operator shall submit an NOI in accordance with R307-401 for a permanent source and obtain a valid AO prior to the end of the 180 working days. [R307-401-17]
II.B.1.d.1 NEW The owner/operator shall keep and maintain the following records on site: A. The initial relocation date at each location
B. Working days at each location
C. Consecutive days at each location. [R307-401-17]

II.B.1.d.2 NEW The owner/operator shall submit records of the working days at each site and the consecutive days at each site to the Director at the end of each 180 calendar days. [R307-401-17] II.B.1.e NEW Temporary relocation sites listed in the Utah PM10 or PM2.5 State Implementation Plan (SIP) shall comply with the standards and adopt the control strategies listed in the PM10 or PM2.5 SIP for the stationary source in addition to the requirements of this AO and the Temporary Relocation Approval Letter. [R307-401-8]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 7
II.B.1.f NEW The owner/operator shall extend the exhaust stack of the generator to no less than 6 feet above the top of the trailer when the generator is temporarily operating in a NAAQS Non-attainment area. [R307-401-8]

II.B.1.g NEW The owner/operator shall not relocate adjacent or contiguous to an existing power generation plant or to a source with a current AO issued by the Director. [R307-401-8] II.B.2 NEW Portable Diesel Generator Requirements
II.B.2.a
NEW
The owner/operator shall comply with the applicable requirements in 40 CFR 63 Subpart
ZZZZ and 40 CFR 60 Subpart IIII for all stationary engines. An engine is considered a stationary engine if the engine meets the definition of "stationary reciprocating internal combustion engine (RICE)" in 40 CFR 63.6675 or "stationary internal combustion engine" in 40 CFR 60.4219. In determining whether an engine is considered a stationary engine, the time the engine remains at a location shall be considered. 40 CFR 1068.30 states that an engine is a stationary engine if:
A. The engine remains at a location for more than 12 consecutive months. B. The engine remains at a seasonal source during the full annual operating period of the
seasonal source. A seasonal source is a stationary source that remains in a single
location on a permanent basis (i.e., at least two years) and that operates at that single
location approximately three months (or more) each year. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]
II.B.2.b NEW The owner/operator shall not exceed the following hours of operation of the diesel generator:
A. 1,000 operating hours per rolling 12-month period at the Todd Substation
B. 1,000 operating hours per rolling 12-month period at any temporary relocation site.
[R307-401-8] II.B.2.b.1 NEW The owner/operator shall maintain records of actual hours of operation of the diesel generator at the Todd Substation and at each temporary relocation site. The owner/operator shall record
the following:
A. Date
B. Start time
C. Stop time D. Operating hours. [R307-401-8]
II.B.2.c
NEW
The owner/operator shall not allow visible emissions from the portable diesel generator to
exceed 20% opacity. [R307-201-3]
II.B.2.c.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 8
II.B.2.d NEW The owner/operator shall only use #1 or #2 diesel fuel as fuel for the portable diesel generator. [R307-401-8]
II.B.2.d.1 NEW The sulfur content of any diesel fuel burned in the portable diesel generator shall not exceed 15 ppm. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.2.d.2 NEW The sulfur content of the diesel fuel burned shall be determined by ASTM Method D4294-89 or an approved equivalent. The Director may request a test of the sulfur content of the fuel at any time. [R307-401-8]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN0140620001-07 dated October 22, 2007
Is Derived From NOI dated June 19, 2024 Incorporates Additional Information dated November 15, 2024 Incorporates Additional Information dated December 11, 2024
REVIEWER COMMENTS
1. Comment regarding 10-Year Review: This is a 10-Year Review of AO DAQE-AN0140620001-07. The contact information, formatting, and rule applicability has been updated. The requirements of State Rule R307-401-17. Temporary Relocation have been added to the AO. A reference to 40 CFR 60 Subpart IIII and 40 CFR 63 Subpart 63 regarding stationary engines has been added to the AO. The physical location of the Todd Substation has been included in the AO. The source has not made any changes to equipment or emissions. However, the previous AO did not include emission estimates for PM2.5 or CO2e. PM2.5 has been conservatively estimated to be equal to PM10. CO2e has been estimated using AP-42 Table 3.4-1. [Last updated February 11, 2025]
2. Comment regarding Synthetic Minor Designation: This source is classified as a synthetic minor because this AO limits the source to emissions that are
below the major source threshold. Operation of the portable 2,593 hp diesel generator is limited to 1,000 hours per rolling 12-month period at the Todd Substation and at each temporary relocation. Without this operation limit, the source would be a major source for NOx emissions. [Last updated
January 9, 2025] 3. Comment regarding Federal Subpart Applicability: MACT 40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) applies to owners and operators of a RICE at any area source of HAP emissions. Because this source operates a RICE at the Todd Substation and temporary relocation sites that are considered area sources of HAP emissions, MACT Subpart ZZZZ applies to this source. NSPS 40 CFR 60 Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines) applies to owners and operates of stationary CI ICE that is constructed, reconstructed, or modified after July 11, 2005. The stationary CI ICE at the facility was constructed,
reconstructed, or modified before July 11, 2005; therefore, NSPS Subpart IIII does not apply to the source. [Last updated February 18, 2025]
4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 Page 10
Standards of Performance for New Stationary Sources 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 61 (NESHAP) or 40 CFR 60 (NSPS) regulations. The facility is subject to 40 CFR 63 (MACT)
Subpart ZZZZ. MACT Subpart ZZZZ exempts sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. Therefore, Title V does not apply to this source. [Last updated January 9, 2025]

Engineer Review N140620003: Garkane Energy Cooperative Inc.- Todd Substation Portable Diesel Generator January 13, 2025 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
Equipment Details
Rating 2,593 hp = (1935.1 kw)
Operational Hours 1,000 hours/yearSulfur Content 15 ppm or 0.0015%
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 0.024 62.23 31.12
CO 5.50E-03 14.26 7.13
PM10 7.00E-04 1.82 0.91
PM2.5 7.00E-04 1.82 0.91
VOC 6.42E-04 1.66 0.83
SO2 1.21E-05 0.03 0.02 AP-42 Table 3.4-1
HAP 0.03 0.01 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.16 3,008 1,504
Methane (mass basis)25 6.35E-05 0 0CO2e1,506
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 7.76E-04 1.41E-02 7.04E-03
Toluene 2.81E-04 5.10E-03 2.55E-03
Xylenes 1.93E-04 3.50E-03 1.75E-03
Formaldehyde 7.89E-05 1.43E-03 7.16E-04
Acetaldehyde 2.52E-05 4.57E-04 2.29E-04
Acrolein 7.88E-06 1.43E-04 7.15E-05
Naphthalene 1.30E-04 2.36E-03 1.18E-03
Acenaphthylene 9.23E-06 1.68E-04 8.38E-05
Acenaphthene 4.68E-06 8.49E-05 4.25E-05
Fluorene 1.28E-05 2.32E-04 1.16E-04
Phenanthrene 4.08E-05 7.41E-04 3.70E-04
Anthracene 1.23E-06 2.23E-05 1.12E-05
Fluoranthene 4.03E-06 7.31E-05 3.66E-05
Pyrene 3.71E-06 6.73E-05 3.37E-05
Benz(a)anthracene 6.22E-07 1.13E-05 5.64E-06
Chrysene 1.53E-06 2.78E-05 1.39E-05
Benzo(b)fluoranthene 1.11E-06 2.01E-05 1.01E-05
Benzo(k)fluoranthene 2.18E-07 3.96E-06 1.98E-06
Benzo(a)pyrene 2.57E-07 4.66E-06 2.33E-06
Indeno(1,2,3-cd)pyrene 4.14E-07 7.51E-06 3.76E-06
Dibenz(a,h)anthracene 3.46E-07 6.28E-06 3.14E-06
Benzo(g,h,l)perylene 5.56E-07 1.01E-05 5.05E-06
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42 does not list 1,3-
Butadiene for engines
greater than 600 hp.)
Diesel-Fired Engines
AP-42 Table 3.3-1
& Table 3.4-1
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
Emission Factor
(lb/MMBtu)
Emergency Engines should equal 100 hours of operation per year
Page 1 of 1 Version 1.1February 21, 2019
MEMORANDUM
DAQC-691-15
Site ID 14062 (B 1)
TO: FILE -GARKANE ENERGY WAREHOUSE -TODS SUBSTATION
THROUGH: Jay Morris, Minor Source Compliance Section Manager~,>-~
FROM: Chad Gilgen, Environmental Scientist (6
DATE: May 13, 2015
SUBJECT: FCE, Minor, Kane County, AIRS #02500006
INSPECTION DA TE:
SOURCE LOCATION:
SOURCE CONTACT(S):
OPERATING STATUS:
PROCESS DESCRIPTION:
APPLICABLE REGULATIONS:
April 29, 2015 -Tods Substation visit
April 30, 2015 -Garkane Energy office vis it
May 4, 2015 -Teleconference with Mike Avant and records
received
Tods Substation:
37°29'57.5"N l l 2°30' l 8.4"W
Kane County, Utah, 84721.
Take 1-1 5 heading south to exit 95. Go left onto UT-20. Go right
onto US-89 heading south toward Panguitch, Utah. From
Panguitch, continue south on US-89 for approximately 27 miles.
Tods Substation is on the west side of US-89.
Garkane Energy Offices:
1802 South Highway 89A
Kanab, Utah 84741
M ike Avant, Engineering Manager: 435-644-5026
[e-mail]
Located at Tods Substation. Not in use at the time of inspection.
Garkane Energy operates a portable di esel generator at the Tods
Substation. The generator is used to produce commercial power.
Though it will typically be located at the Tods Substation, the set
may operate at other locations on a temporary basis. The
generator is mounted on a portable trai ler. A transfo1mer trailer is
associated with the generator set.
Approval Order DAQE-ANO 140620001-07, dated October 22,
2007.
Document Date 5/13/2015
1111111111111111111111111111111111111111
OAQ-2015-005621
SOURCE EVALUATION:
General Conditions:
Status:
Status:
Status:
Status:
Status:
I. This AO applies to the fo llowing company:
2.
3.
4.
5.
Site Office
Garkane Energy Warehouse
1802 South 175 East
Kanab, Utah 84741
Phone Number [phone]
Fax Number [phone]
Corporate Office Location
Garkane Energy
Post Office Box 465
Loa, Utah 84747
[phone]
[phone]
ln compliance. The site office is now located at 1820 South H ighway 89A in Kanab. All
other info rmation re mains the same.
Al l definitions, terms, abbreviations, and references used in this AO conform to those used
in the UAC R307 and Title 40 of the Code of Federal Regulations (40 CFR). Unless
noted otherwise, references cited in these AO conditions refer to those rules.
ln compliance. Definitions, terms, abbreviations, and references used in the AO conform
to those used in the UAC 307 and 40 CFR. Unless noted otherwise, references cited in
the AO cond itions refer to those rules.
The limits set forth in this AO shall not be exceeded without prior approval in accordance
with R307-40 1.
1n compliance. No limit was exceeded based on submitted records and observations
during the Substation visit.
Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved in accordance with
R307-401.
ln compliance. The equipment list and process description appeared to be consistent with
what is described in the AO.
All records referenced in this AO which are required to be kept by the owner/operator,
shall be made available to the Executive Secretary or Executive Secretary's representative
upon request. Records shall be kept for a minimum of two years.
In compliance. All records required by the AO are kept on file at the Garkane Energy
office location for a minimum of two years. A log book is also maintained with the
generator.
6. The owner/operator shall operate the diesel powered generator set and conduct its
operatiO!"JS in accordance with the terms and conditions of this AO, which was written
pursuant to Garkane's Notice oflntent (NOJ) submitted to the Division of Air Quality
2
Status:
7.
Status:
8.
Status:
9.
Status:
(DAQ) on June 29, 2007 and by any terms and conditions listed in a Temporary
Relocation Approval Letter (TRAL) issued by the Executive Secretary for each relocation.
In compliance. The require ments of this condition were reviewed with Mike Avant during
the May 4, 2015, teleconference.
The owner/operator may relocate any of the equipment listed in Condition 9 to any
location approved by a TRAL.
In compliance. The requirements of this condition were reviewed with Mike Avant during
the May 4, 2015, teleconference.
Site-specific cond itions listed in a TRAL shall take precedence over conditions listed in
this AO in the event of a discrepancy between conditions in the AO and site-specific
conditions in the TRAL.
In compliance. The requirements of this condition were reviewed with Mike Avant during
the May 4, 20 I 5, teleconference.
The approved installations shall consist of the following equipment or equivalent*:
A.
B.
One (1) Diesel Generator
Design Capacity:
One ( 1) Diesel Storage Tank
Des ign Capacity:
C. One (I) Transformer Trailer**
2,593 bhp (1,825 kW)
1,200 gallons
* Equivalency shall be determined by the Executive Secretary.
** This equipment is listed for informationa l purposes only. There are no emissions from
this equipment.
In compliance. The equipment listed in this condition was observed during the Tods
Substation visit. The diesel generator listed in part A. of this condition is a Cat 35168
Engine. See attached 'Todd Diesel Generator' email for add itional information.
Relocation
I 0. Prior to operating equipment listed in Condition 9, the owner/operator s hall obtain a
TRAL in accord ance w ith R307-401-17, UAC. DAQ requires ten working days advance
notice for processing and issuing a TRAL. This AO shall serve as the initial TRAL for
operating the generator set at the Todd Substation. A TRAL is not required to return the
generator set back to the Todd Substation after a temporary relocation. A Notice of
Temporary Relocation must in clude the fo llowing information:
A. Location of proposed site, including driving directions
B. Antic ipated startup and completion dates for operation at the proposed s ite
3
Status:
11.
Status:
12.
Status:
13.
Status:
Limitations
C. A scale diagram depicting the general location of equipment on the site, and the
distance to all structures within one mile from the site
D. A list of equipment to be operated at the proposed site
E. Additiona l emission control measures that are not required by this AO for
emission points that th e owner/operator proposes to adopt at the proposed site
F. A reference to this AO
In compliance. The requirements of this condition were reviewed with Mike Avant during
the May 4, 2015, teleconference.
Tfthe generator set is proposed to be re located at a site listed in the Utah PM 10 State
Implementation Plan (PM10 SIP), the owner/operator shall be required to meet standards
and adopt control strategies listed in the PM 10 SlP for that site in addition to the standards
and conditions listed in this AO.
In compliance. The requirements of this condition were reviewed with Mike Avant during
the May 4, 201 5, teleconference.
If the generator set is to be relocated at a site in a NAAQS Non-attainment area, the
exhaust stacks shall be extended a minimum of six feet (6 ft) above the top of the trailer.
In compliance. The requirements of this condition were reviewed with Mike Avant during
the May 4, 201 5, teleconference.
The generator set cannot be relocated adjacent or contiguous to an existing power
generation plant or to a source with a current AO issued by DAQ.
In compliance. The requirements of this condition were reviewed with Mike Avant during
the May 4, 2015, teleconference.
14. Visible emissions from the diesel engine shall not exceed 20% opacity.
Status:
15.
Status:
16.
Opacity observations of emissions from stationary sources shall be conducted according to
40 C FR 60, Appendix A, Method 9.
Compliance not determined. The generator was not operating at the time of inspection.
Operation of the generator set at th e Todd Substation shall not exceed 1,000 operating
hours per rolling 12-month period.
ln compliance. The diesel generator operated a total of 2.1 hours during the May 2014 -
April 2015 rolling 12-month period. See attached 'Tod Gen Log 2013-2014 '.
Operation of the generator set at each temporary location shall not exceed 1,000 operating
hours per rolling 12-month period.
4
Status:
17.
Status:
18.
Status:
ln compliance. The generator has not been moved from the Tods Substation locati on for
the past two years.
The owner/operator shall use only# 1 or #2 diesel in the generator.
1n compliance. T he facility indicated they use only #1 diesel in the generator.
The sulfur content of diesel fuel burned in the generator shall not exceed 0.05% bv we ight
(500 ppm) as determined by ASTM Method D-4294-89 or equivalent method approved by
the Executive Secretary. The Executive Secretary may request a test of the sulfu r content
of the fuel at any time.
In compliance. See attached 'Low Sulfur Cert'.
Records & Miscellaneous
Status:
Stah1s:
19. The owner/operator shall maintain records of actual hours of operation of the generator set
at the Todd substation and each temporary relocation site. Records of operating hours
shall consist of th e fo llowing:
20.
21.
A. Date
B. Start time
C. Stop time
D. Operating hours
In compliance. The requirements of this condition are maintained in a log book kept with
the generator. The information from the log book is also ma intained in a database at the
Garkane Energy office. See attached 'Tod Gen Log 2013-2014 '.
At all times, including periods of starhtp, shutdown, and malfunction, owners and
operators shall, to the extent practicable, maintain and operate any equipment approved
under this AO, inc luding associated air po llution control equipme nt, in a manner
consistent with good air pollution control practice for minimiz ing emissions.
Determination of whether acceptable operating and maintenance procedures are being
used will be based on the information available to the Executive Secretary which may
in clude, but is not limited to, monitoring results, opacity observations, review of operating
and ma intenance procedures, and inspection of the source. A ll maintenance performed on
the equipment authorized by this AO sha ll be recorded.
in compliance. The requirements of this condition are maintained in a log book kept with
the generator. The information from the log book is also maintained in a database at the
Garkane Energy office.
The owner/operator shall comply with R307-107. General Requirements: Unavoidable
Breakd owns.
5
Status:
Status:
Status:
In compliance. No reportable breakdowns have occurred since the previous compliance
inspection on equipment permitted under this Approval Order. The rule was reviewed
with Mike Avant during the May 4, 2015, teleconference.
AREA SOURCE RULES EVALUATION:
The fo llowing Area Source Rules were evaluated during this inspection:
R307-203. Emission Standards: Sulfur Content of Fuels
ln compliance. This area source rule is satisfied by compliance with condition 18 of the
AO.
R307-205. Emission Standards: Fugitive Emissions and Fugitive Dust
ln compliance. This area source rule is satisfied by compliance with condition 11 of the
AO.
APPLICABLE FEDERAL REQUIREMENTS:
ln addition to the requirements of this AO, and applicable Area Source Rules, the fo llowing federal
programs have been found to apply to the following equipment at this facility.
9. A. One (I) Diesel Generator
Des ign Capacity: 2,593 bhp (1 ,825 kW)
Part 63, Subpart ZZZZ, Table 2d, Requirement #4 -Emergency stationary Cl RICE.
Part 63, Subpart ZZZZ, Table 6, Requirement #9 -Existing emergency and black start
stationary RICE located at an area source of HAP.
Part 63, Subpart ZZZZ, §63.6640(f) -Annual report according to requirements in
paragraphs (h)(l) through (3) of this section to be submitted for calendar year 2015 no
later than March 3 I, 20 l 6 and each subsequent year by March 3 I.
EMlSSION INVENTORY: The facility is not required to s ubmit an emissions inventory to
DAQ. The fo llowing Potential to Emit (PTE) emissions
calculations are taken from the AO:
Pollutant Tons/yr
l . PM10 ................................................................... 0.25
2. S02 ..................................................................... 0.53
3. NOx .................................................................. 26.35
4. CO ...................................................................... 1.03
5. voe ................................................................... o.49
HAPs
6. Benzene ............................................................ 0.007
7. Formaldehyde .................................................... 0.00 I
8. Naphthalene ....................................................... 0.001
9. Toluene .............................................................. 0.002
I 0. Xylenes .............................................................. 0.002
6
PREVIOUS ENFORCEMENT
ACTIONS:
COMPLIANCE ST A TUS &
RECOMMENDATIONS:
HPV STATUS:
RECOMMENDATION FOR
NEXT INSPECTION:
ATTACHMENTS:
11. Other PAHs ....................................................... 0.001
12. Total HAPs ........................................................ 0.01 3
No enforcement actions within th e past five years.
In compliance with the conditions of AO DAQE-
AN0140620001-07, dated October 22, 2007, at the time of
inspection. Required records were current and emailed upon
request.
Facility-specific EPA Annual report requirements were emailed
to the facility.
Not Applicable.
None.
Todd Diesel Generator email, Tod Gen Log 2013-2014, Low
Sulfur Cert, Tods Substation photographs (2), Table 2d to
Subpart ZZZZ of Part 63 (facility-specific requirement #4 only),
Table 6 to Subpart ZZZZ of Part 63 (facili ty-specific requirement
#9 only), Annual report requirements for engines greater than I 00
HP that operate for the purpose specified in §63.6640(f).
7
51512015 Mail -Todd Diesel Generator
Chad Gilgen <[e-mail]>
Todd Diesel Generator
Mike Avant <[e-mail]>
To: Chad Gilgen <[e-mail]>
Mon, May 4, 2015 at 2:52 PM
Chad,
According to the Cat Technical Data Specification for the 3516B Engine, The displacement is 69.0 L. The
engine is a V16 engine so the displacement per cylinder would be 4.3L.
Attached is a copy of the low Sulphur Certification for the diesel used to fuel this unit.
Attached is a summary of the operations log for 2013 and 2014.
Let me know if you need anything else.
Thanks,
Mike Avant
Engineering Manager
Garkane Energy
From: Chad Gilgen [mailto:[e-mail]]
Sent: Monday, May 04, 201510:44 AM
(Quoted text hidden]
(Quoted text hidden]
2 attachments
~ Diesel Fuel Low Sulphur Cert 13Jan15.pdf
546K
~ Tod Gen Log 2013-2014.pdf
9K
https://mail .g oog le.com'mail/u/0/?ui = 2&ik= 36f4379b4d&\iew= pt&search= inbox&msg = 14d20b2aa8e25S4c&sim= 14d20b2aa8e25S4c 1/1
1 CJJ &11 L1 20/J -1otLj
EPA RICE Rule Report EMERGENCY Engine at Area Source
[ Engine Designation
Beginning Ending Total Hours . I Readiness Power Qualified Maintenance Work Location Fuel Start Date Start Time End Date End time Clock Clock of Operation Maintenance Checks Outage Demand Other Justification Performed Operator
Reading Reading (XltX) Response
Tod Gen Set Tod Sub Diesel 7-Mar-13 11:54 7-Mar-13 12:26 280 281 0.5 0.5 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 8-May-13 9:55 8-May-13 10:37 281 281 0.5 0.5 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 10-Jul-13 11:04 10-Jul-13 11:31 282 282 0.5 0.5 Exercise Generator Barton Tod Gen Set Tod Sub Diesel 16-Sep-13 15:00 16-Sep-13 15:30 282 283 0.5 0.5 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 7-Nov-13 13:00 7-Nov-13 13:35 283 284 0.5 0.5 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 5-Dec-13 15:00 5-Dec-13 15:10 284 284 02 0.2 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 6-Feb-14 13:15 6-Feb-14 13:55 284 285 0.7 0.7 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 7-Apr-14 9:06 7-Apr-14 9:43 285 285 0,6 0.6 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 10-Jun-14 12:43 10-Jun-14 13:19 285 286 0.6 0.6 Exercise Generator Barton Tod Gen Set Tod Sub Diesel 7-Aug-14 13:30 7-Aug-14 14:05 286 287 0.5 0.5 Exercise Generator Barton
Tod Gen Set Tod Sub Diesel 6-0ct-14 13:50 6-0ct-14 14:35 287 287 0.5 0.5 Exercise Generator Barton Tod Gen Set Tod Sub Diesel 3-Dec-14 9·40 3-Dec-14 10:10 287 288 0.5 05 Exercise Generator Barton
NOTES.
1. Oil Must be chnaged every Annually or every 500 hours
2. Inspect all hoses and belts Annually or every 500 hours
3. For Cl Engines, Inspect Air Cleaner Annually or every 1000 hours
4. For SI Engines. Inspect Sparl< Plugs Annually or every 1000 hours
5, There Is no time limit on the use of emergency stationary RICE in emergency situations (ie Power Outages)
6. You may operate your emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, or the insurance company associated
with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is
not required if the owner or operator maintains records indicating that Federal, State. or local standards require maintenance and testing of emergency RICE beyond 100 hours per year.
7. You may operate your emergency stationary RICE up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per year pro-.;ded for maintenance and testing. The 50 hours per year for non-emergency situations
cannot be used for peak shaving or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity; except that owners and operators may operate the emergency engine for a
maximum of 15 hours per year as part of a demand response program if the regional transmission organization or equivalent balancing authority and transmission operator has determined there are emergency conditions that could lead to a potential electrical blackout,
such as unusually low frequency, equipment over1oad, capacity or energy deficiency, or unacceptable voltage level. The engine may not be operated for more than 30 minutes prior to the time when the emergency condition is expected to occur, and the engine
operation must be terminated immediately after the facility is notified that the emergency condition is no longer imminent. The 15 hours per year of demand response operation are counted as part of the 50 hours of operation per year provided for non-emergency
situations. The supply of emergency power to another entity or entities pursuant to financial arrangement is not limited by this paragraph (f)(1 )(iii), as long as the power provided by the financial arrangement is hmited to emergency power.
0310
HOLLY E!lilERG~ LP CEDAR CITY ·
4410 N. W£CCO RO~.D
Cedar City ur 84720
Ph: ( 435) SB6-1463
6,~~~ ~ --------
~HTPPPD TO·
\:: COTTAM OlL CO. &S:CQUNI C.URTQMtR TRAN ?QLlQ BOL /I
0001160119 0001100120 530 01/013 0029Q39
35 !:AST MAIN BOX A
ESCALANTE, UT 84726
P.O. BOX 136
Escalante
LQI\P START/STOP
01/13/15 10:18
01/13/15 l.0 :58
BILL OF W\PING
PQ , ORDER .l
UT 84726
RII,LED TQ <transt"';:••>:
COTTAM O!L CO vT
35 EASt MAIN BOX A
ESCAW'.NTE. ur 8~126
?.O. BOX 135
Escal ante UT 8 4726
~HIPPER (Transferor);
RollyFrontier Refining &
Marketing LLC
2628 N. Hor~ood/ ste. 1300
FEINi 20-2008139
FREIGHT: COLLECT ~:58
Dallas TX 15201
THINK SA:BTY AT ALL T!MES .
Nr:Ti;Jl. PRODUCT I,ltSCR!PTION
NA1993, DYED OI:E!SEL FUEL, 3, III NON
TAXABLE US£ ONLYJ PENATLY.,FOR TAXABLE
use. ~1s ppm sulfur (maxi.mum) dyed U~tra
r.ow Sultur Diesel Fuel. ·
For use in all nonroad diesel angi nes.
Not f or uae i n highway ve hicles o~
engines e,;,cept for tax-exempt use in
accordance ~ith secticn ~082 of the
Internal Revenue Code .
.. . ,.i ::"°107 .RP!JLJ:;>2 Dl,S -~~"1-.J'n~.2 ... C!J~sel "....!.) RED DYE 2. 092 Gall one •..
LUBRtC!TY l.852 Gallon~
PREM A!lD 6.996 Gailons
TOTAi., GALLONS
TRAILER,1:101
TAAlLER2 : 4 7
SE -'LE:RT AND DRIVE ALERT.
GROSS GRAV Tf,t!P E
39.0 36.l
......
FOR FRODUCT EMERGENCY-CALL CHE."lTREC#CCN201319 l-800-424-9300
Cl\LL CBBMTa~c~OAY OR. N"IGRTl-800-42,-9300 FACILITY ID 8 2281
10621.
10621
Thie i ~ to certify that the above-named inater ial~ are properly classified, described ,
packaged, marked and la.belled, and are in proper condition f or transportation according
to the applicable regulations of the Department of Tra~sportation.
LOADED BY;
DRIVER: 00003833 Mark Stanley Orton
CARRIER: ORBO Bob Orton Trucking
0 PO Box 113
Panquitch UT 84759
I ce~tify that t he quantity was
received as indicated al:>ove,
except as noted.
/ Ph: {435)676-81,l FEIN: 20-4746917
10/l0 3911d 110 W\111.08
Table 2d to Subpart ZZll of Part 63-Requirements for Existing Stationary RICE Located at Area
Sources of HAP Emissions
As stated in §§63.6603 and 63.6640, you must comply with the following requirements for existing
stationary RICE located at area sources of HAP emissions:
During periods oi
You must meet the following requirement, startup you must
For each ... except during periods of startup . . . . ..
4. Emergency stationary CI a. Change oil and filter every 500 hours of
RJCE and black start operation or annually, whichever comes first; 1
stationary CI RJCE.2
b. Inspect air cleaner every 1,000 hours of
operation or annually, whichever comes first,
and replace as necessary; and
c. Inspect all hoses and belts every 500 hours
of operation or annually, whichever comes
first, and replace as necessary.
1Sources have the option to utilize an oil analysis program as described in §63.6625(i) or U) in order
to extend the specified oil change requirement in Table 2d of this subpart.
21f an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the schedule required in Table 2d
of this subpart, or if performing the management practice on the required schedule would otherwise pose
an unacceptable risk under federal, state, or local law, the management practice can be delayed until the
emergency is over or the unacceptable risk under federal, state, or local law has abated . The
management practice should be performed as soon as practicable after the emergency has ended or the
unacceptable risk under federal, state, or local law has abated. Sources must report any failure to perform
the management practice on the schedule required and the federal, state or local law under which the risk
was deemed unacceptable.
[78 FR 6709, Jan. 30, 2013]
Table 6 to Subpart Z:ZZ.Z of Part 63-Continuous Compliance With Emission Limitations, and
Other Requirements
As stated in §63.6640, you must continuously comply with the emissions and operating limitations
and work or management practices as required by the following:
Complying
with the
requirement to You must demonstrate continuous
For each ... . .. compliance by . . .
9. Existing emergency and black start a. Work or i. Operating and maintaining the
stationary RICE S500 HP located at a Management stationary RICE according to the
major source of HAP, existing non-practices manufacturer's emission-related
emergency stationary RICE <I 00 HP operation and maintenance
located at a major source of HAP, existing instructions; or
emergency and black start stationary RICE ii. Develop and follow your own
located at an area source of HAP, existing maintenance plan which must
non-emergency stationary CI RICE S300 provide to the extent practicable for
HP located at an area source of HAP, the maintenance and operation of the
existing non-emergency 2SLB stationary engine in a manner consistent with
RICE located at an area source of HAP, good air pollution control practice
existing non-emergency stationary SI for minimizing emissions.
RICE located at an area source of HAP
which combusts landfill or digester gas
equivalent to 10 percent or more of the
gross heat input on an annual basis,
existing non-emergency 4SLB and 4SRB
stationary RICE S500 HP located at an
area source of HAP, existing non-
emergency 4SLB and 4SRB stationary
RICE >500 HP located at an area source of
HAP that operate 24 hours or less per
calendar year, and existing non-emergency
4SLB and 4SRB stationary RICE >500 HP
located at an area source of HAP that are
remote stationary RICE
3After you have demonstrated compliance fo r two consecutive tests, you may reduce the frequency
of subsequent performance tests to annually. If the results of any subsequent annual performance test
indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you
deviate from any of your operating limitations, you must resume semiannual performance tests.
Annual report requirements for engines greater than 100 HP
If you own or operate an emergency stationary RICE with a site rating of more than l 00 brake HP that
operates or is contractually obligated to be available for more than 15 hours per calendar year for the
purposes specified in§ 63.6640(f)(2)(ii) and (iii) or that operates for the purpose specified in§
63.6640(f)(4)(ii), you must submit an annual report according to the requirements in paragraphs (h)(l)
through (3) of this section.
(1) The report must contain the following information:
(i) Company name and address where the engine is located.
(ii) Date of the report and beginning and ending dates of the reporting period.
(iii) Engine site rating and model year.
(iv) Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place.
(v) Hours operated for the purposes specified in§ 63 .6640(f)(2)(ii) and (iii), including the date, start time,
and end time for engine operation for the purposes specified in § 63.6640(f)(2)(ii) and (iii).
(vi) Number of hours the engine is contractually obligated to be available for the purposes specified in §
63.6640(t)(2)(ii) and (iii).
(vii) Hours spent for operation for the purpose specified in§ 63.6640(f)(4)(ii), including the date, start
time, and end time for engine operation for the purposes specified in § 63 .6640(f)( 4 )(ii). The report must
also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the
engine.
(viii) If there were no deviations from the fuel requirements in § 63.6604 that apply to the engine (if any),
a statement that there were no deviations from the fuel requirements during the reporting period.
(ix) If there were deviations from the fuel requirements in § 63.6604 that apply to the engine (if any),
information on the number, duration, and cause of deviations, and the corrective action taken.
(2) The first annual report must cover the calendar year 2015 and must be submitted no later than March
31, 20 16. Subsequent annual reports for each calendar year must be submitted no later than March 31 of
the following calendar year.
(3) The annual report must be submitted electronically using the subpart specific reporting form in the
Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central
Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not
available in CEDRI at the time that the report is due, the written report must be submitted to the
Administrator at the appropriate address listed in § 63 .13.
Dungan Adams <[e-mail]>
Review of Garkane Energy Air Permits
23 messages
Dungan Adams <[e-mail]>Fri, Oct 4, 2024 at 3:16 PM
To: [e-mail]
Hi Bryant,
My name is Dungan and I work for the Utah Division of Air Quality (DAQ). I wanted to reach because Garkane Energy has
several older permits in our records and I wanted to see if you are aware of which ones are still being used.
- Todd Substation Portable Diesel Generator (DAQE-AN140620001-07) -- This permit was issued in 2007 and has been
used for a temporary relocation in 2023 according to compliance records. I think it is still used and I have attached the
permit for reference.
- Hatch Substation Portable Diesel Generator (DAQE-774-94) -- This permit was issued in 1994 and the DAQ has no
records of recent temporary relocations. I've attached the permit from the DAQ's records and I'm guessing that this permit
is no longer used by your company.
- Hanksville Substation -- The DAQ does not have records of a permit associated with this site, but the site itself shows up
in our database. Does Garkane operate a substation in Hanksville?
- Portable Diesel Generator -- There is another Garkane site that shows up in our database that has no permit associated
with it. Does Garkane operate multiple portable diesel generators?
For the Hatch Substation Portable Diesel Generator, if it is no longer used, I can revoke the permit. For the last two, if you
are not aware of any operation at these locations or any associated permits, I can classify them as inactive sites.
Thanks,
Dungan
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
2 attachments
DAQE-AN0140620001-07.pdf
495K
DAQE-774-94.docx
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2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
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Bryant Shakespear <[e-mail]>Mon, Oct 7, 2024 at 2:26 PM
To: Dungan Adams <[e-mail]>
Hello Dungan,
Yes, we need to talk. We have actually applied for a couple of temporary relocaon permits for the Todds
Generator that we never got a response back from your office and we would like to speak with someone to
update our current permits.
1. Todd Substation Portable Diesel Generator (DAQE-AN140620001-07) -- This permit was
issued in 2007 and has been used for a temporary relocation in 2023 according to
compliance records. I think it is still used and I have attached the permit for reference.

We still use the "Todds Generator" (DAQE-AN140620001-07). We need to amend this
permit to make the generator's "home base" the location that has historically been the
Hatch Substation Portable Diesel Generator (DAQE-774-94). It is our intention to no
longer keep this generator at our Todds substation under normal circumstances.
2. Hatch Substation Portable Diesel Generator (DAQE-774-94) -- This permit was issued in
1994 and the DAQ has no records of recent temporary relocations. I've attached the permit
from the DAQ's records and I'm guessing that this permit is no longer used by your
company.
Hatch Substation Portable Diesel Generator (DAQE-774-94) machine is being retired
BUT Garkane needs to make the permit location the "home base" for the unit permitted
under DAQE-AN140620001-07 Todds Generator.
3. - Hanksville Substation -- The DAQ does not have records of a permit associated with this
site, but the site itself shows up in our database. Does Garkane operate a substation in
Hanksville?
 I have aached a photo of the permit we have for our Hanksville Generator. We sll use it (very rarely, for a
few hours annually) during outage situaons in Hanksville.
4. Portable Diesel Generator -- There is another Garkane site that shows up in our database
that has no permit associated with it. Does Garkane operate multiple portable diesel
generators?
Yes, we have one other portable generator besides the ones indicated above. It's a smaller 350 kW unit. I
have aached a photo. I suspect that it was permied by your office; I can't find our copy. But as with the
Hanksville unit, not all the informaon may have made its way into your database.
I look forward to hearing from you and am happy to provide any follow up informaon I can.
Best Regards,
Bryant
Bryant Shakespear, PE
Chief Operating Officer
Garkane Energy Cooperative
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r61817728141523…2/13
Mobile [phone]
[e-mail]

From: Dungan Adams <[e-mail]>
Sent: Friday, October 4, 2024 3:16 PM
To: Bryant Shakespear <[e-mail]>
Subject: Review of Garkane Energy Air Permits

HiBryant,MynameisDunganandIworkfortheUtahDivisionofAirQuality(DAQ).IwantedtoreachbecauseGarkaneEnergyhasseveralolderpermitsinourrecordsandIwantedtoseeifyouareawa
Caution: External ([e-mail])
First-Time Sender Details
Report This Email FAQ
[Quoted text hidden]
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Dungan Adams <[e-mail]>Tue, Oct 8, 2024 at 1:05 PM
To: Bryant Shakespear <[e-mail]>
Hi Bryant,
Thanks for getting back to me about these four permits.
In the past, the DAQ permitted sources to have a home base location while also allowing temporary relocation. This style
of permit has not been issued for many years and I think setting a new "home base" might be viewed as a new stationary
source which would require a new permit. The generator being viewed as a new stationary source would complicate this
process, because the older engine would need to meet current control technology standards and Garkane would lose the
ability to temporarily relocate as needed. I will check with my manager and see if what you are requesting for the Todds
Generator is possible without a new permit.
For the Hanksville and Hatch Substation Permits, the process should be more straightforward. Both permits are for 1,100
kW generators that are operated 100 hours or less per year. At this amount of operation, both would qualify for small
source exemptions and the current permits are not required. I can revoke the Hatch Substation Permit if the generator is
being retired and replace the Hanksville Substation Permit with a small source exemption if the generator is still
occasionally used.
Because the generator you sent pictures of is on a trailer, I think there is a good chance that it would be classified as a
nonroad mobile source-- which the DAQ does not permit. As long as the green portable generator is not used at the same
location for 12 consecutive months, there are no permitting requirements. If the generator stays exclusively in one location
for more than 12 consecutive months, let me know and we can figure out how to proceed.
Let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
Bryant Shakespear <[e-mail]>Tue, Oct 8, 2024 at 3:15 PM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Thanks, Dungan,
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r61817728141523…5/13
Before you revoke or alter any permits, I would like to know what your supervisor says. I would also like to
schedule a call with me and my consultant to discuss Garkane's opons.
Please provide some potenal mes that work for you to have a call.
Best,
Bryant
From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 8, 2024 1:05 PM
To: Bryant Shakespear <[e-mail]>
Subject: Re: Review of Garkane Energy Air Permits

[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Oct 8, 2024 at 3:20 PM
To: Bryant Shakespear <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Bryant,
Of course, the DAQ can't revoke permits without explicit source concurrence. I am available to meet anytime after 10am
this Thursday or Friday and have some scattered availability tomorrow. After this week I will be out of the office until
October 22nd.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Oct 8, 2024 at 3:25 PM
To: Bryant Shakespear <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Based on Eric's availability, it looks like this week won't work and we will have to wait until I am back in the office. I will
reach out when I am back and we can get something scheduled.
Thanks,
Dungan
[Quoted text hidden]
Bryant Shakespear <[e-mail]>Tue, Oct 8, 2024 at 3:30 PM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Very Good, Thanks
From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 8, 2024 3:25 PM
To: Bryant Shakespear <[e-mail]>
Cc: [e-mail] <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Oct 24, 2024 at 11:29 AM
To: Bryant Shakespear <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r61817728141523…6/13
Hi Bryant,
Let's set up a time to meet and discuss Garkane's permits and the requests you mentioned. I am available to meet next
Monday or Tuesday before 1pm, or next Thursday or Friday after 10am. I am also available anytime tomorrow if you want
to have a call then. Let me know if any of these times work for you, otherwise suggest some times that do, and I can
adjust my schedule.
Thanks,
Dungan
[Quoted text hidden]
Clark, Eric <[e-mail]>Thu, Oct 24, 2024 at 11:32 AM
To: Dungan Adams <[e-mail]>, Bryant Shakespear <[e-mail]>
All –

I can make most of those times. Monday or Tuesday is best for me. Thursday afternoon is also ok. I am unavailable
Friday afternoon.

Eric Clark, P.E.
Senior Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
[Quoted text hidden]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
Bryant Shakespear <[e-mail]>Thu, Oct 24, 2024 at 11:52 AM
To: "Clark, Eric" <[e-mail]>, Dungan Adams <[e-mail]>
Monday and Tuesday are booked up for me. Anytime Thursday would work fine for me.
Dungan do you want to send out a invite link?
Bryant
Get Outlook for iOS
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r61817728141523…7/13
From: Clark, Eric <[e-mail]>
Sent: Thursday, October 24, 2024 11:32:31 AM
To: Dungan Adams <[e-mail]>; Bryant Shakespear <[e-mail]>
Subject: RE: Review of Garkane Energy Air Permits

[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Oct 24, 2024 at 12:09 PM
To: Bryant Shakespear <[e-mail]>
Cc: "Clark, Eric" <[e-mail]>
I just sent out the invite link for Thursday, October 31 at 1pm. Let me know if anything changes and we need to find
another time.
Thanks,
Dungan
[Quoted text hidden]
Clark, Eric <[e-mail]>Thu, Oct 24, 2024 at 12:13 PM
To: Dungan Adams <[e-mail]>, Bryant Shakespear <[e-mail]>
Dungan,

Thanks
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Oct 31, 2024 at 2:00 PM
To: Bryant Shakespear <[e-mail]>
Hi Bryant,
Here are the links to the permit revocation request and the small source exemption application. You will need to fill out
one revocation and one small source exemption for each of the Hatch and Hanksville permits.
This is the key information for the permit revocation forms:
Site Name Site ID Permit ID Subject to O&G PBR Explanation for the revocation
request
Hatch Substation 11399 DAQE-774-94 No Replacing permit with Small Source
Exemption
Hanksville Substation 11400 DAQE-775-94 No Replacing permit with Small Source
Exemption
For each small source exemption (SSE) form, briefly describe what the generator is used for, list the generator as the
emission unit, and attach the emission calculation spreadsheet I have attached in this email. You can put N/A for pollution
control equipment. The emission calculation spreadsheet I have attached estimates the emissions for one (1) 1100kW
diesel generator with a NOx emission rate of 14g/hp-hr operated for 100 hours per year. If this information is no longer
accurate please update the spreadsheet accordingly. The two SSE forms should be almost identical with different Site
Names
For the Todd permit, the listed addresses are:
Site Office Corporate Office Location
Garkane Energy Warehouse Garkane Energy
1802 South 175 East Post Office Box 465
Kanab, Utah 84741 Loa, Utah 84747
Does any of this need to be updated?
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r61817728141523…8/13
Let me know if you have any questions and I am happy to help out.
Thanks,
Dungan Adams
[Quoted text hidden]
Engine - Diesel.xlsx
81K
Dungan Adams <[e-mail]>Thu, Nov 14, 2024 at 3:04 PM
To: Bryant Shakespear <[e-mail]>
Hi Bryant,
I wanted to follow up about the email I sent a few weeks ago. Please let me know if you have any questions about the
permit revocation, the small source exemption, or the 10-year review.
Thanks,
Dungan
[Quoted text hidden]
Bryant Shakespear <[e-mail]>Fri, Nov 15, 2024 at 6:37 AM
To: Dungan Adams <[e-mail]>
Dungan,
Thank you for the reminder. I completed the forms for the Hatch and Hanksville generators this morning.
Please let me know if you don't see them on your perming applicaon traking system.
Below are some minor changes to the Todd's permit informaon.
Site Office
Garkane Energy Cooperave, Inc
1802 South 175 East
Kanab, Utah 84741
Cooperate Office Locaon
Garkane Energy Cooperave, Inc
1802 South 175 East
Kanab, Utah 84741
Best Regards
Bryant Shakespear, PE
Chief Operating Officer
Garkane Energy Cooperative
Mobile [phone]
[e-mail]

2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r61817728141523…9/13

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 3:04 PM
[Quoted text hidden]

[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Nov 15, 2024 at 10:03 AM
To: Bryant Shakespear <[e-mail]>
Great, thank you! I will let you know if any questions come up.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Mon, Dec 9, 2024 at 4:16 PM
To: Bryant Shakespear <[e-mail]>
Hi Bryant,
What is the physical address of the Todd Substation? I don't think the site office/corporate office addresses are where the
substation is located. I found "0.75 miles North of US89 and SR14" in our database, but I would like to confirm that is
correct. If you can provide the lat/long coordinates of the substation that would be great.
Thanks,
Dungan
[Quoted text hidden]
Bryant Shakespear <[e-mail]>Wed, Dec 11, 2024 at 3:00 PM
To: Dungan Adams <[e-mail]>
Dungan,
The permit home locaon is 37°29'55.31"N, 112°30'18.80"W, which is near the intersecon of Steed Drive
and US Hwy 89.
Best Regards,
Bryant
Bryant Shakespear, PE
Chief Operating Officer
Garkane Energy Cooperative
Mobile [phone]
[e-mail]

2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r6181772814152…10/13
From: Dungan Adams <[e-mail]>
Sent: Monday, December 9, 2024 4:16 PM
To: Bryant Shakespear <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
Garkane EX2000 Cat Generator.kmz
1K
Bryant Shakespear <[e-mail]>Mon, Dec 30, 2024 at 1:38 PM
To: Dungan Adams <[e-mail]>
Cc: Daniel Thompson <[e-mail]>, Gerry Hoyt <[e-mail]>
Dungan,
Can I get your help? Roughly two weeks ago, Garkane submied a Temporary Relocaon Permit Applicaon
for our Todds Generator to move it to Hatch for some me. We have not received any correspondence from
your office. This happened last me we made a similar applicaon and never heard anything back. Can you
please provide me with some guidance on who we need to speak with or what needs to be done?
Best Regards,
Bryant Shakespear, PE
Chief Operating Officer
Garkane Energy Cooperative
Mobile [phone]
[e-mail]

From: Bryant Shakespear <[e-mail]>
Sent: Monday, December 9, 2024 6:40 PM
To: Dungan Adams <[e-mail]>
[Quoted text hidden]

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secure.utah.gov_govpay_checkout_creditcard_confirm.pdf
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TRAL APPLICATION HATCH 20241209.pdf
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FUGIATIVE DUST PLAN.pdf
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2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
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Dungan Adams <[e-mail]>Thu, Jan 9, 2025 at 3:54 PM
To: Bryant Shakespear <[e-mail]>
Cc: Daniel Thompson <[e-mail]>, Gerry Hoyt <[e-mail]>
Hi Bryant,
Sorry for the delay, I was on vacation over the holidays. I will reach out to the DAQ compliance division and see what is
going on. Thanks for bringing this to my attention.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Jan 28, 2025 at 9:11 AM
To: Bryant Shakespear <[e-mail]>
Cc: Daniel Thompson <[e-mail]>, Gerry Hoyt <[e-mail]>
Hi Bryant,
The Temporary Relocation Authorization letter for the Todd generator relocation was mailed out today. Approval has been
granted for temporary relocation and you should receive the letter soon.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Feb 18, 2025 at 12:26 PM
To: Bryant Shakespear <[e-mail]>
Hi Bryant,
Attached is the draft of the updated permit for Garkane's Todd Substation Portable Generator. Since this permit was first
issued, state rules regarding portable equipment have changed, and these changes are reflected in the updated permit.
Please review conditions II.B.1.d, II.B.1.d.1, and II.B.1.d.2 and be aware of these rule based changes.
Let me know if you have any questions about the draft. If everything looks good, please sign the cover page and return
the document to me.
Thanks,
Dungan
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RN140620003.rtf
1509K
Bryant Shakespear <[e-mail]>Fri, Feb 21, 2025 at 8:23 AM
To: Dungan Adams <[e-mail]>
Dungan,
Please see the aached signed concurrence.
Best Regards,
Bryant
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r6181772814152…12/13
Bryant Shakespear, PE
Chief Operating Officer
Garkane Energy Cooperative
Mobile [phone]
[e-mail]

From: Dungan Adams <[e-mail]>
Sent: Tuesday, February 18, 2025 12:26 PM
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Garkane concurrence permit renew.pdf
320K
2/24/25, 1:47 PM State of Utah Mail - Review of Garkane Energy Air Permits
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r4944977740376299349&simpl=msg-a:r6181772814152…13/13