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Home My WebLink AboutDAQ-2025-001459 DAQE-AN124950011-25 {{$d1 }} Travis Ball Utah Municipal Power Agency 75 West 300 North P.O. Box 818 Spanish Fork, UT 84660 tball@umpa.energy Dear Mr. Ball: Re: Approval Order: Administrative Amendment to Approval Order DAQE-282-02 for a 10-Year Review and Permit Updates Project Number: N124950011 The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year administrative review of this source and its respective AO. Utah Municipal Power Agency must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Stockton Antczak, who can be contacted at (385) 306-6724 or santczak@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. Sincerely, {{$s }} Bryce C. Bird Director BCB:SA:jg cc: Salt Lake County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director March 6, 2025 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-AN124950011-25 Administrative Amendment to Approval Order DAQE-282-02 for a 10-Year Review and Permit Updates Prepared By Stockton Antczak, Engineer (385) 306-6724 santczak@utah.gov Issued to Utah Municipal Power Agency - West Valley Power Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality March 6, 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.................................................................................................................. 3 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 5 PERMIT HISTORY ..................................................................................................................... 7 ACRONYMS ................................................................................................................................. 8 DAQE-AN124950011-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Utah Municipal Power Agency Utah Municipal Power Agency - West Valley Power Plant Mailing Address Physical Address 75 West 300 North P.O. Box 818 5935 West 4700 South West Valley City, UT 84128 Spanish Fork, UT 84660 Source Contact UTM Coordinates Name: Travis Ball 412,737 m Easting Phone: (801) 472-8863 4,502,274 m Northing Email: tball@umpa.energy Datum NAD83 UTM Zone 12 SIC code 4911 (Electric Services) SOURCE INFORMATION General Description Utah Municipal Power Agency operates a power generation facility located in West Valley City. The West Valley Power Plant operates five (5) natural gas turbines, each with a rating of 43.4 MW. NSR Classification 10-Year Review Source Classification Located in Salt Lake County PM10 Maint Area, Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: A Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), GG: Standards of Performance for Stationary Gas Turbines Title IV (Part 72 / Acid Rain) Project Description This is a 10-year review of the AO DAQE-282-02 dated April 18, 2002. This project updated the previous AO to include current permitting language and formatting. DAQE-AN124950011-25 Page 4 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) Carbon Monoxide 0 191.63 Nitrogen Oxides 0 162.06 Particulate Matter - PM10 0 58.41 Sulfur Dioxide 0 12.09 Volatile Organic Compounds 0 12.09 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Formaldehyde (CAS #50000) 0 8180 Total HAPs (CAS #THAPS) 0 11820 Change (TPY) Total (TPY) Total HAPs 0 10.00 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 in accordance with UAC R307-401. [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 five-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 five (5) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and Monitoring. [R307-150] DAQE-AN124950011-25 Page 5 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 West Valley Power Plant II.A.2 Natural Gas Turbines Five (5) GE LM6000 PC Sprint natural gas simple cycle turbines, each with water injection, evaporative spray mist inlet air cooling, Selective Catalytic Reduction (SCR) catalyst, and CO oxidation catalyst. Each engine characteristics: Site rated output at baseload, 20F: 43.4 MW Heat rate at baseload, 20F: 8,393 Btu/kW-hr (natural gas LHV of 935.34 Btu/scf) Maximum firing rate: 389,186 scf/hr (at 20F) Stack exit height: 81 feet Stack exit diameter: 12 feet SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: All natural gas combustion exhausts - 10% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401] II.B.1.b In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, NSPS Subpart A, 40 CFR 60.1 to 60.18, and Subpart GG, 40 CFR 60.330 to 60.334 (Standards of Performance for Stationary Gas Turbines) apply to this installation. Sulfur monitoring can be waived for pipeline-quality natural gas [40 CFR 72.7.(d).(1)]. Nitrogen monitoring can be waived for pipeline-quality natural gas, since there is no fuel-bound nitrogen and since the fuel nitrogen does not contribute appreciably to NOx emissions [USEPA Memo, August 14, 1987]. [R307-401] II.B.1.c The owner/operator shall use only pipeline-quality natural gas as a fuel in the turbines. [R307-401] II.B.1.d In addition to the requirements of this AO, the owner/operator shall comply with all applicable provisions of 40 CFR Parts 72, 73, 75, 76, 77, and 78 - Federal regulations for the Acid Rain Program under Clean Air Act Title IV. [R307-401] DAQE-AN124950011-25 Page 6 II.B.1.e The owner/operator shall install, calibrate, maintain, and operate a continuous monitoring system for measuring nitrogen oxides and carbon monoxide emissions discharged to the atmosphere from each turbine stack and record the output of the system. The monitoring system shall be used for measuring and determining compliance. The continuous monitoring system shall comply with applicable provisions of UAC, R307-170, and applicable federal regulations for the Acid Rain Program under Clean Air Act Title IV. [R307-401] II.B.2 Natural Gas Turbine Requirements II.B.2.a Emissions to the atmosphere from the indicated emission points shall not exceed the following rates and concentrations: Source: Each LM6000 Turbine Exhaust Stack Pollutant lb/hr* ppmdv** ppmdv*** (15% O2 dry) (15% O2 dry) (15% O2 dry) (30-day rolling (30-day rolling average) average) NOx 37 5 100 CO 43.75 10 NA * Total emissions for all five (5) turbines under steady state operation not including startups and shutdowns. ** Emissions from an individual turbine under steady state operation not including startups and shutdowns. *** Emissions from an individual turbine (in accordance with 40 CFR 60 Subpart GG requirements). [R307-401] II.B.2.b Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: [R307-401] II.B.2.b.1 Testing Status and Frequency Testing Test Emissions Point Pollutant Status Frequency Turbine #1 to #4 NOx * CEMs Exhaust Stack CO * CEMs Turbine #5 NOx * CEMs Exhaust Stack CO * CEMs * Initial testing has been performed. [R307-401] DAQE-AN124950011-25 Page 7 II.B.2.b.2 Notification The Director shall be notified at least 45 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and binder sampling procedures to be used. A pretest conference shall be held if directed by the Director. [R307-401] II.B.2.b.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-401] II.B.2.b.4 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-401] II.B.2.b.5 Nitrogen Oxides (NOx) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or Method 20. [R307-401] II.B.2.c NOx emissions in lbs/hr shall be calculated from the ppmvd CEMs recorded data using 40 CFR 60 Appendix A, Method 19. CO emissions in lbs/hr shall be calculated from the ppmvd CEMs recorded based on 40 CFR 60 Appendix A, Method 19. [R307-401] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-282-02 dated April 18, 2002 DAQE-AN124950011-25 Page 8 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- RN124950011 January 16, 2025 Travis Ball Utah Municipal Power Agency Utah Municipal Power Agency 75 West 300 North P.O. Box 818 Spanish Fork, UT 84660 tball@umpa.energy Dear Travis Ball, Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-282-02 for a 10-Year Review Project Number: N124950011 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. Utah Municipal Power Agency should complete this review within 10 business days of receipt. Utah Municipal Power Agency should contact Stockton Antczak at (385) 306-6724 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Stockton Antczak at santczak@utah.gov 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 Utah Municipal Power Agency does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Utah Municipal Power Agency 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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 Lieutenant Governor 2/3/2025 Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N124950011 Owner Name Utah Municipal Power Agency Mailing Address Utah Municipal Power Agency 75 West 300 North P.O. Box 818 Spanish Fork, UT, 84660 Source Name Utah Municipal Power Agency - West Valley Power Plant Source Location 5935 West 4700 South West Valley City, UT 84128 UTM Projection 412,737 m Easting, 4,502,274 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4911 (Electric Services) Source Contact Travis Ball Phone Number (801) 472-8863 Email tball@umpa.energy Billing Contact Travis Ball Phone Number 801-472-8863 Email tball@umpa.energy Project Engineer Stockton Antczak, Engineer Phone Number (385) 306-6724 Email santczak@utah.gov Notice of Intent (NOI) Submitted October 16, 2024 Date of Accepted Application November 5, 2024 Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 2 SOURCE DESCRIPTION General Description Utah Municipal Power Agency operates a power generation facility located in West Valley City. The West Valley Power Plant operates five natural gas turbines, each with rating of 43.4 MW. NSR Classification: 10 Year Review Source Classification Located in the Salt Lake County PM10 Maint Area, Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, and Salt Lake County SO2 NAA, Salt Lake County Airs Source Size: A Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), GG: Standards of Performance for Stationary Gas Turbines Title IV (Part 72 / Acid Rain) Project Proposal Administrative Amendment to Approval Order DAQE-282-02 for a 10-Year Review Project Description This is a 10-Year Review of the Approval Order DAQE-282-02 dated April 18, 2002. This project updated the previous AO to include current permitting language and formatting. EMISSION IMPACT ANALYSIS This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, a modeling analysis is not required. [Last updated January 7, 2025] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 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) Carbon Monoxide 0 191.63 Particulate Matter - PM10 0 58.41 Sulfur Dioxide 0 12.09 Volatile Organic Compounds 0 12.09 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Formaldehyde (CAS #50000) 0 8180 Total HAPs (CAS #THAPS) 0 11820 Change (TPY) Total (TPY) Total HAPs 0 10.00 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 4 Review of BACT for New/Modified Emission Units . BACT review regarding Site Equipment 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 January 7, 2025] 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 Utah Administrative Code (UAC) Rule 307 (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. [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 in accordance with UAC R307- 401. [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 five (5) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307- 401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and Monitoring. [R307-150] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 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 Permitted Source West Valley Power Plant II.A. Natural Gas Turbines Five (5) GE LM6000 PC Sprint natural gas simple cycle turbines each with water injection, evaporative spray mist inlet air cooling, Selective Catalytic Reduction (SCR) catalyst and CO oxidation catalyst. Each engine characteristics: Site rated output at baseload, 20F: 43.4 MW Heat rate at baseload, 20F: 8,393 Btu/kW-hr (natural gas LHV of 935.34 Btu/scf) Maximum firing rate: 389,186 scf/hr (at 20F) Stack exit height: 81 feet Stack exit diameter: 12 feet 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 Site Wide Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: All natural gas combustion exhausts - 10% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 6 II.B.1.b In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18 and Subpart GG, 40 CFR 60.330 to 60.334 (Standards of Performance for Stationary Gas Turbines) apply to this installation. Sulfur monitoring can be waived for pipeline quality natural gas [40 CFR 72.7.(d).(1)]. Nitrogen monitoring can be waived for pipeline quality natural gas, since there is no fuel bound nitrogen and since the fuel nitrogen does not contribute appreciably to NOx emissions [USEPA Memo, August 14, 1987]. [R307-401] II.B.1.c The owner/operator shall use only pipeline quality natural gas as a fuel in the turbines. [R307- 401] II.B.1. In addition to the requirements of this AO, the owner/operator shall comply with all applicable provisions of 40 CFR Part 72, 73, 75, 76, 77, and 78 - Federal regulations for the Acid Rain Program under Clean Air Act Title IV. [R307-401] II.B.1.e The owner/operator shall install, calibrate, maintain, and operate a continuous monitoring system for measuring nitrogen oxides and carbon monoxide emissions discharged to the atmosphere from each turbine stack and record the output of the system. The monitoring system shall be used for measuring and determining compliance. The continuous monitoring system shall comply with applicable provisions of UAC, R307-170 and applicable Federal regulations for the Acid Rain Program under Clean Air Act Title IV. [R307-401] II.B.2 Natural Gas Turbine Requirements II.B.2.a Emissions to the atmosphere from the indicated emission points shall not exceed the following rates and concentrations: Source: Each LM6000 Turbine Exhaust Stack Pollutant lb/hr* ppmdv** ppmdv*** (15% O2 dry) (15% O2 dry) (15% O2 dry) (30-day rolling (30-day rolling average) average) NOx 37 5 100 CO 43.75 10 NA * Total emissions for all five turbines under steady state operation not including startups and shutdowns ** Emissions from an individual turbine under steady state operation not including startups and shutdowns *** Emissions from an individual turbine (in accordance with 40 CFR 60 Subpart GG requirements). [R307-401] II.B.2.b Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: [R307-401] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 7 II.B.2.b.1 Testing Status and Frequency Testing Test Emissions Point Pollutant Status Frequency Turbine #1 to #4 NOx *, ** CEMs Exhaust Stack CO *,** CEMs Turbine #5 NOx ** CEMs Exhaust Stack CO CEMs * The initial testing has already been performed on turbines #3 and #4. ** Initial compliance testing for NOx for turbines #1, #2, and #5 shall be performed in accordance with the 40 CFR 60 Subpart GG. Initial compliance testing shall be performed within 60 days after achieving the maximum production rate at which the affected facility will be operated and in no case later than 180 days after the startup of a new emission source. [R307-401] II.B.2.b.2 Notification The Director shall be notified at least 45 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and binder sampling procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-401] II.B.2.b.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-401] II.B.2.b.4 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-401] II.B.2.b.5 Nitrogen Oxides (NOx) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E or Method 20. [R307-401] II.B.2.c NOx emissions in lbs/hr shall be calculated from the ppmvd CEMs recorded data using 40 CFR 60 Appendix A, Method 19. CO emissions in lbs/hr shall be calculated from the ppmvd CEMs recorded based on 40 CFR 60 Appendix A, Method 19. [R307-401] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 8 Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 9 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-282-02 dated April 18, 2002 REVIEWER COMMENTS 1. Comment regarding Summary of Changes: Contact and location information for the source were updated. The formatting of the conditions and permit were updated. Conditions 1, 6, and 8 were removed as the information in these conditions are found in the general language of the permit and do not need their own condition. Conditions 9, 18, and 22 were removed because no new equipment or plans need to be submitted as a result of this project. The general conditions were updated and the remaining conditions were re-arranged to match current permitting organization. [Last updated January 7, 2025] 2. Comment regarding NSPS Applicability: 40 CFR 60 Subpart GG is applicable to all stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per hour, based on the lower heating value of the fuel fired. The turbines on site are applicable to this subpart. [Last updated January 7, 2025] 3. 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, 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; or 4. Any Title IV affected source. This source is considered a major source, and it is a Title IV affected source. Therefore Title V applies to this source. [Last updated January 7, 2025] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 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 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- RN124950011 January 16, 2025 Travis Ball Utah Municipal Power Agency Utah Municipal Power Agency 75 West 300 North P.O. Box 818 Spanish Fork, UT 84660 tball@umpa.energy Dear Travis Ball, Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-282-02 for a 10-Year Review Project Number: N124950011 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. Utah Municipal Power Agency should complete this review within 10 business days of receipt. Utah Municipal Power Agency should contact Stockton Antczak at (385) 306-6724 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Stockton Antczak at santczak@utah.gov 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 Utah Municipal Power Agency does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Utah Municipal Power Agency 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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 Lieutenant Governor 2/3/2025 Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N124950011 Owner Name Utah Municipal Power Agency Mailing Address Utah Municipal Power Agency 75 West 300 North P.O. Box 818 Spanish Fork, UT, 84660 Source Name Utah Municipal Power Agency - West Valley Power Plant Source Location 5935 West 4700 South West Valley City, UT 84128 UTM Projection 412,737 m Easting, 4,502,274 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4911 (Electric Services) Source Contact Travis Ball Phone Number (801) 472-8863 Email tball@umpa.energy Billing Contact Travis Ball Phone Number 801-472-8863 Email tball@umpa.energy Project Engineer Stockton Antczak, Engineer Phone Number (385) 306-6724 Email santczak@utah.gov Notice of Intent (NOI) Submitted October 16, 2024 Date of Accepted Application November 5, 2024 Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 2 SOURCE DESCRIPTION General Description Utah Municipal Power Agency operates a power generation facility located in West Valley City. The West Valley Power Plant operates five natural gas turbines, each with rating of 43.4 MW. NSR Classification: 10 Year Review Source Classification Located in the Salt Lake County PM10 Maint Area, Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, and Salt Lake County SO2 NAA, Salt Lake County Airs Source Size: A Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), GG: Standards of Performance for Stationary Gas Turbines Title IV (Part 72 / Acid Rain) Project Proposal Administrative Amendment to Approval Order DAQE-282-02 for a 10-Year Review Project Description This is a 10-Year Review of the Approval Order DAQE-282-02 dated April 18, 2002. This project updated the previous AO to include current permitting language and formatting. EMISSION IMPACT ANALYSIS This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, a modeling analysis is not required. [Last updated January 7, 2025] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 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) Carbon Monoxide 0 191.63 Particulate Matter - PM10 0 58.41 Sulfur Dioxide 0 12.09 Volatile Organic Compounds 0 12.09 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Formaldehyde (CAS #50000) 0 8180 Total HAPs (CAS #THAPS) 0 11820 Change (TPY) Total (TPY) Total HAPs 0 10.00 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 4 Review of BACT for New/Modified Emission Units . BACT review regarding Site Equipment 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 January 7, 2025] 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 Utah Administrative Code (UAC) Rule 307 (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. [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 in accordance with UAC R307- 401. [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 five (5) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307- 401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and Monitoring. [R307-150] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 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 Permitted Source West Valley Power Plant II.A. Natural Gas Turbines Five (5) GE LM6000 PC Sprint natural gas simple cycle turbines each with water injection, evaporative spray mist inlet air cooling, Selective Catalytic Reduction (SCR) catalyst and CO oxidation catalyst. Each engine characteristics: Site rated output at baseload, 20F: 43.4 MW Heat rate at baseload, 20F: 8,393 Btu/kW-hr (natural gas LHV of 935.34 Btu/scf) Maximum firing rate: 389,186 scf/hr (at 20F) Stack exit height: 81 feet Stack exit diameter: 12 feet 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 Site Wide Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: All natural gas combustion exhausts - 10% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 6 II.B.1.b In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18 and Subpart GG, 40 CFR 60.330 to 60.334 (Standards of Performance for Stationary Gas Turbines) apply to this installation. Sulfur monitoring can be waived for pipeline quality natural gas [40 CFR 72.7.(d).(1)]. Nitrogen monitoring can be waived for pipeline quality natural gas, since there is no fuel bound nitrogen and since the fuel nitrogen does not contribute appreciably to NOx emissions [USEPA Memo, August 14, 1987]. [R307-401] II.B.1.c The owner/operator shall use only pipeline quality natural gas as a fuel in the turbines. [R307- 401] II.B.1. In addition to the requirements of this AO, the owner/operator shall comply with all applicable provisions of 40 CFR Part 72, 73, 75, 76, 77, and 78 - Federal regulations for the Acid Rain Program under Clean Air Act Title IV. [R307-401] II.B.1.e The owner/operator shall install, calibrate, maintain, and operate a continuous monitoring system for measuring nitrogen oxides and carbon monoxide emissions discharged to the atmosphere from each turbine stack and record the output of the system. The monitoring system shall be used for measuring and determining compliance. The continuous monitoring system shall comply with applicable provisions of UAC, R307-170 and applicable Federal regulations for the Acid Rain Program under Clean Air Act Title IV. [R307-401] II.B.2 Natural Gas Turbine Requirements II.B.2.a Emissions to the atmosphere from the indicated emission points shall not exceed the following rates and concentrations: Source: Each LM6000 Turbine Exhaust Stack Pollutant lb/hr* ppmdv** ppmdv*** (15% O2 dry) (15% O2 dry) (15% O2 dry) (30-day rolling (30-day rolling average) average) NOx 37 5 100 CO 43.75 10 NA * Total emissions for all five turbines under steady state operation not including startups and shutdowns ** Emissions from an individual turbine under steady state operation not including startups and shutdowns *** Emissions from an individual turbine (in accordance with 40 CFR 60 Subpart GG requirements). [R307-401] II.B.2.b Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: [R307-401] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 7 II.B.2.b.1 Testing Status and Frequency Testing Test Emissions Point Pollutant Status Frequency Turbine #1 to #4 NOx *, ** CEMs Exhaust Stack CO *,** CEMs Turbine #5 NOx ** CEMs Exhaust Stack CO CEMs * The initial testing has already been performed on turbines #3 and #4. ** Initial compliance testing for NOx for turbines #1, #2, and #5 shall be performed in accordance with the 40 CFR 60 Subpart GG. Initial compliance testing shall be performed within 60 days after achieving the maximum production rate at which the affected facility will be operated and in no case later than 180 days after the startup of a new emission source. [R307-401] II.B.2.b.2 Notification The Director shall be notified at least 45 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and binder sampling procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-401] II.B.2.b.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-401] II.B.2.b.4 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-401] II.B.2.b.5 Nitrogen Oxides (NOx) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E or Method 20. [R307-401] II.B.2.c NOx emissions in lbs/hr shall be calculated from the ppmvd CEMs recorded data using 40 CFR 60 Appendix A, Method 19. CO emissions in lbs/hr shall be calculated from the ppmvd CEMs recorded based on 40 CFR 60 Appendix A, Method 19. [R307-401] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 8 Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 Page 9 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-282-02 dated April 18, 2002 REVIEWER COMMENTS 1. Comment regarding Summary of Changes: Contact and location information for the source were updated. The formatting of the conditions and permit were updated. Conditions 1, 6, and 8 were removed as the information in these conditions are found in the general language of the permit and do not need their own condition. Conditions 9, 18, and 22 were removed because no new equipment or plans need to be submitted as a result of this project. The general conditions were updated and the remaining conditions were re-arranged to match current permitting organization. [Last updated January 7, 2025] 2. Comment regarding NSPS Applicability: 40 CFR 60 Subpart GG is applicable to all stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per hour, based on the lower heating value of the fuel fired. The turbines on site are applicable to this subpart. [Last updated January 7, 2025] 3. 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, 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; or 4. Any Title IV affected source. This source is considered a major source, and it is a Title IV affected source. Therefore Title V applies to this source. [Last updated January 7, 2025] Engineer Review N124950011: Utah Municipal Power Agency - West Valley Power Plant January 16, 2025 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 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 Stockton Antczak <santczak@utah.gov> Subject: 10-Year Review for Air Quality Permit DAQE-282-02 1 message Travis Ball <tball@umpa.energy>Wed, Nov 6, 2024 at 7:48 AM To: "santczak@utah.gov" <santczak@utah.gov> Cc: Jerame Blevins <Jerame@umpa.energy> Stockton, See the responses to your quesons in the body of your email. From: Stockton Antczak <santczak@utah.gov> Sent: Tuesday, November 5, 2024 10:41 AM To: Kevin Garlick <kevin@umpa.energy> Subject: 10-Year Review for Air Quality Permit DAQE-282-02 Cauon! This message was sent from outside your organizaon.Allow sender | Block sender | Report Utah Municipal Power Agency, The Utah Division of Air Quality is conducng a 10-year review of the West Valley Power Plant and the Approval Order (AO) associated with it DAQE-282-02. This review will update the formang and language of this AO to make it similar to modern permits. The permit requirements will stay the same. However, if state or federal laws have changed since your AO was issued, the requirements in your AO may be subject to change. Your or your company will NOT be charged anything for this project. I just have a couple quesons. Are you sll the best person to contact regarding the Approval Order? Kevin Garlick has rered, and I was hired to replace him. My name is Travis Ball, email address: tball@umpa.energy Are these the correct addresses for this site? Yes, the address is correct. Physical: 5935 West 4700 South West Valley City, UT 84128 Mailing: Same as physical address Is this the correct name of this site? Yes Utah Municipal Power Agency - West Valley Power Plant If you have any quesons for me as the engineer over this project, please reach out. Best Regards, Stockton Antczak 2/28/25, 1:57 PM State of Utah Mail - Subject: 10-Year Review for Air Quality Permit DAQE-282-02 https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1814984954602248046&simpl=msg-f:1814984954602248046 1/2 -- Stockton J. Antczak | Perming Engineer | Major New Source Review 385-306-6724 (cell) 195 North 1950 West, Salt Lake City, UT 84116 Travis Ball, P.E. | VP - Generaon a: 696 W 100 S | Spanish Fork, UT 84660 e: tball@umpa.energy | w: www.umpa.energy m: (801)472-8863 | p: (801)803-5476 NOTE: This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for theuse of the individual or entity designated above. SENDER EXPRESSLY PRESERVES AND ASSERTS ALL PRIVILEGES AND IMMUNITIES APPLICABLE TO THISEMAIL. If you are not the intended recipient of this message, please notify the sender immediately, and delete the message, any attachments, and the reply. Anydisclosure, reproduction, distribution or other use including taking any action in reliance on the contents of this email transmission or any attachments by an individual orentity other than the intended recipient is prohibited. 2/28/25, 1:57 PM State of Utah Mail - Subject: 10-Year Review for Air Quality Permit DAQE-282-02 https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1814984954602248046&simpl=msg-f:1814984954602248046 2/2 Pollutant AO (tpy)Title V Renewal (tpy) Carbon Monoxide 191.63 191.63 Particulate Matter - PM10 58.41 57.60 Sulfur Dioxide 12.09 29.67 Volatile Organic Compounds 12.09 18.33 Formaldehyde 4.09 6.20 Total HAPs 5.91 8.97 Stockton Antczak <santczak@utah.gov> West Valley Power Plant Air Quality Permit 10-Year Review 4 messages Melissa Armer <marmer@trinityconsultants.com>Tue, Feb 4, 2025 at 11:15 AM To: "santczak@utah.gov" <santczak@utah.gov> Cc: Travis Ball <tball@umpa.energy>, "jerame@umpa.energy" <jerame@umpa.energy> Hi Stockton, UMPA passed along your 10-year permit review, which I reviewed and below are some notes and questions. I compared the summary of emissions to what we included for the Title V renewal application, and they are not consistent. See table below. II.B.2.b.1 states that initial compliance testing has been completed for turbines #3 and #4 and indicates that initial compliance testing may still be needed for turbines #1, #2, and #5? I’d like to better understand this statement and what historical testing and reporting was completed to ensure we are meeting this requirement. Let me know if you would like to have a meeting to discuss these items. Thank you, Melissa Melissa Armer, P.E. Manager of Consulting Services – Idaho Trinity Consultants, Inc. P: 208.472.8837 x 2302 M: 208.870.3215 405 S. 8th St. Ste 331, Boise, ID 83702 Email: marmer@trinityconsultants.com 2/28/25, 1:58 PM State of Utah Mail - West Valley Power Plant Air Quality Permit 10-Year Review https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1823151674516948063&simpl=msg-f:182315167451694806…1/4 Upcoming Training: 02/19/2025 – Introduction to Exhaust Management, Abatement, and Air Emissions in the Semiconductor Industry (PHOENIX, AZ) 02/20/2025 – Introduction to Semiconductor Industry Toxic Release Inventory and Greenhouse Gas Emissions Reporting (PHOENIX, AZ) 03/12/2025 – Advanced TRI Reporting Workshop (RENO, NV) Stockton Antczak <santczak@utah.gov>Tue, Feb 4, 2025 at 11:57 AM To: Melissa Armer <marmer@trinityconsultants.com> Melissa, Both the summary of emissions and condition II.B.2.b.1 were brought forward from the previous AO. For the summary of emissions, I don't think I would be able to adjust them as part of a 10-year review project and I am not sure why they would differ from the Title V permit. It looks like both permits have the same equipment. It could be that emission factors have changed since the AO was first issued and that has led to different emission totals. For the testing language in II.B.2.b.1, I left it as is because we generally do for 10-year review but I can look into our records and see if we have reports for when those turbines were tested. I am assuming they were tested within the 180 limit of startup way back when the AO was issued, or else there would have been some compliance issues. If you can confirm on your end that they were tested then that would work as well. I would just go into the condition and set them all to showing initial testing being complete. Give me a couple days to look into this, and ask for some guidance from my supervisor. I will send you an email once I have a bit better of an idea of how we should resolve these discrepancies. Please let me know if you have any other questions. Thanks, Stockton [Quoted text hidden] 2/28/25, 1:58 PM State of Utah Mail - West Valley Power Plant Air Quality Permit 10-Year Review https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1823151674516948063&simpl=msg-f:182315167451694806…2/4 Stockton Antczak <santczak@utah.gov>Tue, Feb 25, 2025 at 10:27 AM To: Melissa Armer <marmer@trinityconsultants.com> Melissa, Sorry it has taken me so long to get back to you. I had originally thought this would only take a couple days but it took a while to get my questions answered and dig up the older documents. Here is a summary of what I've been able to figure out so far. First, in regards to condition II.B.2.b.1, I am going to update the language so that it just says that initial testing has been completed for all of them. No specific dates are required in the condition. So there shouldn't be anything to worry about there. As far as why the emission totals don't match up, I'm stumped. I looked into it possibly being a change in AP-42 emission factors but from what I have found, it doesn't look like they have changed since 2002, when the current AO was issued. It also looks like the equipment is all the same between the AO and the Title V permits and I don't show any grandfathered equipment either. I looked through all of the documents that we have related to your facility and I couldn't find why the numbers wouldn't match. I only found that the Title V numbers have remained the same since at least 2013. I also discussed this with the Title V engineer that did your most recent renewal and she didn't seem to have any issues with it. With all of that said, we think it would be good to just keep the emission totals in the AO the same for now. Since the two emissions that are being monitored (NOx and CO) are the same between both the AO and Title V, we aren't too worried about the differences in the other emissions at this time. And because a 10-year review is meant to just update the current AO, we don't have any reasoning for increasing the emissions estimates in the permit at this time. If the site decides to do any modification to the equipment on site in the future, the emissions can be re-evaluated then and updated. Again, sorry for the long wait on this. Please let me know if you have any questions. Attached is an updated copy of my review with the revised language for condition II.B.2.b.1. If everything looks good to you, we can wrap this project up. Thanks, Stockton [Quoted text hidden] RN124950011.rtf 1481K Melissa Armer <marmer@trinityconsultants.com>Fri, Feb 28, 2025 at 11:17 AM To: Stockton Antczak <santczak@utah.gov> Cc: "jerame@umpa.energy" <jerame@umpa.energy>, Travis Ball <tball@umpa.energy> Thank you Stockton. UMPA has reviewed and we do not have any additional questions. See attached for the signed document. Melissa Armer, P.E. Manager of Consulting Services – Idaho Trinity Consultants, Inc. P: 208.472.8837 x 2302 M: 208.870.3215 405 S. 8th St. Ste 331, Boise, ID 83702 Email: marmer@trinityconsultants.com 2/28/25, 1:58 PM State of Utah Mail - West Valley Power Plant Air Quality Permit 10-Year Review https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1823151674516948063&simpl=msg-f:182315167451694806…3/4 Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly. [Quoted text hidden] RN124950011.pdf 313K 2/28/25, 1:58 PM State of Utah Mail - West Valley Power Plant Air Quality Permit 10-Year Review https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1823151674516948063&simpl=msg-f:182315167451694806…4/4 Utah Municipal Power Agency 5935 W 4700 S West Valley City, UT 84118 December 13, 2023 Mr. Bryce Bird, Division Director Utah Division of Air Quality P.O. Box 144820 Salt Lake City, Utah 84114-4820 RE: Utah Municipal Power Agency- West Valley Power Plant Title V Operating Permit Renewal Application Dear Mr. Bird: This letter, along with enclosures, constitutes the renewal application for Utah Municipal Power Agency’s (UMPA) West Valley Power Plant Title V Operating Permit # 3500527004. Enclosed with this letter are: UDAQ Title V Operating Permit Application Form Appendices including Compliance Plan and Certification of Compliance Acid Rain Permit Application Form With this application submittal, UMPA has complied with a complete and timely application for the renewal of the current Title V Operating Permit that expires on July 12, 2024. If there is any additional information that is required, or there are any questions about the application, please contact myself or Melissa Armer of Trinity Consultants Inc. at (208) 472-8837. Sincerely, Jerame Blevins West Valley Plant Manager cc: David Beatty/UDAQ Operating Permits Section Manager Trinity Consultants Inc. OPERATING PERMIT APPLICATION FORM October 19, 2006 Utah Division of Air Quality OPERATING PERMIT APPLICATION APPLICATION FOR:  INITIAL  MODIFICATION  RENEWAL AN APPLICATION FOR A PERMIT TO OPERATE MUST BE SUBMITTED WITHIN 12 MONTHS OF COMMENCING OPERATION OR OCTOBER 10, 1995, WHICHEVER IS LATER; OR, FOR RENEWALS, NOT LATER THAN THE RENEWAL DATE. This is not a stand alone document. Please refer to the Utah Administrative Code or the Permit Application Instructions for specific details required to complete the application. Please print or type all information requested. A completeness review will be made utilizing a Completeness Checklist. If you would like a copy of the checklist or if you have any questions please contact the Operating Permit Section of the Division of Air Quality at (801) 536-4000. Written inquiries may be addressed to: Division of Air Quality, Operating Permit Section, P.O. Box 144820, Salt Lake City, Utah 84114-4820. GENERAL OWNER AND PLANT INFORMATION 1. Company name and address: Utah Municipal Power Agency 696 West 100 SouthSpanish Fork, UT 84660 Phone: (801) 798-7489 2. Company contact for environmental issues: Kevin Garlick – Power Resource Manager Utah Municipal Power Agency Phone No.: (801) 803-5476 3. Plant name and address, and plant contact (if different from above): Jerame Blevins Plant Manager 5935 W 4700 S West Valley City, UT 84118 Phone: (801) 967-1200 4. Owner's name and address (if different from #1): 5. Is plant permanent?  Yes  No If not, how long will equipment be at this location? 6. County plant is located in: _____Salt Lake_________ Are you within 50 miles of state border? Yes  No 7. Directions to plant (street address and/or directions to site to include U.S. Geological Survey map if necessary): West Valley Power Plant 5935 W 4700 S West Valley City, UT 84118 8. Identify any current Approval Order(s) (continue on separate sheet if necessary): Grandfathered?  Yes  No AO#_DAQE-282-02 __Date 04 / 28 / 2002 AO#_________________Date ____/____/____ AO#_________________Date ____/____/____ AO#_________________Date ____/____/____ AO#_________________Date ____/____/____ AO#_________________Date ____/____/____ 9. If request for modification, previous operating permit # and date: DAQO #___35005270045___________________ DATE: 07 / 12 / 2019 10. Type of business at this plant: __Power Generation Facility______ 11. Is your company a Small Business?12. Standard Industrial Classification (SIC) Code OPERATING PERMIT APPLICATION FORM October 19, 2006  Yes  No (See Instructions): [ 4 ] [ 9 ] [ 1 ] [ 1 ] PROCESS INFORMATION 13. Site plan of plant drawn to scale to include location of emission units (Attach as Appendix A): 14. Flow diagram of emission unit(s) at the plant to include flow rates and other applicable information (Attach as Appendix B): 15. Detailed process/equipment description. (Attach as Appendix C) Description must include:  Process/Equipment specific form(s) identified in the instructions  Fuels and their use  Equipment used in process  Description of product(s)  Raw materials used  Operation schedules  Description of changes to process  Production rates (include daily/seasonal variances) (if applicable) 16. Does this application contain confidential information?  Yes  No If yes, mark those portions claimed confidential and submit a statement in support of the claim. 17. Are you requesting that the permit include Alternative Operating Scenario(s)?  Yes  No If yes, include the detailed information described in this application for each alternative requested. EMISSIONS RELATED INFORMATION 18. Describe all potential emissions of air pollutants. (Attach as Appendix D). Include the following:  Emissions for which the source is major.  Emissions of regulated air pollutants.  Emissions of hazardous air pollutants.  Description of any operational constraints or work practices imposed that limit the amount of regulated or hazardous air pollutants.  Emissions above described in appropriate units (lbs/hr, lbs/day, ppm, etc.) based on the underlying standard, and in tons/year.  All calculations, including conversion factors as appropriate, to support the emissions data above. 19. Identify on the site plan (see #13 above) all emissions points; and all relevant building dimensions, stack parameters, etc. 20. List and describe any insignificant emission units. (Attach as Appendix E) 21. List all air pollution control equipment and include equipment specific forms identified in the instructions. (Attach as Appendix F) MONITORING INFORMATION 22. List and describe all compliance monitoring devices and activities. (Attach as Appendix G) 23. Cite and describe any applicable test methods used for determining compliance. (Include with Appendix G) APPLICABLE REQUIREMENTS 24. Cite and describe all applicable requirements with regard to (but not limited to) the following (attach as Appendix H):  SIP  HAP  NSPS PSD  NSR  UACR Title IV  Approval Order  Other 25. Are there any proposed exemptions from applicable requirements? (If yes, attach as Appendix I)  Yes  OPERATING PERMIT APPLICATION FORM October 19, 2006 No ADDITIONAL INFORMATION 26. Is the trading of emissions involved? (If yes, include detailed description as Appendix J)  Yes  No 27. Has a Risk Management Plan been forwarded to Region VIII, EPA, in accordance with 40 CFR Part 68?  Yes  No  RMP Not Required COMPLIANCE PLAN AND CERTIFICATION 28. Compliance Plan (Attach as Appendix K) Plan must include the following:  Description of compliance status with respect to all applicable requirements.  A statement that source will continue to comply with all requirements with which the source is in compliance.  A statement that source will comply with any requirement that becomes effective during term of permit.  For requirements not being complied with, a detailed narrative description of how you will achieve compliance. 29. Compliance Schedule (Include with Appendix K) Schedule must include the following:  A statement that source will continue to comply with all requirements with which the source is in compliance.  A statement that source will comply with any requirement that becomes effective during term of permit.  A schedule of remedial measures to come into compliance with any requirement not being met. Include any outstanding Notice Of Violations (NOVs) and date.  An enforceable sequence of actions, with milestones, leading to compliance.  A schedule for submission of certified progress reports at least every 6 months for sources out of compliance. 30. Compliance Plan Certification (Attach as Appendix L) The responsible official must certify the truth, accuracy, and completeness of the compliance plan in accordance with R307-415-5c(9) and provide other information related to compliance.  Include a certification of compliance with all applicable requirements by a responsible official consistent with R307-415-5d.  Include a statement of the methods used for determining compliance, to include a description of:  Monitoring  Recordkeeping  Reporting requirements  Test methods  Include a schedule for submission of compliance certifications during the permit term to be submitted annually or as specified by the applicable requirement.  Include a statement indicating the compliance status with any applicable enhanced monitoring and compliance certification requirements of the Act. CERTIFICATION OF APPLICATION 31. In accordance with UAC R307-415-5d, I hereby certify that the information and data submitted in and with this application are true, accurate and complete, based on information and belief formed after reasonable inquiry. Signature: Title: Power Resource Manager 32. Kevin Garlick _____________________ 33. Telephone Number: (801) 803-5476 34. Date: 12/13/2023 OPERATING PERMIT APPLICATION FORM October 19, 2006 Name (Typed or printed) TITLE V OPERATING PERMIT APPLICATION Utah Municipal Power Agency / West Valley Power Plant Prepared By: Melissa Armer, P.E. – Managing Consultant Matthew O’Brien – Associate Consultant TRINITY CONSULTANTS 405 S. 8th St. Suite 331 Boise, ID 83702 208.472.8837 December 13, 2023 Project 231301.0059 A-1 APPENDIX A. SITE LOCATION The West Valley Power Plant (WVPP) is a natural-gas-fired electricity generating plant located at 5935 West 4700 South in West Valley City, Utah. The Plant utilizes five General Electric LM6000 PC SPRINT simple cycle turbine generator sets - each with a nominal electric power output rating of 43.4 MW - to supply electricity to the Salt Lake metropolitan valley area. Figure A-1 is a large-scale vicinity map that shows the general location for the WVPP. Figure A-2 is a smaller scale drawing that provides a more detailed view of the WVPP site location and each emission unit. The Plant elevation is approximately 4,600 feet above mean sea level. Figure A-1. Site Vicinity Map A-2 Figure A-2. Site Plan EU#1 EU#3 EU#4 EU#5 EU#2 B-1 APPENDIX B. PROCESS FLOW DIAGRAM AND STACK PARAMETERS Table B-1 provides a list and description of all emission units located at the WVPP. The emission unit identification numbers in this list are used throughout this application. All stack heights at the WVPP are less than 65 meters (213 feet) (each is 81 feet), therefore, a demonstration of Good Engineering Practice (GEP) stack height is not required. The stack exhaust gas parameters for natural gas combustion are provided in Table B-2. Table B-1. List of Emission Units Emission Unit ID # Description 1 Generating Unit #1 2 Generating Unit #2 3 Generating Unit #3 4 Generating Unit #4 5 Generating Unit #5 Table B-2. List of Emission Units Emission Unit (EU) Emission Point Stack Height (feet) Temperature (oF) Flow Rate (ft3/sec) Generating Unit #1 (EU1) 1 81 828 9,852 Generating Unit #2 (EU2) 2 81 828 9,852 Generating Unit #3 (EU3) 3 81 828 9,852 Generating Unit #4 (EU4) 4 81 828 9,852 Generating Unit #5 (EU5) 5 81 828 9,852 B-2 Figure B-1. General Process Flow Diagram C-1 APPENDIX C. PROCESS DESCRIPTION General Plant Description The WVPP is an electricity -generating plant which consists of five natural-gas-fired simple cycle combustion turbine generator sets. West Valley Units 3 and 4 became operational in 2001, with Units 1, 2 and 5 becoming operational in 2002. The primary purpose of the Plant is to produce electricity for sale via the utility power distribution system to meet the demands of the Salt Lake Valley service area. The entire Plant includes the natural gas fuel supply system, the turbine-generators, the pollution control systems including an aqueous ammonia injection system, and other Plant-wide systems such as compressed air and water supply systems. Air pollutants are emitted through point sources during the electricity generation process and insignificant fugitive emissions are created from various emission units or activities. Many of the emission units are considered insignificant. Production Data and Operation Schedule The generators for each of the five Plant units have a nominal electrical power output rating of 43.4 MW. Each gas turbine has a design heat input rate of 404.15 MMBtu/hr at full load operation utilizing the higher heating value of the natural gas fuel supply. The Plant is designed to operate as a peaking facility. Fuel Systems The fuel source for the Plant consists exclusively of pipeline-quality compressed natural gas. The Plant is constructed and operated such that compressed natural gas can be supplied as required from one source. Kern River gas has a compressed natural gas pipeline, with an associated terminal located at the WVPP that can be used to supply combustion- quality fuel to the Plant's five simple cycle gas turbines. The natural gas fuel supply from the Kern River Line is provided to the Plant at expected conditions of 1,000 psig at 60°F. Simple Cycle Gas Turbine-Generators Ambient air is compressed in the compressor section of the turbine engines. Natural gas is injected into the compressed air and ignited, with combustion and expansion occurring in the turbine section of each engine. The combustion exhaust gases turn the turbine blades and shaft which drives the electric generator connected to the turbine via the common shaft. Air pollutants are generated during the combustion process. The combustion gas exits the turbine and flows through a carbon monoxide (CO) catalyst for CO emission control and then through a selective catalytic reduction (SCR) catalyst used for nitrogen oxides (NOx) emissions control, and finally through an exhaust stack prior to discharging to the atmosphere. Pollution Control Equipment Demineralized water is sprayed into the turbine section of the simple cycle combustion turbine engines to cool the combustion gas and reduce NOx emissions. The combustion gas is then discharged from the turbine diffuser and flows through a CO catalyst consisting of an Engelhard Carnet metallic substrate catalyst that oxidizes carbon monoxide to carbon dioxide (C02). Aqueous ammonia is injected into the combustion exhaust gases. The combustion exhaust gases then flow through an Engelhard VNX vanadia- titania SCR catalyst that further reduces NOx emissions. C-2 After passing through the NOx SCR system, the combustion gas flows through the exhaust stack and is discharged to atmosphere. Continuous Emission Monitors (CEMs) located in the exhaust stacks measure CO and NOX emissions as well as the oxygen (O2) content of the exhaust gas. Water Supply and Treatment Treated water is used at the Plant for a variety of uses including spray intercooling (SPRINT) of the intake air to increase turbine efficiency, water injection at the turbines for NOx emissions control, and various culinary and potable water requirements. Plant-Wide Activities Other miscellaneous activities are performed at the Plant that have the potential to generate air emissions. These include, but are not limited to, abrasive blasting operations for maintenance purposes, welding operations and the painting of miscellaneous plant equipment and structures. D-1 APPENDIX D. POTENTIAL EMISSIONS WVPP is a major source (i.e., greater than 100 tons per year of any pollutant) for NOx and CO. Emissions estimates for this Plant are based on maximum potential values. Potential to Emit Calculations (PTE) for Criteria pollutants, Green House Gasses (GHG) and Hazardous Air Pollutants (HAP) are shown in Tables D-1 through D-3. Table D-1. Criteria Pollutant Emissions Criteria Emissions Combustion Turbines 1,2, 3, 4 and 5 Facility- Wide Emissions (tpy) Natural Gas Emission Factor Units Reference Individual Turbine Emissions (tpy) SO2 3.40E-03 lb/MMBtu AP-42, Table 3.1-2a 5.93 29.67 VOC 2.10E-03 lb/MMBtu 2017 BACT analysis b 3.67 18.33 NOx 7.4 lb/hr a Permit limit 32.41 162.06 CO 8.8 lb/hr a Permit limit 38.33 191.63 TSP 6.60E-03 lb/MMBtu AP-42, Table 3.1-2a 11.52 57.60 PM10 6.60E-03 lb/MMBtu AP-42, Table 3.1-2a 11.52 57.60 PM2.5 4.70E-03 lb/MMBtu AP-42, Table 3.1-2a 8.20 41.02 a.Individual turbine emission factors for NOx and CO are calculated by dividing the Facility-wide permit limit by the number of turbines. Eg. 37 lb/hr/5 =7.4 lb/hr b.WVPP turbines are equipped with water injection, evaporative spray mist inlet air cooling, SCR catalyst, and CO oxidation catalyst and are estimated to achieve VOC emissions at 2 ppmvd @ 15% O2 which is equivalent to thecurrent BACT control limits. Table D-2. Greenhouse Gas Emissions GHG Emissions Combustion Turbines 1,2, 3, 4 and 5 Facility- Wide Emissions (tpy) Natural Gas Emission Factor Units Reference Individual Turbine Emissions (tpy) CO2 53 lb/MMBtu 40 CFR Part 98 204,189 1,020,945 CH4 1.00E-03 lb/MMBtu 40 CFR Part 98 4 19.24 N2O 1.00E-04 lb/MMBtu 40 CFR Part 98 0.4 1.92 CO2e b 8.20 41.02 a.CO2, N2O and CH4 emission factors based on 40 CFR Part 98 Table C-1 and C-2 Default Natural Gas b.Utilizes a global warming potential of 298 for N2O and 25 for CH4 per updated ruling 11/29/13 78 FR 71904. D-2 Table D-3. Hazardous Air Pollutants (HAP) Emissions HAP Emissions Combustion Turbines 1,2, 3, 4 and 5 Facility- Wide Emissions (tpy) Natural Gas Emission Factor Units Reference Individual Turbine Emissions (tpy) Acetaldehyde 4.00E-05 lb/MMBtu AP-42, Table 3.1-3 0.070 0.35 Acrolein 6.40E-06 lb/MMBtu AP-42, Table 3.1-3 0.011 0.06 Benzene 1.2E-05 lb/MMBtu AP-42, Table 3.1-3 0.021 0.10 1,3-Butadiene 4.3E-07 lb/MMBtu AP-42, Table 3.1-3 0.001 0.004 Ethylbenzene 3.20E-05 lb/MMBtu AP-42, Table 3.1-3 0.056 0.28 Formaldehyde 7.10E-04 lb/MMBtu AP-42, Table 3.1-3 1.239 6.20 Naphthalene 1.30E-06 lb/MMBtu AP-42, Table 3.1-3 0.002 0.01 PAH 2.20E-06 lb/MMBtu AP-42, Table 3.1-3 0.004 0.02 Propylene Oxide 2.90E-05 lb/MMBtu AP-42, Table 3.1-3 0.051 0.25 Toluene 1.30E-04 lb/MMBtu AP-42, Table 3.1-3 0.227 1.13 Xylene 6.40E-05 lb/MMBtu AP-42, Table 3.1-3 0.112 0.56 Maximum Individual HAP Emissions (tpy) 6.20 Maximum Total HAP Emissions (tpy) 8.97 E-3 APPENDIX E. INSIGNIFICANT ACTIVITIES WVPP has the following Insignificant Emission Units: Turbine Generator Compartment The vents located atop each turbine generator package are air/oil separators that emit only air with very small quantities, if any, of Volatile Organic Compound (VOC) vapor. This occurs whenever the unit is operating. The WVPP also conducts various maintenance activities such as welding, painting and abrasive blasting which result in insignificant emissions. F-1 APPENDIX F. CONTROL EQUIPMENT DESCRIPTION Table F-1 contains a list of pollution control equipment that is installed at the Plant: Table F-1. West Valley Pollution Control Equipment Pollution Control Equipment Description Unit No. 1 Nitrogen Oxides (NOx) Water Injection Systems The purpose of this installation is to inject water into the Unit 1 simple cycle combustion turbine to reduce the NOx concentration of the combustion gas. The combustion gas NOx concentration following water injection is 25 ppmvd. The Unit 1 NOx water injection system became operational in 2002. Unit No.1 Carbon Monoxide (CO) Catalyst System The purpose of this installation is to reduce the CO emissions following the combustion process. Exhaust gases from the Unit 1 turbine flow through a CO catalyst consisting of an Engelhard Camet metallic substrate catalyst that oxidizes CO to carbon dioxide (CO2). The CO catalyst system reduces the CO concentration to 10 ppmvd. The Unit 1 CO system became operational in 2002. Unit No. 1 Selective Catalytic Reduction (SCR) System The combustion gases also flow through a SCR system that further reduces the NOx concentration of the exhaust gas. A solution of 19% aqueous ammonia is sprayed into the combustion gas as it passes through an injection grid. After passing through the ammonia injection grid, the turbine exhaust flows through an Engelhard VNX vanadia-titania SCR catalyst that reduces the NOx concentration to 5 ppmvd. The Unit 1 SCR system became operational in 2002. Unit No.2 Nitrogen Oxides (NOx) Water Injection Systems The purpose of this installation is to inject water into the Unit 2 simple cycle combustion turbine to reduce the NOx concentration of the combustion gas. The combustion gas NOx concentration following water injection is 25 ppmvd. The Unit 2 NOx water injection system became operational in 2002. Unit No. 2 Carbon Monoxide (CO) Catalyst System The purpose of this installation is to reduce the CO emission following the combustion process. Exhaust gases from the Unit 2 turbine flow through a CO catalyst consisting of an Engelhard Camet metallic substrate catalyst that oxidizes CO to CO2. The CO catalyst system reduces the CO concentration to 10 ppmvd. The Unit 2 CO system became operational in 2002. Unit No.2 Selective Catalytic Reduction (SCR) System The combustion gases also flow through a SCR system that further reduces the NOx concentration of the exhaust gas. A solution of 19% aqueous ammonia is sprayed into the combustion gas as it passes through an injection grid. After passing through the ammonia injection grid, the turbine exhaust flows through an Engelhard VNX vanadia-titania SCR catalyst that reduces the NOx concentration to 5 ppmvd. The Unit 2 SCR system became operational in 2002. Unit No. 3 Nitrogen Oxides (NOx) Water Injection Systems The purpose of this installation is to inject water into the Unit 3 simple cycle combustion turbine to reduce the NOx concentration of the combustion gas. The combustion gas NOx concentration following water injection is 25 ppmvd. The Unit 3 NOx water injection system became operational in 2001. Unit No. 3 Carbon Monoxide (CO) Catalyst System The purpose of this installation is to reduce the CO emission following the combustion process. Exhaust gases from the Unit 3 turbine flow through a CO catalyst consisting of an Engelhard Camet metallic substrate catalyst that oxidizes CO to CO2. The CO catalyst system reduces the CO concentration to 10 ppmvd. The Unit 3 CO system became operational in 2001. Unit No. 3 The combustion gases also flow through a SCR system that further reduces the NOx concentration of the exhaust gas. A solution of 19% aqueous ammonia is sprayed into the F-2 Selective Catalytic Reduction (SCR) System combustion gas as it passes through an injection grid. After passing through the ammonia injection grid, the turbine exhaust flows through an Engelhard VNX vanadia-titania SCR catalyst that reduces the NOx concentration to 5 ppmvd. The Unit 3 SCR system became operational in 2001. Unit No. 4 Nitrogen Oxides (NOx) Water Injection Systems The purpose of this installation is to inject water into the Unit 4 simple cycle combustion turbine to reduce the NOx concentration of the combustion gas. The combustion gas NOx concentration following water injection is 25 ppmvd. The Unit 4 NOx water injection system became operational in 2001. Unit No. 4 Carbon Monoxide (CO) Catalyst System The purpose of this installation is to reduce the CO emission following the combustion process. Exhaust gases from the Unit 4 turbine flow through a CO catalyst consisting of an Engelhard Camet metallic substrate catalyst that oxidizes CO to CO2. The CO catalyst system reduces the CO concentration to 10 ppmvd. The Unit 4 CO system became operational in 2001. Unit No.4 Selective Catalytic Reduction (SCR) System The combustion gases also flow through a SCR system that further reduces the NOx concentration of the exhaust gas. A solution of 19% aqueous ammonia is sprayed into the combustion gas as passes through an injection grid. After passing through the ammonia injection grid, the turbine exhaust flows through an Engelhard VNX vanadia-titania SCR catalyst that reduces the NOx concentration to 5 ppmvd. The Unit 4 SCR system became operational in 2001. Unit No.5 Nitrogen Oxides (NOx) Water Injection Systems The purpose of this installation is to inject water into the Unit 5 simple cycle combustion turbine to reduce the NOx concentration of the combustion gas. The combustion gas NOx concentration following water injection is 25 ppmvd. The Unit 5 NOx water injection system became operational in 2002. Unit No.5 Carbon Monoxide (CO) Catalyst System The purpose of this installation is to reduce the CO emission following the combustion process. Exhaust gases from the Unit 1 turbine flow through a CO catalyst consisting of an Engelhard Camet metallic substrate catalyst that oxidizes CO to CO2. The CO catalyst system reduces the CO concentration to 10 ppmvd. The Unit 5 CO system became operational in 2002. Unit No.5 Selective Catalytic Reduction (SCR) System The combustion gases also flow through a SCR system that further reduces the NOx concentration of the exhaust gas. A solution of 19% aqueous ammonia is sprayed into the combustion gas as it passes through an injection grid. After passing through the ammonia injection grid, the turbine exhaust flows through an Engelhard VNX vanadia-titania SCR catalyst that reduces the NOx concentration 5 ppmvd. The Unit 5 SCR system became operational in 2002. Notes: (1) - All exhaust gas concentrations are shown as corrected to 15% Oxygen. All five combustion turbine generation units have identical emission control systems. As shown in Table F-1 the emission control systems consist of a turbine water injection system to reduce NOx emissions, a CO catalyst system to reduce CO emissions, and a SCR system to further reduce NOx emissions. Carbon monoxide emissions are controlled to a rate of 10 ppmvd and NOx emissions are controlled to a rate of 5 ppmvd. Stack-mounted continuous emissions monitors (CEMs) are used to measure CO and NOx emissions prior to discharge to the atmosphere from the five exhaust stacks. The monitoring devices are described in Table G-1. G-1 APPENDIX G. MONITORING METHODS AND DEVICES Table G-1. Compliance Monitoring Emissions Source Compliance Monitoring Device Manufacturer Model Number Calibration Frequency Quality Assurance Test Frequency Monitoring Frequency Compliance Test Method Unit 1 NOx Thermo 42iQLS 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 2; 40 CFR 75 Appendix A O2 Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 3; 40 CFR 75 Appendix A CO Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Labs Appendix B, Performance Specification 4 Fuel Flow Meter Yokogawa YFA11- AUPA-05 N/A Annually Continuous 40 CFR 75 Appendix D Unit 2 NOx Thermo 42iQLS 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 2; 40 CFR 75 Appendix A O2 Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 3; 40 CFR 75 Appendix A CO Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 4; 40 CFR 75 Appendix D Fuel Flow Meter Yokogawa YFA11- AUPA-05 N/A Annually Continuous 40 CFR 75 Appendix D Unit 3 NOx Thermo 42iQLS 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 2; 40 CFR 75 Appendix A O2 Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 3; 40 CFR 75 Appendix A CO Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 4 G-2 Fuel Flow Meter Yokogawa YFA11- AUPA-05 N/A Annually Continuous 40 CFR 75 Appendix D Unit 4 NOx Thermo 42iQLS 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 2; 40 CFR 75 Appendix A O2 Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 3; 40 CFR 75 Appendix A CO Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 4 Fuel Flow Meter Yokogawa YFA11- AUPA-05 N/A Annually Continuous 40 CFR 75 Appendix D Unit 5 NOx Thermo 42iQLS 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 2; 40 CFR 75 Appendix A O2 Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 3; 40 CFR 75 Appendix A CO Thermo 48iQ 24 hours Quarterly Continuous 40 CFR 60 Appendix B, Performance Specification 4 Fuel Flow Meter Yokogawa YFA11- AUPA-05 N/A Annually Continuous 40 CFR 75 Appendix D H-1 APPENDIX H. APPLICABLE REQUIREMENTS Table H-1 lists all applicable requirements, references to the applicable regulations, and a short description of each requirement for the WVPP. Table H-1. Applicable Requirements – Utah Source Description Applicable Requirements Source ID Unit ID Description Pollutant/ Parameter Utah R304-415 Reg. Citation or Permit No. State Only Limitations Plant- wide Plant-wide: Title V permit Permits R307-415 Title V Permit renewal is required Plant- wide Plant-wide emissions inventory Permits R307-150 Emission Inventory Plant- wide Plant-wide acid rain permit Permits R307-417 Acid Raid Permit (Title IV) (within Title V Permit) Plant- wide Plant-wide allowances Facility R307-403-5 Allowances are required for SO2 Plant- wide Plant-wide emissions NOx DAQE-282-02 37 lb NOx /hr Total Emissions based on 30-day rolling average Plant- wide Plant-wide emissions NOx R307-110-17 1050 lb NOx /day Total Emissions of Five Turbines Plant- wide Plant-wide emissions CO DAQE-282-02 43.75 lb CO/hr Total Emissions based on 30-day rolling average EU#6 Natural gas simple cycle turbine group (EU#1-EU#5) Visible Emissions DAQE-282-02 10% opacity for combustion exhaust EU#6 Natural gas simple cycle turbine group (EU#1-EU#5) CO DAQE-282-02 10 ppmvd (15% O2 Dry) based on 30-day rolling average EU#6 Natural gas simple cycle turbine group (EU#1-EU#5) NOx DAQE-282-02 5 ppmvd (15% O2 Dry) based on 30-day rolling average EU#6 Natural gas simple cycle turbine group (EU#1-EU#5) NOx DAQE-282-02 100 ppmvd (15% O2 Dry) based on a 4-hour rolling average H-2 EU#6 Natural gas simple cycle turbine group (EU#1-EU#5) Controls R307-403-3 Sources constructed in or in areas that could affect the Salt Lake City maintenance area for CO are subject to LAER requirements for CO and NOx emissions EU#6 Natural gas simple cycle turbine group (EU#1-EU#5) Controls R307-401-5(d) BACT for sources emitting VOC or NOx H-1 Table H-2. Utah Administrative Code (UAC) R307 – Air Quality Rules Applicable Rule Description Summary of Standards or Requirements No t A p p l i c a b l e Ad m i n i s t r a t i v e In C o m p l i a n c e St a t u s Un d e t e r m i n e d No t i n Co m p l i a n c e Comments R307-101 General Requirements x Not a source-specific requirement R307-102 General Requirements: Broadly Applicable Requirements x Not a source-specific requirement R307-103 Administrative Procedures x Not a source-specific requirement R307-105 General Requirements: Emergency Controls x Requirement for DAQ R307-107 General Requirements: Unavoidable Breakdown x Not a source-specific requirement R307-107-1 Application R307-107 applies to all regulated pollutants including those for which there are monitoring requirements under R307-170 . x Not a source-specific requirement R307-107-2 Reporting A breakdown for any period >2 hours must be reported within 24 hours of the beginning of the breakdown. x No breakdowns to report. R307-107-2 Reporting Within 14 calendar days of the beginning of any breakdown >2 hours, a written report shall be submitted to the executive secretary which shall include the cause and nature of the event, estimated quantity of pollutant (total and excess), time of emissions and steps taken to control the emissions and to prevent recurrence. x No breakdowns to report. R307-107-3 Penalties x Not a source-specific requirement R307-110 General Requirements: State Implementation Plan Proposed SIP changes accepted by WVPP on 11/14/2015. Total NOx emissions from all five (5) turbines combined shall be no greater than 1050 lb of NOx per day. Compliance to be determined by CEM. x See enclosed letter for source-specific requirements R307-115 General Conformity x Not a source-specific requirement R307-120 General Requirements: Tax Exemption for Air and Water Pollution Control Equipment x Not a source-specific requirement R307-121 General Requirements: Eligibility of Expenditures for x H-2 Purchase of Vehicles that Use Cleaner Burning Fuels for Corporate and Individual Income Tax Credits R307-122 General Requirements: Eligibility of Expenditures for Purchase and Installation Costs of Fireplaces and Wood Stoves that Use Cleaner Burning Fuels x R307-130 General Penalty Policy x Not a source-specific requirement R307-135 Enforcement Response Policy for Asbestos Hazard Emergency Response Act x Not a source-specific requirement R307-150 Emission Inventories x R307.150-1 Purpose and General Requirements x Not a source-specific requirement R307.150-1 (3) Periodic Emission Inventories Emission inventories shall be submitted on or before April 15 of each year following the calendar year for which an inventory is required… x R307.150-1 (4) Additional Emission Inventories Required The executive secretary may require at any time a full or partial year inventory upon reasonable notice to affected sources when it is determined that the inventory is necessary to develop a SIP, to assess whether there is a threat to public health or safety or the environment, or to determine whether the source is in compliance with R307. x This has not been required. R307.150-1 (5) Recordkeeping Maintain a copy of the emission inventory submitted to the Division and make records available for inspection indicating how the information submitted in the inventory was determined, including any calculations, data, measurements, and estimates used. Records shall be kept for a period of at least five years from the due date of each inventory. x R307.150-2 Definitions x Not a source-specific requirement R307.150-3 (1) Applicability of R307-150-4 R307-150-4 applies to all stationary sources with actual emissions of 100 tons or more per year of sulfur dioxide in calendar year 2000 or any subsequent year unless exempted in R307-150-3(a). x Not a source-specific requirement H-3 R307.150-3 (2) Applicability of R307-150-5 R307-150-5 applies to large major sources. "Large Major Source means a major source that emits or has the potential to emit 2500 tons or more per year of oxides of sulfur, oxides of nitrogen, or carbon monoxide, or that emits or has the potential to emit 250 tons or more per year of PM10, PM2.5, volatile organic compounds, or ammonia. x Not a source-specific requirement R307.150-3 (3) Applicability R307-150-6 R307-150-6 applies to: x Not a source-specific requirement R307.150-3 (3) (a) Each "major source" that is not a large major source (“major source" means major source as defined in R307-415-3.); x Not a source-specific requirement R307.150-3 (3) (b) Each source with the potential to emit 5 tpy or more of lead; and x Not a source-specific requirement R307.150-3 (3) (c) Each source not included in (2) or (3)(a) or (3)(b) above that is located in Davis, Salt Lake, Utah, or Weber Counties and that has the potential to emit 25 tons or more per year of any combination of NOx, SOx and PM10, or the potential to emit 10 tons or more per year of VOC. x Not a source-specific requirement R307.150-3 (4) (4) R307-150-7 applies to Part 70 sources not included in (2) or (3) above. x Not a source-specific requirement R307.150-4 Sulfur Dioxide Milestone Inventory Requirements x R307.150-5 Sources Identified in R307-150-3(2), Large Major Source Inventory Requirements x Source is not a “large stationary source” R307.150-6 (1) Sources Identified in R307-150-3(3) Submit an inventory every third year for all emissions units including fugitive emissions. x Source is identified in R307-150-3(3) [major source that is not a large major source]. (a) Emission Inventory Requirements Inventory shall include PM10, PM2.5, SOx, NOx, CO, VOC, ammonia, other chargeable pollutants, and HAPs not exempted in R307-150-8. x (b) The emissions of a pollutant shall be calculated using the source’s actual operating hours, production rates, and types of materials processed, stored, or combusted during the inventoried time period. The rate and period of emissions, excess or breakdown emissions, startup and shut down emissions, the specific emissions unit which is the source of the air pollution, composition of air contaminant, type and efficiency of the air pollution control equipment, and other information necessary to quantify operation and emissions and to evaluate pollution control efficiency. x H-4 For each pollutant, the inventory shall include: (2) Sources identified in R307- 150-3(3). Additional conditional emission inventory requirements Submit an inventory for each year in which the total amount of PM10, SOX, NOx, CO, or VOC increases or decreases by 40 tpy or more from the most recently submitted inventory. For each pollutant, the inventory shall meet the requirements of R307-150-6(1)(a) and (b). x R307.150-7 Sources Identified in R307-150-3(4), Other Part 70 Sources x R307-150-6 applies R307.150-8 Exempted Hazardous Air Pollutants Certain HAPs are exempt from emission inventory requirements in R307-150 if they are emitted in an amount less than thresholds. x Source emits HAP at levels exceeding exemption thresholds. R307-165 Emissions Testing x R307-165-1 Purpose Establishes the frequency of emission testing requirements for all areas in the state. x No testing required R307-165-2 Testing Every 5 Years Emission testing is required at least once every 5 years of all sources with established emission limitations specified in AOs issued under R307-401 or in section IX. Part H of the Utah SIP. x Sources are not subject to emission limitations R307-165-3 Notification of DAQ At least 30 days prior to conducting any emission testing required under any part of R307, the owner or operator shall notify the executive secretary of the date, time and place of such testing,… x R307-165-4 Test Conditions All tests shall be conducted while the source is operating at the maximum production or combustion rate at which such source will be operated. During the tests, the source shall burn fuels or combination of fuels, use raw materials, and maintain process conditions representative of normal operations… x R307-165-5 Rejection of Test Results The executive secretary may reject emissions test data if they are determined to be incomplete, inadequate, not representative of operating condition, or if the director was not provided an opportunity to have an observer present at the test. x R307-170 Continuous Emission Monitoring Program The purpose of this rule is to establish consistent requirements for all sources required to install a continuous monitoring system (CMS) and for sources who opt into the continuous emissions monitoring program. Not subject to R307-170-6, Minimum Monitoring Requirements for Specific Sources Not subject to R307-170-9(7), Excess Emission Report x H-5 R307-201 Emission Standards: General Emission Standards x R307-201-1 R307-201 establishes emission standards for all areas of the state except for sources listed in section IX, Part H of the SIP or located in a PM10 nonattainment or maintenance area. x Not a source-specific requirement R307-201- 2 Applicability x Not a source-specific requirement R307-201- 3 (1) Visible-Emissions Standards. Installations constructed on or before April 25, 1971, except diesel engines: 40% opacity, except as otherwise provided in these rules. x Installation constructed after April 25, 1971. R307-201- 3 (2) Visible Emissions Standards. Installations constructed after April 25, 1971, except diesel engines: 20% opacity, except as otherwise provided in these rules. x R307-201- 3 (3) Visible Emissions Standards. Incinerators 20% opacity. x Facility does not operate affected source. R307-201- 3 (4) Visible Emissions Standards. Gasoline powered engine or vehicle No visible emissions. x Facility does not operate affected source R307-201- 3 (5) Visible Emissions Standards. Diesel engines, except locomotives, manufactured after January 1, 1973: 20% opacity, except for starting motion no farther than 100 yards or for stationary operation not exceeding three minutes in any hour. x R307-201- 3 (6) Visible Emission Standards. Diesel engines, except locomotives, manufactured before January 1, 1973: 40% opacity, except for starting motion no farther than 100 yards or for stationary operation not exceeding three minutes in any hour. x R307-201- 3 (7) Visible emissions exceeding the opacity standards for short time periods as the result of initial warmup, soot blowing, cleaning of grates, building of boiler fires, cooling, etc., caused by start-up or shutdown of Exceedances shall not be deemed in violation provided that the executive secretary finds that adequate control technology has been applied. The owner or operator shall minimize visible and non-visible emissions during start-up or shutdown of a facility, installation, or operation through the use of adequate control technology and proper procedures. Unavoidable combustion irregularities which exceed three minutes in length must be handled in accordance with R307-107. x H-6 a facility, installation or operation, or unavoidable combustion irregularities which do not exceed 3 minutes in length. R307-201- 3 (8) Compliance Method Visible emissions shall be brought into compliance with these requirements by reduction of the total weight of contaminants discharged per unit of time rather than by dilution of emissions with clean air. x R307-201- 3 (9) Opacity Observation Opacity observations of emissions from stationary sources shall be conducted in accordance with EPA Method 9. Opacity observers of mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at 15 second intervals over a 6-minute period shall not apply. x R307-201- 4 Automobile Emission Control Devices x R307-202 Emission Standards: General Burning x Facility does not conduct open burning R307-203 Emission Standards: Sulfur Content of Fuels x R307-204 Emission Standards: Smoke Management x R307-205- 1 Purpose R307-205 establishes minimum work practices and emission standards for sources of fugitive emissions and fugitive dust for sources of fugitive emissions and fugitive dust for sources located in all areas in the state except those listed in section IX. Part H of the SIP or located in a PM10 nonattainment or maintenance area. x Not a source-specific requirement R307-205- 2 Applicability x Not a source-specific requirement R307-205- 3 Definitions x Not a source-specific requirement R307-205- 4 Fugitive emissions from sources which were constructed on or before April 25, 1971 40% opacity x R307-205- 4 Fugitive emissions from sources constructed or 20% opacity x H-7 modified after April 25, 1971 R307-205- 5 (1) Material Storage and Handling Minimize fugitive dust by the use of enclosures, covers, stabilization or other equivalent methods or techniques as approved by the executive secretary. x Facility does not store material in piles R307-205- 5 (2) (a) Construction and Demolition Activities, clearing or leveling of land greater than one-quarter acre in size, earthmoving, excavation, or movement of trucks or construction equipment over cleared land greater than one-quarter acre in size or access haul roads Take steps to minimize fugitive dust from such activities. x R307-205- 5 (2) (b) Construction and Demolition Activities. Any land area greater than one-quarter acre in size that has been cleared or excavated. Take measures to prevent fugitive particulate matter from becoming airborne. x R307-205- 5 (2) (c) Demolition Activities Take steps to minimize fugitive dust from such activities x R307-205- 6 (1) Roads The executive secretary may require persons owning, operating or maintaining any new or existing road, or having right-of-way easement or possessory right to use the same, to supply traffic count information as determined necessary to ascertain whether or not control techniques are adequate or additional controls are necessary. x R307-205- 6 (2) Roads Any person who deposits materials that may create fugitive dust on a public or private road shall clean the road promptly. x R307-205- 7 Mining Activities x R307-205- 8 Tailings Piles and Ponds x R307-206 Emission Standards: Abrasive Blasting x R307-207 Emission Standards: Residential Fireplaces and Stoves x H-8 R307-210 Stationary Sources NSPS incorporated by reference x No NSPS applies R307-214 National Emission Standards for Hazardous Air Pollutants NESHAP/MACT incorporated by reference x No NESHAP/MACT applies R307-215 Emission Standards: Acid Rain Requirements x R307-220 Emission Standards: Plan for Designated Facilities x R307-221 Emission Standards: Emission Controls for Existing Municipal Solid Waste Landfills x R307-222 Emission Standards: Existing Incinerators for Hospital, Medical, Infectious Waste x R307-223 Emission Standards: Existing Small Municipal Waste Combustion Units x R307-250 Western Backstop Sulfur Dioxide Trading Program x Source is not a BART- eligible source, as defined in 40 CFR 51.301, due to SO2 emissions. Source does not emit or have the PTE SO2 at threshold levels (100 tpy) R307-301 Utah and Weber Counties: Oxygenated Gasoline Program As a Contingency Measure x R307-302 Davis, Salt Lake, Utah, Weber Counties: Residential Fireplaces and Stoves x R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards x H-9 R307-306 PM10 Nonattainment and Maintenance Areas: Abrasive Blasting x R307-307 Davis, Salt Lake, and Utah Counties: Road Salting and Sanding x R307-309 Nonattainment and Maintenance Areas for PM10: Fugitive Emissions and Fugitive Dust x R307-310 Salt Lake County: Trading of Emission Budgets for Transportation Conformity x R307-320 Davis, Salt Lake and Utah Counties, and Ogden City: Employer-Based Trip Reduction Program x R307-325 Davis and Salt Lake Counties and Ozone Nonattainment Areas: Ozone Provision x R307-326 Davis and Salt Lake Counties and Oxone Nonattainment Areas: Control Hydrocarbon Emissions in Refineries x R307-327 Davis and Salt Lake Counties and Ozone Nonattainment Areas: Petroleum Liquid Storage x R307-328 Davis, Salt Lake, Utah and Weber Counties and Ozone Nonattainment Areas: Gasoline Transfer and Storage x R307-335 Davis and Salt Lake Counties and Ozone Nonattainment Areas: x H-10 Degreasing and Solvent Cleaning Operations R307-340 Davis and Salt Lake Counties and Ozone Nonattainment Areas: Surface Coating Processes x R307-341 Davis and Salt Lake Counties and Ozone Nonattainment Areas: Cutback Asphalt x R307-342 Davis, Salt Lake, Utah and Weber Counties and Ozone Nonattainment Areas: Qualification of Contractors and Test Procedures for Vapor Recovery Systems for Gasoline Delivery Tanks x R307-343 Davis and Salt Lake Counties and Ozone Nonattainment Areas: Emissions Standards for Wood Furniture Manufacturing Operations x R307-401 Permit: New and Modified Sources x R307-401- 1 Purpose Application and permitting requirements for new installations and modifications to existing installations throughout the State of Utah. x Not a source-specific requirement R307-401- 2 Definitions x Not a source-specific requirement R307-401- 3 Applicability x Not a source-specific requirement R307-401- 4 (1) General Requirements. Air Pollution Control Apparatus Any control apparatus installed on an installation shall be adequately and properly maintained x No control equipment at facility R307-401- 4 (2) General Requirements x Not a source-specific requirement R307-401- 4 (3) General Requirements. Low Oxides of Nitrogen Burner Technology. Whenever existing fuel combustion burners are replaced, install low oxides of nitrogen burners or equivalent oxides of nitrogen controls, as determined by the executive secretary, unless such equipment is not physically practical or cost effective. The owner or operator shall submit a demonstration that the equipment is not physically practical or cost effective to the executive secretary for review and approval prior to beginning construction. x No burners have been replaced H-11 R307-401- 5 Notice of intent Except as provided in R307-401-9 through R307-401-17. Any person subject to R307-401 shall submit a notice of intent to the executive secretary and receive an approval order prior to initiation of construction, modification or relocation. The notice of intent shall be in a format specified by the executive secretary. x R307-401- 6 Review Period x Not a source-specific requirement R307-401-7 Public Notice x Not a source-specific requirement R307-401-8 Approval Order x Not a source-specific requirement R307-401-9 Small Source Exemption x R307-401- 10 Source Category Exemptions x R307-401- 11 Replacement-in-kind Equipment Existing process equipment or pollution control equipment that is covered by an existing AO or SIP requirement may be replaced as provided by R307-401-11(2) if conditions set out in R307-401-11(1) are met. x R307-401- 12 Reduction in Air Contaminants x Not a source-specific requirement R307-401- 13 Plant-wide Applicability Limits x R307-401-14 Used Oil Fuel Burned for Energy Recovery x R307-401- 15 Air Strippers and Soil Venting Projects x R307-401- 16 De minimis Emissions From Soil Aeration Projects x R307-401- 17 Temporary Relocation x R307-401- 18 Eighteen Month Review x R307-401- 19 Analysis of Alternatives x R307-401- 20 Relaxation of Limitations x R307-403 Permits: New and Modified Sources in Nonattainment Areas and Maintenance Areas x H-12 R307-405 Permits: Major Sources in Attainment or Unclassified Areas (PSD) Implements the federal PSD permitting program for major sources and major modifications in attainment areas and maintenance areas as required by 40 CFR 51.166. Supplements, but does not replace, permitting requirements of R307-401. x R307-406 Visibility The Executive Secretary shall review any new major source or major modification proposed in either an attainment area or area of nonattainment area for the impact of its emissions on visibility in any mandatory Class I area. x Not a source-specific requirement R307-410 Permits: Emissions ImpactAnalysis This rule establishes procedures and requirements for evaluating the emissions impact of new or modified sources that require an approval order under R307-401 to ensure that the source will not interfere with the attainment or maintenance of any NAAQS. The rule also establishes the procedures and requirements for evaluating the emissions impact of HAPs. The rule also establishes the procedures for establishing an emission rate based on the good engineering practice stack height as required by 40 CFR 51 .118. x R307-410- 1 Purpose x Not a source-specific requirement R307-410-2 Definitions x Not a source-specific requirement R307-410- 3 Use of Dispersion Models All estimates of ambient concentrations derived in meeting the requirements of R307 shall be based on appropriate air quality models, data bases, and other requirements specified in 40 CFR Part 51, Appendix W, (Guideline on Air Quality Models), effective July 1, 2005, which is hereby incorporated by reference… x Not a source-specific requirement R307-410- 4 Modeling of Criteria Pollutant Impacts in Attainment Areas Prior to receiving an AO under R307 -401, a new or modified Areas. source in an attainment area with a total controlled emission rate per pollutant or increase in total controlled emission rate(s) greater than or equal to amounts specified in Table 1 in R307-410-4, shall conduct air quality modeling… x R307-410- 5 Documentation of Ambient Air Impacts for HAPs Prior to receiving an approval order under R307 -401, a source shall provide documentation of increases in emissions of hazardous air pollutants as required under R307-410-5(c) for all installations not exempt under R307-410-S(a). x R307-410- 6 Stack Heights and Dispersion Techniques x Not a source-specific requirement R307-414 Permits: Fees for Approval Orders x R307-415 Permits: Operating Permit Requirements x R307-417 Permits: Acid Rain Sources x R307-420 Permits: Ozone Offset Requirements in Davis and Salt Lake Counties x H-13 R307-421 Permits: PM10 Offset Requirements in Salt Lake County and Utah County x R307-801 Asbestos Rule R307-801 establishes procedures and requirements for asbestos projects and training programs, procedures and requirements for the certification of persons engaged in asbestos activities, and work practice standards for performing such activities . . . x Facility has not engaged in any demolition activities R307-840 Lead-Based Paint Accreditation, Certification and Work Practice Standards. x Facility is not engaged in lead-based paint activities as defined in R307-840-2 R307-801 Asbestos Rule R307-801 establishes procedures and requirements for asbestos projects and training programs, procedures and requirements for the certification of persons engaged in asbestos activities, and work practice standards for performing such activities . . . x Facility has not engaged in any demolition activities R307-840 Lead-Based Paint Accreditation, Certification and Work Practice Standards. x Facility is not engaged in lead-based paint activities as defined in R307-840-2 H-1 Table H-3. Federal Clean Air Act Standards and Regulations Program Identifier Program Citation Secondary Identifier Pollutants/ Parameters Affected Source/ Source Category Applicability Dates Rule/Permit Citation Summary Applicability Determination Pr o p o s a l D a t e Pr o m u l g a t i o n Da t e Co m p l i a n c e Da t e Ap p l i c a b l e No t A p p l i c a b l e Ba s i s / N o t e s NSPS 40CFR60 New Source Performance Standards NSPS 40CFR60 Subpart A General §§60.1-60.19 General Provision x Facility operates affected source(s) NSPS 40CFR60 Subpart Db NOx, SO2, PM SGU 06/19/84 (49FR25102) 11/25/86 (51FR42768) §§60.40b- 60.49b Industrial-Commercial- Institutional Steam Generating Units x Heat input capacity less than thresholds and commenced construction prior to relevant date. NSPS 40CFR60 Subpart Dc NOx, SO2, PM SGU 06/09/89 (54FR24792) 09/12/90 (55FR37674) §§60.40c-60.48c Small Industrial-Commercial-Institutional Steam Generating Units x Commenced construction prior to relevant date. NSPS 40CFR60 Subpart K VOC Tanks 6/11/1973 3/8/1974 §§60.110- 60.113 Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 x Facility does not operate affected source(s). Petroleum liquid storage tanks <40,000 gal. NSPS 40CFR60 Subpart Ka VOC Tanks 5/18/1978 4/4/1980 §§60.110a-60.115a Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May18, 1978, and Prior to July 23, 1984 x Facility does not operate affected source(s). Petroleum liquid storage tanks <40,000 gal. H-2 NSPS 40CFR60 Subpart Kb VOC Tanks 07/23/84 (49FR29713) 04/08/87 (52FR11420) §§60.110b- 60.116b Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 x VOL tanks that commenced construction after July 23, 1984 are less than the 75 m3 capacity and exempt as provided by 40 CFR60.110b(d )(4). NSPS 40CFR60 Subpart GG NOx, SO2 CT 10/03/77 (42FR53782) 4/14/03 (68 FR 17989) 9/10/79 (44FR52798) 7/8/04 (69FR41345) §§60.330- 60.335 Stationary Gas Turbines x NSPS 40CFR60 Subpart KKK VOC NGPP 01/20/84 (49FR2636) 06/24/85 (50FR26122) §§60.330-60.336 Equipment Leaks of VOC from Onshore Natural Gas Processing Plants x Facility commenced construction, reconstruction or modification prior to January 20, 1984 NSPS 40CFR60 Subpart LLL SO2 NGPP 01/20/84 (49FR2656) 10/01/85 (50FR2656) §§60.330- 60.648 Onshore Natural Gas Processing: SO2 Emissions x Facility commenced construction, reconstruction or modification prior to January 20, 1984 NSPS 40CFR60 Subpart CCCC D/F, Cd, Pb, Hg, PM, HCI, NO. SO2. CO, Fug. Ash, opacity CISWI §§60.2000- 60.2265 CISWIs for Which Construction is Commenced After November 30, 1999 or for Which Modification or Reconstruction is Commenced on or After June 1, 2001 x Facility does not operate affected source(s) NSPS 40CFR60 Subpart DDDD D/F, Cd, Pb, Hg, PM, HCI, NO. SO2. CO, Fug. Ash, opacity CISWI §§60.2500- 60.2875 Emissions Guidelines and Compliance Times for CISWIs that Commenced Construction On or Before November 30, 1999 x Facility does not operate affected source(s) H-3 NSPS 40CFR60 Subpart IIII NOx ICE 07/11/05 07/11/2006 §§60.4200- 60.4219 Stationary Compression Ignition Internal Combustion Engines x Emergency stationary CI-ICE commenced construction prior to July 11, 2005 NSPS 40CFR60 Subpart JJJJ NOx ICE 6/12/06 1/18/2008 Stationary Spark-Ignition Internal Combustion Engines x Stationary SI- ICE commenced construction prior to June 12, 2006 NSPS 40CFR60 Subpart KKKK NOx, SO2 CT 2/18/08 (70FR8314) 07/06/2006 (71FR68482) CTs for Which Construction is Commenced After February 18, 2005 or for Which Modification or Reconstruction is Commenced on or After February 27, 2006 x Facility does not operate affected source(s) NESHAP 40CFR61 Subpart A General §§61.01-61.19 General Provisions x NESHAP 40CFR61 Subpart M Asbestos §§61.140-61.157 Asbestos x Facility has not engaged in demolition or renovation activities NESHAP 40CFR61 Subpart M Asbestos §§61.140 Applicability x NESHAP 40CFR61 Subpart M Asbestos Demolition & §§61.145 Standard for demolition and renovation x NESHAP 40CFR61 Subpart M Asbestos Demolition & Renovation §§61.150 Standard for waste disposal for manufacturing, fabricating, demolition x NESHAP 40CFR61 Subpart M Asbestos Demolition & Renovation §§61.153 Reporting x MACT 40CFR63 NESHAPs for Source Categories (MACT) x MACT 40CFR63 Subpart A HAP General §§63.1-63.16 General Provisions x MACT 40CFR63 Subpart HH HAP ONG 6/17/1999 6/17/02 §§63.760- 63.779 Oil and Natural Gas Production Facilities x Compressor station TEG MACT 40CFR63 Subpart HHH HAP 6/17/1999 (64FR32610) 6/17/02 §§63.1270- 63.1289 Natural Gas Transmission and Storage Facilities x Facility is in oil and natural gas production source category MACT 40CFR63 Subpart EEEE HAP OLD 2/3/2004 (69FR5038) 2/3/07 §§63.2330- 63.2406 Organic Liquids Distribution (Non- Gasoline) x Facility is an area source H-4 MACT 40CFR63 Subpart YYYY HAP CT 3/5/2004 (69FR15011) 3/5/07 §§63.6080-63.6115 Stationary Combustion Turbines x Facility does not operate affected source(s) MACT 40CFR63 Subpart ZZZZ HAP ICE 6/15/2004 (69FR33473) 1/18/2008 (73FR3568) 6/15/07 1/18/11 §§63.650- 63.6675 Stationary Reciprocating Internal Combustion Engines x Facility is an area source. Area source provisions do not apply to existing RICE MACT 40CFR63 Subpart DDDDD HAP Boilers & Process Heaters 9/13/2004 (60FR55217) 3/21/11 §§63.7480- 63.7575 Industrial, Commercial and Institutional Boilers and Process Heaters x Facility does not operate affected source(s) MACT 40CFR63 Subpart GGGGG HAP SR 10/8/2003 (68FR58171) 10/8/06 §§63.7880-63.7957 Site Remediation x Facility is an area source MACT 40CFR63 Subpart UUUUU PM, SO2, NOx Rule affects coal and oil fired EGUs x Facility does not burn coal or oil MACT 40CFR63 Subpart JJJJJ Area Source Boilers 1/20/14 Area Source ICI Boilers x Facility does not operate affected source(s) CAM 40CFR64 PSEU §§64.1-64.10 Compliance Assurance Monitoring (CAM) x Facility does not operate affected source(s) CAM 40CFR64 PSEU §§64.1 Definitions x CAM 40CFR64 PSEU §§64.2 Applicability x Exempt from CAM due to use of CEMS CAR 40CFR65 VOC Consolidated Federal Air Rule (CAR) RMP 40CFR68 Listed Chemicals Chemical Accident Prevention x ODS 40CFR82 Subpart B ODS §§82.30-82.42 Servicing of Motor Vehicle Air x Facility does not service ODS 40CFR82 Subpart F ODS §§82.150- 82.169 Recycling and Emissions Reduction x Facility does not service ODS 40CFR82 Subpart H ODS §§82.250- 82.270 Halon Emissions Reduction x Facility does not operate GHG 40CFR98 Facilities emitting >/= 25,000 metric tons of CO2e of GHG, reporting under RGGI or Acid x NSPS 40CFR60 Subpart Kb VOC Tanks 07/23/84 (49FR29713) 04/08/87 (52FR11420) §§60.110b- 60.116b Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, x VOL tanks that commenced construction after July 23, 1984 are less H-5 Reconstruction, or Modification Commenced After July 23, 1984 than the 75 m3 capacity and exempt as provided by 40 CFR60.110b(d )(4). NSPS 40CFR60 Subpart GG NOx, SO2 CT 10/03/77 (42FR53782) 4/14/03 (68 FR 17989) 9/10/79 (44FR52798) 7/8/04 (69FR41345) §§60.330- 60.335 Stationary Gas Turbines x NSPS 40CFR60 Subpart KKK VOC NGPP 01/20/84 (49FR2636) 06/24/85 (50FR26122) §§60.330- 60.336 Equipment Leaks of VOC from Onshore Natural Gas Processing Plants x Facility commenced construction, reconstructio n or modification prior to January 20, 1984 NSPS 40CFR60 Subpart LLL SO2 NGPP 01/20/84 (49FR2656) 10/01/85 (50FR2656) §§60.330- 60.648 Onshore Natural Gas Processing: SO2 Emissions x Facility commenced construction, reconstructio n or modification prior to January 20, 1984 NSPS 40CFR60 Subpart CCCC D/F, Cd, Pb, Hg, PM, HCI, NO. SO2. CO, Fug. Ash, opacity CISWI §§60.2000- 60.2265 CISWIs for Which Construction is Commenced After November 30, 1999 or for Which Modification or Reconstruction is Commenced on or After June 1, 2001 x Facility does not operate affected source(s) NSPS 40CFR60 Subpart DDDD D/F, Cd, Pb, Hg, PM, HCI, NO. SO2. CO, Fug. Ash, opacity CISWI §§60.2500- 60.2875 Emissions Guidelines and Compliance Times for CISWIs that Commenced Construction On or Before November 30, 1999 x Facility does not operate affected source(s) H-6 NSPS 40CFR60 Subpart IIII NOx ICE 07/11/05 07/11/2006 §§60.4200- 60.4219 Stationary Compression Ignition Internal Combustion Engines x Emergency stationary CI- ICE commenced construction prior to July 11, 2005 NSPS 40CFR60 Subpart JJJJ NOx ICE 6/12/06 1/18/2008 Stationary Spark-Ignition Internal Combustion Engines x Stationary SI- ICE commenced construction prior to June 12, 2006 NSPS 40CFR60 Subpart KKKK NOx, SO2 CT 2/18/08 (70FR8314) 07/06/2006 (71FR68482) CTs for Which Construction is Commenced After February 18, 2005 or for Which Modification or Reconstruction is Commenced on or After February 27, 2006 x Facility does not operate affected source(s) NESHAP 40CFR61 Subpart A General §§61.01-61.19 General Provisions x NESHAP 40CFR61 Subpart M Asbestos §§61.140- 61.157 Asbestos x Facility has not engaged in demolition or renovation activities NESHAP 40CFR61 Subpart M Asbestos §§61.140 Applicability x NESHAP 40CFR61 Subpart M Asbestos Demolition & §§61.145 Standard for demolition and renovation x NESHAP 40CFR61 Subpart M Asbestos Demolition & Renovation §§61.150 Standard for waste disposal for manufacturing, fabricating, demolition x NESHAP 40CFR61 Subpart M Asbestos Demolition & Renovation §§61.153 Reporting x MACT 40CFR63 NESHAPs for Source Categories (MACT) x MACT 40CFR63 Subpart A HAP General §§63.1-63.16 General Provisions x MACT 40CFR63 Subpart HH HAP ONG 6/17/1999 6/17/02 §§63.760- 63.779 Oil and Natural Gas Production Facilities x Compressor station TEG MACT 40CFR63 Subpart HHH HAP 6/17/1999 (64FR32610) 6/17/02 §§63.1270- 63.1289 Natural Gas Transmission and Storage Facilities x Facility is in oil and natural gas production H-7 source category MACT 40CFR63 Subpart EEEE HAP OLD 2/3/2004 (69FR5038) 2/3/07 §§63.2330- 63.2406 Organic Liquids Distribution (Non- Gasoline) x Facility is an area source MACT 40CFR63 Subpart YYYY HAP CT 3/5/2004 (69FR15011) 3/5/07 §§63.6080- 63.6115 Stationary Combustion Turbines x Facility does not operate affected source(s) MACT 40CFR63 Subpart ZZZZ HAP ICE 6/15/2004 (69FR33473) 1/18/2008 (73FR3568) 6/15/07 1/18/11 §§63.650- 63.6675 Stationary Reciprocating Internal Combustion Engines x Facility is an area source. Area source provisions do not apply to existing RICE MACT 40CFR63 Subpart DDDDD HAP Boilers & Process Heaters 9/13/2004 (60FR55217) 3/21/20 11 §§63.7480- 63.7575 Industrial, Commercial and Institutional Boilers and Process Heaters x Facility does not operate affected source(s) MACT 40CFR63 Subpart GGGGG HAP SR 10/8/2003 (68FR58171) 10/8/06 §§63.7880- 63.7957 Site Remediation x Facility is an area source MACT 40CFR63 Subpart UUUUU PM, SO2, NOx Rule affects coal and oil fired EGUs x Facility does not burn coal or oil MACT 40CFR63 Subpart JJJJJ Area Source Boilers 1/20/14 Area Source ICI Boilers x Facility does not operate affected source(s) CAM 40CFR64 PSEU §§64.1-64.10 Compliance Assurance Monitoring (CAM) x Facility does not operate affected source(s) CAM 40CFR64 PSEU §§64.1 Definitions x CAM 40CFR64 PSEU §§64.2 Applicability x Exempt from CAM due to use of CEMS CAR 40CFR65 VOC Consolidated Federal Air Rule (CAR) RMP 40CFR68 Listed Chemicals Chemical Accident Prevention x ODS 40CFR82 Subpart B ODS §§82.30-82.42 Servicing of Motor Vehicle Air x Facility does not service ODS 40CFR82 Subpart F ODS §§82.150- 82.169 Recycling and Emissions Reduction x Facility does not service H-8 ODS 40CFR82 Subpart H ODS §§82.250- 82.270 Halon Emissions Reduction x Facility does not operate GHG 40CFR98 Facilities emitting >/= 25,000 metric tons of CO2e of GHG, reporting under RGGI or Acid x I-1 APPENDIX I. PROPOSED EXEMPTIONS There are no exemptions to any applicable regulations or requirements for the Plant. The WVPP utilizes data obtained from the plant's natural gas vendor to monitor sulfur content in the natural gas fuel supply. Natural gas is used exclusively as the fuel source for the gas turbine engines.1 Nitrogen monitoring of the fuel supply for the five Generating Units can be waived because there is no fuel- bound nitrogen, therefore the fuel nitrogen does not contribute appreciably to the NOx emissions.2 1 40 CFR 72.7 (d)(1) 2 USEPA Memo, August 14, 1987 J-1 APPENDIX J. EMISSION TRADING This section is not applicable to the WVPP. K-1 APPENDIX K. COMPLIANCE PLAN / SCHEDULE Compliance Plan ►The WVPP is in compliance with all applicable requirements. ►The WVPP will continue to comply with all requirements with which the source is in compliance. ►The WVPP will comply with any requirement that becomes effective during the term of the permit. ►The WVPP is in compliance with all applicable requirements as stated in Appendix H of the permit application. Compliance Schedule ►The WVPP will continue to comply with applicable requirements with which this source is in compliance. ►The WVPP will comply with any requirement that becomes effective during the term of the permit. L-1 APPENDIX L. COMPLIANCE CERTIFICATIONS Compliance Plan Certification ►The rules and regulation defining the methods used for determining compliance, which include required monitoring, recordkeeping, reporting requirements and test methods, are identified in Appendices G and H of this application. ►Compliance certifications during the permit term will be submitted annually, at a minimum, on or before April 15 of each calendar year. ►This source is in compliance with all requirements as listed in Appendix H of this application. I hereby certify that, based on information and belief formed after reasonable inquiry, the statements and information in this document are true, accurate and complete. Responsible Official's Signature: ________________________________________________ Date: ________________________________________________ 12/13/2023 M-1 APPENDIX M. ACID RAIN PERMIT The Acid Rain permit conditions are in Section IV of the Title V Permit. EPA Form 7610-16 (Revised 8-2019) STEP 1 Identify the facility name, State, and plant (ORIS) code. STEP 2 Enter the unit ID# for every affected unit at the affected source in column "a." United States Environmental Protection Agency OMB No. 2060-0258 Acid Rain Program Approval expires 12/31/2021 Acid Rain Permit Application For more information, see instructions and 40 CFR 72.30 and 72.31. This submission is: new revised for ARP permit renewal Facility (Source) Name State Plant Code a b Unit ID# Unit Will Hold Allowances in Accordance with 40 CFR 72.9(c)(1) Yes Yes Yes Yes Yes West Valley Power Plant Utah 55622 1 2 3 4 5 x EPA Form 7610-16 (Revised 8-2019) Acid Rain - Page 2 Facility (Source) Name (from STEP 1) STEP 3 Permit Requirements Read the standard requirements. (1) The designated representative of each affected source and each affected unit at the source shall:(i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFRpart 72 in accordance with the deadlines specified in 40 CFR 72.30; and(ii) Submit in a timely manner any supplemental information that the permitting authoritydetermines is necessary in order to review an Acid Rain permit application and issue or denyan Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall:(i) Operate the unit in compliance with a complete Acid Rain permit application or a supersedingAcid Rain permit issued by the permitting authority; and(ii) Have an Acid Rain Permit. Monitoring Requirements (1) The owners and operators and, to the extent applicable, designated representative of eachaffected source and each affected unit at the source shall comply with the monitoringrequirements as provided in 40 CFR part 75.(2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall beused to determine compliance by the source or unit, as appropriate, with the Acid Rain emissionslimitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under theAcid Rain Program.(3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operatorsto monitor emissions of other pollutants or other emissions characteristics at the unit under otherapplicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements (1) The owners and operators of each source and each affected unit at the source shall:(i)Hold allowances, as of the allowance transfer deadline, in the source's compliance account(after deductions under 40 CFR 73.34(c)), not less than the total annual emissions of sulfurdioxide for the previous calendar year from the affected units at the source; and(ii)Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.(2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfurdioxide shall constitute a separate violation of the Act.(3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxiderequirements as follows:(i)Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or(ii)Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFRpart 75, an affected unit under 40 CFR 72.6(a)(3).(4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking Systemaccounts in accordance with the Acid Rain Program.(5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1)of the sulfur dioxide requirements prior to the calendar year for which the allowance wasallocated.(6) An allowance allocated by the Administrator under the Acid Rain Program is a limitedauthorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of theAcid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the UnitedStates to terminate or limit such authorization.(7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute aproperty right. Nitrogen Oxides Requirements The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. EPA Form 7610-16 (Revised 8-2019) Acid Rain - Page 3 Facility (Source) Name (from STEP 1) STEP 3, Cont’d.Excess Emissions Requirements (1) The designated representative of an affected source that has excess emissions in any calendaryear shall submit a proposed offset plan, as required under 40 CFR part 77.(2) The owners and operators of an affected source that has excess emissions in any calendar yearshall:(i) Pay without demand the penalty required, and pay upon demand the interest on that penalty,as required by 40 CFR part 77; and(ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeeping and Reporting Requirements (1) Unless otherwise provided, the owners and operators of the source and each affected unit at thesource shall keep on site at the source each of the following documents for a period of 5 yearsfrom the date the document is created. This period may be extended for cause, at any time priorto the end of 5 years, in writing by the Administrator or permitting authority:(i) The certificate of representation for the designated representative for the source and eachaffected unit at the source and all documents that demonstrate the truth of the statements inthe certificate of representation, in accordance with 40 CFR 72.24; provided that thecertificate and documents shall be retained on site at the source beyond such 5-year perioduntil such documents are superseded because of the submission of a new certificate ofrepresentation changing the designated representative;(ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to theextent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-year periodshall apply.(iii) Copies of all reports, compliance certifications, and other submissions and all records madeor required under the Acid Rain Program; and,(iv) Copies of all documents used to complete an Acid Rain permit application and any othersubmission under the Acid Rain Program or to demonstrate compliance with therequirements of the Acid Rain Program.(2) The designated representative of an affected source and each affected unit at the source shallsubmit the reports and compliance certifications required under the Acid Rain Program, includingthose under 40 CFR part 72 subpart I and 40 CFR part 75. Liability (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, acomplete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7or 72.8, including any requirement for the payment of any penalty owed to the United States, shallbe subject to enforcement pursuant to section 113(c) of the Act.(2) Any person who knowingly makes a false, material statement in any record, submission, or reportunder the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c)of the Act and 18 U.S.C. 1001.(3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program thatoccurs prior to the date that the revision takes effect.(4) Each affected source and each affected unit shall meet the requirements of the Acid RainProgram.(5) Any provision of the Acid Rain Program that applies to an affected source (including a provisionapplicable to the designated representative of an affected source) shall also apply to the ownersand operators of such source and of the affected units at the source.(6) Any provision of the Acid Rain Program that applies to an affected unit (including a provisionapplicable to the designated representative of an affected unit) shall also apply to the owners andoperators of such unit. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected sourceor affected unit, or by an owner or operator or designated representative of such source or unit,shall be a separate violation of the Act. EPA Form 7610-16 (Revised 8-2019) Acid Rain - Page 4 Facility (Source) Name (from STEP 1) STEP 3, Cont’d.Effect on Other Authorities No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or anexemption under 40 CFR 72.7 or 72.8 shall be construed as:(1) Except as expressly provided in title IV of the Act, exempting or excluding the owners andoperators and, to the extent applicable, the designated representative of an affected source oraffected unit from compliance with any other provision of the Act, including the provisions of title Iof the Act relating to applicable National Ambient Air Quality Standards or State ImplementationPlans;(2) Limiting the number of allowances a source can hold; provided, that the number of allowancesheld by the source shall not affect the source's obligation to comply with any other provisions ofthe Act;(3) Requiring a change of any kind in any State law regulating electric utility rates and charges,affecting any State law regarding such State regulation, or limiting such State regulation, includingany prudence review requirements under such State law;(4) Modifying the Federal Power Act or affecting the authority of the Federal Energy RegulatoryCommission under the Federal Power Act; or,(5) Interfering with or impairing any program for competitive bidding for power supply in a State inwhich such program is established. STEP 4 Certification Read the I am authorized to make this submission on behalf of the owners and operators of the affected certification source or affected units for which the submission is made. I certify under penalty of law that I have statement, sign,personally examined, and am familiar with, the statements and information submitted in this and date.document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment. DateSignature Name Kevin Garlick 12/13/2023 1 The Acid Rain Program requires the designated representative to submit an Acid Rain permit application for each source with an affected unit. A complete Certificate of Representation must be received by EPA before the permit application is submitted to the Title V permitting authority. A complete Acid Rain permit application, once submitted, is binding on the owners and operators of the affected source and is enforceable in the absence of a permit until the Title V permitting authority either issues a permit to the source or disapproves the application. Please type or print. If assistance is needed, contact the Title V permitting authority. STEP 1 A Plant Code is a 4 or 5 digit number assigned by the Department of Energy’s (DOE) Energy InformationAdministration (EIA) to facilities that generate electricity. For older facilities, "Plant Code" is synonymous with"ORISPL" and "Facility" codes. If the facility generates electricity but no Plant Code has been assigned, or if thereis uncertainty regarding what the Plant Code is, send an email to the EIA. The email address is EIA-860@eia.gov. STEP 2 In column "a," identify each unit at the facility by providing the appropriate unit identification number, consistentwith the identifiers used in the Certificate of Representation and with submissions made to DOE and/or EIA. Donot list duct burners. For new units without identification numbers, owners and operators must assign identifiersconsistent with EIA and DOE requirements. Each Acid Rain Program submission that includes the unitidentification number(s) (e.g., Acid Rain permit applications, monitoring plans, quarterly reports, etc.) shouldreference those unit identification numbers in exactly the same way that they are referenced on the Certificate ofRepresentation. Submission Deadlines For new units, an initial Acid Rain permit application must be submitted to the Title V permitting authority 24 months before the date the unit commences operation. Acid Rain permit renewal applications must be submitted at least 6 months in advance of the expiration of the acid rain portion of a Title V permit, or such longer time as provided for under the Title V permitting authority’s operating permits regulation. Submission Instructions Submit this form to the appropriate Title V permitting authority. If you have questions regarding this form, contact your local, State, or EPA Regional Acid Rain contact, or call EPA's Clean Air Markets Hotline at (202) 343-9620. Paperwork Burden Estimate The public reporting and record keeping burden for this collection of information is estimated to average 8 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address. Instructions for the Acid Rain Program Permit Application