DAQ-2025-002251

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DAQC-382-25
Site ID 12825 (B1)

MEMORANDUM

TO: FILE – UTAH ASSOCIATED MUNICIPAL POWER SYSTEMS (UAMPS) – Nebo
Power Plant

THROUGH: Harold Burge, Major Source Section Manager

FROM: Jeremiah Marsigli, Environmental Scientist

DATE: April 17, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Utah County,
FRS ID#UT0000004904900234

INSPECTION DATE: April 16, 2025

SOURCE ADDRESS: 1265 Bamberger Road, Payson, Utah 84651

MAILING ADDRESS: 1265 Bamberger Road, Payson, Utah 84651

SOURCE CONTACTS: David Gammell – Assistant Pant Manager: [phone]

OPERATING STATUS: Operating in combined cycle mode

PROCESS DESCRIPTION: UAMPS operates a combined cycle natural gas turbine engine and
HRSG with duct burner for the generation of electrical power. Natural
gas is burned in a turbine engine and duct burner, which produces 141
megawatts of power. Exhaust from the turbine is cooled in the cooling
towers. NOX emissions are controlled by a dry-low-NOX burner and
selective catalytic reduction system. Steam generated goes through the
heat recover steam generator, duct burner with SCR for NOx control and
the steam turbine generator set. Electricity produced at this plant is sold
to the grid to provide municipal power.

Under Title IV of the CAA (Acid Rain Program), UAMPS is required to
monitor emissions for pollutants responsible for acid rain formation. It
includes provisions for a two-phase reduction of SO2 and NOx emissions
nationwide and a program for emission trading and accounting. The
UAMPS utilizes a natural gas fired turbine equipped with an HRSG and
duct burner for steam generation. Provisions of Title IV are primarily
emission monitoring requirements. Because UAMPS is fueled by natural
gas only, an SO2 monitor is not required.

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APPLICABLE
REGULATIONS: Title V Operating Permit #4900234004, Date of Permit January 18,
2022; Date of Last Revision January 18, 2022

Federal Rules incorporated into the permit:
40 CFR 72 - Title IV – Acid Rain Program Phase II
40 CFR 60, Subpart Da -NSPS Electric Utility Steam Generating Units
40 CFR 60, Subpart GG - NSPS Stationary Gas Turbines
40 CFR 63, Subpart ZZZZ – NESHAP for Stationary Reciprocating
Internal Combustion Engines

SOURCE INSPECTION EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. The source appeared to be operating in compliance with the conditions of this
permit. See each condition below for more specific details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

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I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: In compliance. The source appeared to be operating in compliance with the conditions of this
permit. See each condition below for more specific details.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The permit has not expired.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: This permit expires January 18, 2027. Application for renewal is due by July 18, 2026.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is not an inspection item.

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I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. Permit fees have been paid as invoiced.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance. Entry was allowed during this inspection. Records were provided as requested.

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I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All application forms, reports, or compliance certifications submitted pursuant
to this permit in the past year appeared to have contained certification as to its truth,
accuracy, and completeness by a responsible individual as defined in R307-415-3.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

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I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-415-
6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance. The last certification was received by DAQ on January 24, 2024. This report
was reviewed under separate cover and found to meet the requirements of this condition.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: Any permit shields are listed in section three below.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g (1))
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I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g (4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: In compliance. No emergency events were reported or recorded during the 12-month period
preceding this inspection.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: This is not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: This is not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: This is not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: This is not an inspection item.
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I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit. (R307-415-
6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

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I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129
For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail
code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records are kept as required. No deviations have been recorded or reported.
Monitoring reports have been submitted every six months. The semi-annual report for the
period ending December 31, 2024, was mailed to DAQ along with the Annual Compliance
Certification but could not be located in DAQ’s source files. A replacement copy was
immediately provided along with a certified mail receipt. The report and mail receipt are
attached.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

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I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit. (R307-415-
7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance. Emission inventories have been submitted as required.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 #1: GE Frame 7-EA Generator (in Simple Cycle Mode)
Gas turbine generator equipped with dry-low-NOx burners and an inlet evaporative cooler. The
maximum heat input is 880 MMBTU/hr (HHV) at the baseload. NSPS GG

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II.A.3 #2: GE Frame 7-EA Generator (in Combined Cycle Mode)
Gas turbine generator equipped with one HRSG and steam turbine generator set, with maximum
heat input of 992 MMBtu/hr (HHV) at the baseload. The duct burner (NSPS Da) with maximum
firing rate at 312 MM BTU/hr (LHV), equipped with a SCR for NOx control.

II.A.4 #3: Emergency Generator
One emergency generator rated at 60 kW, constructed before Jun 12, 2006. NESHP ZZZZ

II.A.5 #4: Cooling Tower
One cooling tower with 3 cells. No-unit specific applicable requirements

Status: In compliance. No unapproved equipment was observed.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on Permitted Source (Source-wide).

II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, 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 Executive Secretary which may include, but is not limited
to, monitoring results, opacity observations, review of operating and maintenance procedures, and
inspection of the source. [Origin: DAQE-AN128250007-17]. [R307-401-8]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit. [R307-415-6b]

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The equipment appeared to be maintained in a manner consistent with good air
pollution control practices for minimizing emissions. A computerized work order program called
Rüftechnik Fluke X5 is used to track and record maintenance activities on the generator, duct
burner, and associated equipment. The emergency generator is maintained by Wheeler Caterpillar.

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II.B.1.b Condition:

Combined CO emissions shall be no greater than 96.46 tons per 12-month rolling period.
[DAQE-AN128250007-17]. [R307-401-8]

II.B.1.b.1 Monitoring:

The emissions shall be determined on a rolling 12-month total. Within the first 20 days of each
month, the total shall be calculated for each calendar month and added to the previous 11 months
data.

Monthly emissions shall be the sum of emissions from the gas turbine, duct burner, and
emergency generator. Emissions from the gas turbine and the duct burner shall be obtained from
CEMS recorded data. Emissions from the emergency generator shall be obtained by multiplying
the engine rating, recorded hours of operation and emission factors from the Vendor data if
available or EPA's Compilation of Air Pollutant Emission Factors, AP-42.

Hours of operation for emergency generator shall be determined by the operations log.

II.B.1.b.2 Recordkeeping:

Daily consumption or usage records shall be maintained for all periods of operation. All records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. These records are available in a spreadsheet which shows the turbine, generator and
burner totals, and combined totals. The 12-month totals for the duct burner and turbine can be
drawn from the CEMS recording system. The 12-month CO total ending March 31, 2025, was
34.385 tons.

II.B.1.c Condition:

Combined NOx emissions shall be no greater than 69 tons per 12-month rolling period. [DAQE-
AN128250007-17]. [R307-401-8(1)(a)(BACT)]

II.B.1.c.1 Monitoring:

The emissions shall be determined on a rolling 12-month total. Within the first 20 days of each
month, the total shall be calculated for each calendar month and added to the previous 11 months
data.

Monthly emissions shall be the sum of emissions from the gas turbine, duct burner, and
emergency generator. Emissions from the gas turbine and the duct burner shall be obtained from
CEMS recorded data. Emissions from the emergency generator shall be obtained by multiplying
the engine rating, recorded hours of operation and emission factors from the Vendor data if
available or EPA's Compilation of Air Pollutant Emission Factors, AP-42.

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Hours of operation for emergency generator shall be determined by the operations log.

II.B.1.c.2 Recordkeeping:

Daily consumption or usage records shall be maintained for all periods of operation. All records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. These records are available in a spreadsheet which shows the turbine, generator and
burner totals, and combined totals. The 12-month totals for the duct burner and turbine can be
drawn from the CEMS recording system. The 12-month NOx total ending March 31, 2025, was
58.344 tons.

II.B.1.d Condition:

The permittee shall use only natural gas as fuel in the gas turbine and duct burner. Fuel oil #2 or better
shall be used as fuel in the emergency generator. [DAQE-AN128250007-17]. [R307-401-8]

II.B.1.d.1 Monitoring:

In lieu of fuel monitoring, the report required for this permit condition will serve as monitoring.

II.B.1.d.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit.

II.B.1.d.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee shall
certify with each annual certification report that fuel usages in each affected unit compliance with
the permit condition during the reporting year.

Status: In compliance. Only pipeline quality natural gas is burned in the turbine and duct burner.

II.B.1.e Condition:

The sulfur content of fuel oil burned shall be no more than 0.0015% by weight unless otherwise specified
in this permit. [DAQE-AN128250007-17]. [R307-401-8]

II.B.1.e.1 Monitoring:

Sulfur content shall be determined either by testing each fuel delivery of fuel oil or by inspection
of the fuel sulfur-content specifications provided by the vendor in purchase records. Sulfur
content in either instance shall be determined in accordance with ASTM-D-4294-89, or approved
equivalent.

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II.B.1.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The most recent fuel delivery trip ticket showed #2 ULSD was received from Bridge
Source.

II.B.1.f Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[40 CFR 82.150(b)]. [40 CFR 82]

II.B.1.f.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.f.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.f.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The source certified compliance with this condition in the most recent annual
compliance certification.

II.B.1.g Condition:

The permittee shall develop, maintain, and implement a written Emissions Minimization Plan that
describes, in detail, procedures for operating and maintaining the GE Frame 7-EA Generator, including
associated air pollution control and monitoring equipment, during events of startup and shutdown.

The plan shall contain detailed steps to minimize, to the maximum extent practicable, the frequency and
duration of operation in startup or shutdown and shall be followed at all times. This shall include, but not
necessarily be limited to: careful and detailed design, planning, operation, and maintenance so as to avoid
unnecessary, preventable, or unreasonably frequent or lengthy startups and shutdowns.

The permittee should periodically revise the plan as necessary to satisfy the requirements of this condition
or to reflect changes in equipment or procedures at the affected source. Each such revision must be
submitted to the Director. [DAQE-AN28250007-17]. [R307-401-8]

15
II.B.1.g.1 Monitoring:

Recordkeeping requirement required in this permit condition shall serve as monitoring
requirement.

II.B.1.g.2 Recordkeeping:

The permittee shall maintain records demonstrating the procedures in the Emissions
Minimization Plan were followed. These records shall include the date and time of occurrence
and duration of each startup and shutdown, total hours of startup and shutdown every calendar
year for each affected unit, emissions during startup and shutdown as well as other pertinent
information.

II.B.1.g.3 Reporting:

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. An emissions minimization plan was provided and appeared to include the
requirements of this condition. The plan was last updated in 2024.

II.B.1.h Condition:

The following shall be installed and operational:

(1) The gas turbine shall be equipped with an inlet evaporative cooler;

(2) The HRSG shall be equipped with a Selective Catalytic Reduction System for abatement of NOx
emissions from the duct burner and the gas turbine;

(3) Continuous Emission Monitoring Systems for NOx, CO and O2 (CEMS) shall be provided for
monitoring emissions from the gas turbine bypass stack, when operating in a simple cycle mod; or gas
turbine, HRSG and duct burner main stack, when operating in combined cycle mode;

(4) The height of the gas turbine bypass stack shall be no less than 100 feet as measured from the base of
the stack;

(5) The height of the main stack shall be no less than 150 feet as measured from the base of the stack.
[DAQE-AN28250007-17]. [R307-401-8]

II.B.1.h.1 Monitoring:

Recordkeeping requirement required in this permit condition shall serve as monitoring
requirement.

II.B.1.h.2 Recordkeeping:

A log shall be kept indicating that the installation has been completed.

16
II.B.1.h.3 Reporting:

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. This equipment has been installed and is operated. Stack heights have not been
reduced. The CEMs for NOx, CO, and O2 are installed and reporting under R307-170 is
completed.

II.B.2 Conditions on GE Frame 7-EA Generator (in Simple Cycle Mode) (Emission Unit #1).

II.B.2.a Condition:

Visible emission shall be no greater than 10 % opacity. [DAQE-AN128250007-17]. [R307-401-8]

II.B.2.a.1 Monitoring:

The annual certification required for this permit condition will serve as monitoring.

II.B.2.a.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit

II.B.2.a.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee shall
certify each annual certification report that only pipeline quality natural gas is used as fuel during
the reporting year.

Status: In compliance. The source certified continuous compliance with this condition in the most recent
annual compliance certification. The plant was not operating in simple cycle mode at the time of
this inspection.

II.B.2.b Condition:

Emissions of CO from the gas turbine at the simple cycle mode shall be no greater than 25 ppmdv (15%
O2, dry) based on 8-hour block average under steady state operation (not including startup and shutdown).
[DAQE-AN128250007-17]. [R307-401-8]

II.B.2.b.1 Monitoring:

The emission of CO shall be monitored by continuous emission monitoring system (CEMS)
consisting of CO and O2 monitors. The O2 monitor shall be used to adjust the measured CO
concentrations to 15% O2. The permittee shall calibrate, maintain, and operate a CEMS as
required by R307-170 to determine compliance with CO concentration. The quality assurance
requirements of R307-170, Continuous Emission Monitoring Systems Program shall be used to
fulfill data quality assurance requirements. The hourly average of CO emissions shall be
calculated every hour and the 8-hour block average shall be calculated using the hourly average
data.

17
II.B.2.b.2 Recordkeeping:

Results of CO monitoring shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and all the reporting
provisions contained in Section I of this permit. The quarterly reports required in R307-170-9 is
considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if
all information required by Provision I.S.2.c is included in the report.

Status: Not evaluated. Compliance with the CEM requirements in this condition are evaluated by DAQ’s
CEM specialist.

II.B.2.c Condition:

Emission of NOx from the gas turbine at the simple cycle mode shall be no greater than 9 ppmdv (15%
O2, dry) based on 30 day rolling average under steady state operation (not including startup and
shutdown) and shall be no greater than 97.12 ppmdv (15% O2, dry) during all periods of unit operation.
[DAQE-AN128250007-17]. [40 CFR 60.332(a)(1), R307-401-8(1)(a)(BACT)]

II.B.2.c.1 Monitoring:

(a) The permittee shall install, certify, maintain, operate, and quality-assure a continuous
emission monitoring system (CEMS) consisting of NOx and O2 monitors to determine compliance
with the applicable NOx limitations. The CEMS shall be installed, certified, maintained and
operated as follows:

(1) Each CEMS must be installed and certified according to PS 2 and 3 (for diluent) of 40 CFR
part 60, appendix B, except the 7-day calibration drift is based on unit operating days, not
calendar days. Appendix F, Procedure 1 is not required. The relative accuracy test audit (RATA)
of the NOx and diluent monitors may be performed individually or on a combined basis, i.e., the
relative accuracy tests of the CEMS may be performed either:

(i) On a ppm basis (for NOx) and a percent O2 basis for oxygen; or

(ii) On a ppm at 15 percent O2 basis.

(2) As specified in 40 CFR 60.13(e)(2), during each full unit operating hour, each monitor must
complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each
15-minute quadrant of the hour, to validate the hour. For partial unit operating hours, at least one
valid data point must be obtained for each quadrant of the hour in which the unit operates. For
unit operating hours in which required quality assurance and maintenance activities are
performed on the CEMS, a minimum of two valid data points (one in each of two quadrants) are
required to validate the hour.

(3) For purposes of identifying excess emissions, CEMS data must be reduced to hourly
averages as specified in 40 CFR 60.13(h).

18
(i) For each unit operating hour in which a valid hourly average, as described in paragraph
(a)(2) of this section, is obtained for both NOx and diluent, the data acquisition and handling
system must calculate and record the hourly NOx emissions in the units of percent NOx by
volume, dry basis, corrected to 15 percent O2. For any hour in which the hourly average O2
concentration exceeds 19.0 percent O2, a diluent cap value of 19.0 percent O2 may be used in the
emission calculations.

(ii) If the permittee has installed a NOx CEMS to meet the requirements of 40 CFR Part 75 and
is continuing to meet the ongoing requirements of 40 CFR Part 75, the CEMS may be used to
meet the requirements of this section, except that the missing data substitution methodology
provided for at 40 CFR Part 75, subpart D, is not required for purposes of identifying excess
emissions. Instead, periods of missing CEMS data are to be reported as monitor downtime in the
excess emissions and monitoring performance report required in Sec. 60.7(c).

(b) Each continuous emission monitoring system shall meet the Specifications and Test
Procedures required by 40 CFR Part 75, Appendix A.

(c) The permittee shall implement Quality Assurance and Quality Control Procedures required by
40 CFR Part 75, Appendix B.

(d) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, shall be used in addition to 40 CFR Part 75 procedures to fulfill data quality assurance
requirements.

(e) The daily average of NOx emissions shall be calculated once for each day and the 30-day
rolling average shall be calculated by adding previous 30 days data on a daily basis.

II.B.2.c.2 Recordkeeping:

Results of NOx monitoring shall be recorded and maintained as required in R307-170, 40 CFR 60
subpart GG, 40 CFR 75 subpart F, and as described in Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

(a) The permittee shall comply with the reporting provisions in R307-170-9, 40 CFR 75
Subpart G, 40 CFR Subpart GG and all the reporting provisions contained in Section I of this
permit.

(b) The permittee shall submit reports of excess emissions and monitor downtime, in
accordance with 40 CFR 60.7(c). Excess emissions shall be reported for all periods of unit
operation, including startup, shutdown and malfunction. For the purpose of reports required under
40 CFR 60.7(c), periods of excess emissions and monitor downtime that shall be reported are
defined as follows:

(1) An hour of excess emissions shall be any unit operating hour in which the 4-hour rolling
average NOx concentration exceeds applicable NSPS emission standard of 97.12 ppmdv (15% O2,
dry). A ``4-hour rolling average NOx concentration'' is the arithmetic average of the average NOx
concentration measured by the CEMS for a given hour (corrected to 15 percent O2) and the three-
unit operating hour average NOx concentrations immediately preceding that unit operating hour.

19
(2) A day of excess emission shall be any unit operating period in which the 30-day rolling
average NOx concentration exceeds the applicable limit. A "30-day rolling average NOx emission
rate'' is the arithmetic average of all hourly NOx emission data in ppm measured by the CEMS for
a given day and the twenty-nine-unit operating days average NOx emission rates immediately
preceding that unit operating day. A new 30-day average is calculated each unit operating day as
the average of all hourly NOx emissions rates for the preceding 30-unit operating days if a valid
NOx emission rate is obtained for at least 75 percent of all operating hours.

(3) A period of monitor downtime shall be any unit operating hour in which sufficient data are not
obtained to validate the hour, for either NOx concentration or diluent (or both).

(4) All reports of excess emissions and monitor downtime shall be postmarked by the 30th day
following the end of each 6-month period.

(c) The quarterly reports required in R307-170-9 and 40 CFR 75 Subpart G are considered prompt
notification of permit deviations required in Provision I.S.2.c of this permit if all information
required by Provision I.S.2.c is included in the report.

Status: Not evaluated. Compliance with the CEM requirements in this condition are evaluated by DAQ’s
CEM specialist.

II.B.2.d Condition:

Sulfur content of any natural gas burned shall be no more than 0.8 percent by weight. [40 CFR 60.333].
[40 CFR 60 Subpart GG]

II.B.2.d.1 Monitoring:

The annual certification required for this permit condition will serve as monitoring.

II.B.2.d.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit

II.B.2.d.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee shall
certify each annual certification report that only pipeline quality natural gas is used as fuel during
the reporting year. [R307-415-6b]

Status: In compliance. Only pipeline quality natural gas is burned. The source certified continuous
compliance with this condition in the most recent compliance certification.

II.B.3 Condition on GE Frame 7-EA Generator (in Combined Cycle Mode) (Emission Unit #2).

II.B.3.a Condition:

Visible emission shall be no greater than 10 % opacity. [DAQE-AN128250007-17]. [40 CFR 60.42a(b),
R307-401-8]

20
II.B.3.a.1 Monitoring:

The annual certification required for this permit condition will serve as monitoring.

II.B.3.a.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit

II.B.3.a.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee shall
certify each annual certification report that only pipeline quality natural gas is used as fuel during
the reporting year.

Status: In compliance. The source certified continuous compliance with this condition in the most recent
annual compliance certification. No connections other than natural gas were found. No visible
emissions were observed during this inspection.

II.B.3.b Condition:

Emission of NOx from the gas turbine and duct burner exhaust stack shall be no greater than 5 ppmdv
(15% O2, dry) based on 30 day rolling average under steady state operation (not including startup and
shutdown) and shall be no greater than 97.12 ppmdv (15% O2, dry) from the gas turbine during all
periods of unit operation. [DAQE-AN128250007-17]. [40 CFR 60.332(a)(1), 40 CFR 60.44Da(d)(2), 40
CFR 60 Subpart Da, 40 CFR 60 Subpart GG, R307-401-8]

II.B.3.b.1 Monitoring:

(a) The permittee shall install, certify, maintain, operate, and quality-assure a continuous
emission monitoring system (CEMS) consisting of NOx and O2 monitors to determine compliance
with the applicable NOx limitations. The CEMS shall be installed, certified, maintained and
operated as follows:

(1) Each CEMS must be installed and certified according to PS 2 and 3 (for diluent) of 40 CFR
part 60, appendix B, except the 7-day calibration drift is based on unit operating days, not
calendar days. Appendix F, Procedure 1 is not required. The relative accuracy test audit (RATA)
of the NOx and diluent monitors may be performed individually or on a combined basis, i.e., the
relative accuracy tests of the CEMS may be performed either:

(i) On a ppm basis (for NOx) and a percent O2 basis for oxygen; or

(ii) On a ppm at 15 percent O2 basis.

(2) As specified in 40 CFR 60.13(e)(2), during each full unit operating hour, each monitor must
complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each
15-minute quadrant of the hour, to validate the hour. For partial unit operating hours, at least one
valid data point must be obtained for each quadrant of the hour in which the unit operates. For
unit operating hours in which required quality assurance and maintenance activities are
performed on the CEMS, a minimum of two valid data points (one in each of two quadrants) are
required to validate the hour.
21
(3) For purposes of identifying excess emissions, CEMS data must be reduced to hourly
averages as specified in 40 CFR 60.13(h).

(i) For each unit operating hour in which a valid hourly average, as described in paragraph
(a)(2) of this section, is obtained for both NOx and diluent, the data acquisition and handling
system must calculate and record the hourly NOx emissions in the units of percent NOx by
volume, dry basis, corrected to 15 percent O2. For any hour in which the hourly average O2
concentration exceeds 19.0 percent O2, a diluent cap value of 19.0 percent O2 may be used in the
emission calculations.

(ii) If the permittee has installed a NOx CEMS to meet the requirements of 40 CFR Part 75 and
is continuing to meet the ongoing requirements of 40 CFR Part 75, the CEMS may be used to
meet the requirements of this section, except that the missing data substitution methodology
provided for at 40 CFR Part 75, subpart D, is not required for purposes of identifying excess
emissions. Instead, periods of missing CEMS data are to be reported as monitor downtime in the
excess emissions and monitoring performance report required in Sec. 60.7(c).

(b) Each continuous emission monitoring system shall meet the Specifications and Test
Procedures required by 40 CFR Part 75, Appendix A.

(c) The permittee shall implement Quality Assurance and Quality Control Procedures required by
40 CFR Part 75, Appendix B.

(d) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, shall be used in addition to 40 CFR Part 75 procedures to fulfill data quality assurance
requirements.

(e) The daily average of NOx emissions shall be calculated once for each day and the 30-day
rolling average shall be calculated by adding previous 30 days data on a daily basis.

II.B.3.b.2 Recordkeeping:

Results of NOx monitoring shall be recorded and maintained as required in R307-170, 40 CFR 60
subpart GG, 40 CFR 75 subpart F, and as described in Provision I.S.1 of this permit.

II.B.3.b.3 Reporting:

(a) The permittee shall comply with the reporting provisions in R307-170-9, 40 CFR 75 Subpart
G, 40 CFR Subpart GG and all the reporting provisions contained in Section I of this permit.

(b)The permittee shall submit reports of excess emissions and monitor downtime, in accordance
with 40 CFR 60.7(c). Excess emissions shall be reported for all periods of unit operation,
including startup, shutdown and malfunction. For the purpose of reports required under 40 CFR
60.7(c), periods of excess emissions and monitor downtime that shall be reported are defined as
follows:

(1) An hour of excess emissions shall be any unit operating hour in which the 4-hour rolling
average NOx concentration exceeds applicable NSPS emission standard of 97.12 ppmdv (15% O2,
dry). A ``4-hour rolling average NOx concentration'' is the arithmetic average of the average NOx
concentration from the gas turbine for a given hour (corrected to 15 percent O2) and the three-unit
operating hour average NOx concentrations immediately preceding that unit operating hour.
22
(2) A day of excess emission shall be any unit operating period in which the 30-day rolling
average NOx concentration exceeds the applicable limit. A "30-day rolling average NOx emission
rate'' is the arithmetic average of all hourly NOx emission data in ppm measured by the CEMS for
a given day and the twenty-nine-unit operating days average NOx emission rates immediately
preceding that unit operating day. A new 30-day average is calculated each unit operating day as
the average of all hourly NOx emissions rates for the preceding 30-unit operating days if a valid
NOx emission rate is obtained for at least 75 percent of all operating hours.

(3) A period of monitor downtime shall be any unit operating hour in which sufficient data are
not obtained to validate the hour, for either NOx concentration or diluent (or both).

(4) All reports of excess emissions and monitor downtime shall be postmarked by the 30th day
following the end of each 6-month period.

(c) The quarterly reports required in R307-170-9 and 40 CFR 75 Subpart G are considered
prompt notification of permit deviations required in Provision I.S.2.c of this permit if all
information required by Provision I.S.2.c is included in the report.

Status: Not evaluated. Compliance with the CEM requirements in this condition are evaluated by DAQ’s
CEM specialist.

II.B.3.c Condition:

Emissions of CO from the gas turbine at combined cycle mode shall be no greater than 10 ppmdv (15%
O2, dry) based on 8-hour block average under steady state operation (not including startup and shutdown).
[DAQE-AN128250007-17]. [R307-401-8(1)(a)(BACT)]

II.B.3.c.1 Monitoring:

The emission of CO shall be monitored by continuous emission monitoring system (CEMS)
consisting of CO and O2 monitors. The O2 monitor shall be used to adjust the measured CO
concentrations to 15% O2. The permittee shall calibrate, maintain, and operate a CEMS as
required by R307-170 to determine compliance with CO concentration. The quality assurance
requirements of R307-170, Continuous Emission Monitoring Systems Program shall be used to
fulfill data quality assurance requirements. The hourly average of CO emissions shall be
calculated every hour and the 8-hour block average shall be calculated using the hourly average
data.

II.B.3.c.2 Recordkeeping:

Results of CO monitoring shall be recorded and maintained as required in R307-170 and as
described in Provision I.S.1 of this permit.

23

II.B.3.c.3

Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and all the reporting
provisions contained in Section I of this permit. The quarterly reports required in R307-170-9 is
considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if
all information required by Provision I.S.2.c is included in the report.

Status: Not evaluated. Compliance with the CEM requirements in this condition are evaluated by DAQ’s
CEM specialist.

II.B.3.d Condition:

Sulfur content of any natural gas burned shall be no more than 0.8 percent by weight. [40 CFR 60.333].
[40 CFR 60 Subpart GG]

II.B.3.d.1 Monitoring:

The annual certification required for this permit condition will serve as monitoring.

II.B.3.d.2 Recordkeeping:

The annual certification required for this permit condition shall be maintained as described in
Provision I.S.1 of the permit

II.B.3.d.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee shall
certify each annual certification report that only pipeline quality natural gas is used as fuel during
the reporting year.

Status: In compliance. Only pipeline quality natural gas is burned. The source certified continuous
compliance with this condition in the most recent annual compliance certification.

II.B.3.e Condition:

Emissions of PM shall be no greater than 0.03 lb/MMBtu heat input from the duct burner. [40 CFR
60.42a(a)]. [40 CFR 60 Subpart Da]

II.B.3.e.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested at least once every five years, based on the date of the
last test. Tests may also be required at the direction of the Executive Secretary.

(b) Notification. At least 30 days before the test, the source shall notify the Executive Secretary
of the date, time, and place of testing and provide a copy of the test protocol. The source shall
attend a pretest conference if determined necessary by the Executive Secretary.

24
(c) Methods.

(1) The dry basis F factor (O2) procedures in Method 19 shall be used to compute the emission
rate of particulate matter.

(2) For the particular matter concentration, Method 5 shall be used at affected facilities without
wet FGD systems and Method 5B shall be used after wet FGD systems.

(i) The sampling time and sample volume for each run shall be at least 120 minutes and 1.70
dscm (60 dscf). The probe and filter holder heating system in the sampling train may be set to
provide an average gas temperature of no greater than 160 ±14 °C (320 ±25 °F).

(ii) For each particulate run, the emission rate correction factor, integrated or grab sampling and
analysis procedures of Method 3B shall be used to determine the O2 concentration. The O2
sample shall be obtained simultaneously with, and at the same traverse points as, the particulate
run. If the particulate run has more than 12 traverse points, the O2 traverse points may be reduced
to 12 provided that Method 1 is used to locate the 12 O2 traverse points. If the grab sampling
procedure is used, the O2 concentration for the run shall be the arithmetic mean of the sample O2
concentrations at all traverse points.

(d) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.

II.B.3.e.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.3.e.3 Reporting:

The results of stack testing shall be submitted to the Executive Secretary within 60 days of
completion of the testing. Reports shall clearly identify results as compared to permit limits and
indicate compliance status. There are no additional reporting requirements for this provision
except those specified in Section I of this permit.

Status: In compliance. Stack testing was last conducted June 2, 2021. Test results were submitted to DAQ
and audited in DAQC-1346-21. DAQ calculated test results for PM were 0.002 lb/MMBtu.

II.B.4 Conditions on Emergency Generator (Emission Unit #3).

II.B.4.a Condition:

Visible emission shall be no greater than 20 % opacity. [DAQE-AN128250007-17]. [R307-401-
8(1)(a)(BACT)]

25
II.B.4.a.1 Monitoring:

An opacity observation of each affected emission unit shall be conducted once every six months
by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9.
The individual is not required to be a certified visible emissions observer (VEO). If any visible
emissions are observed, an opacity determination of that emission unit shall be performed by a
certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the
initial observation.

II.B.4.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The emergency generator was not operating during this inspection. Opacity
observations are outsourced to Montrose Environmental, and have been conducted and recorded
semi-annually.

II.B.4.b Condition:

Emergency generators shall be used for electricity production only during periods when electric power
from the public utilities is interrupted, except for routine engine maintenance and testing. [DAQE-
AN128250007-17]. [R307-401-8(1)(a)(BACT)]

II.B.4.b.1 Monitoring:

An operation log shall be used to record the following information for each usage: date(s), total
hours used, and reason for usage.

II.B.4.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Emergency generator logs are kept and include the required information.

26
II.B.4.c Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Executive Secretary which may include, but is not limited
to, monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)].
[40 CFR 63 Subpart ZZZZ]

II.B.4.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. The
permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.4.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Generator maintenance is outsourced to Wheeler Caterpillar. Records are kept.

II.B.4.d Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
affected emission unit:

(1) The permittee shall operate the affected emission unit according to the requirements in paragraphs
(1)(a) through (1)(c). Any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in 1.a through 1.c, is prohibited.
If the engine is not operated in accordance with paragraphs 1.a through 1.c, it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.

(a) There is no time limit on the use of emergency stationary RICE in emergency situations.

(b) Operation for the purpose of maintenance checks and readiness testing is limited to 100 hours per
year, provided that the tests are recommended by Federal, State or local government, the manufacturer,
the vendor, or the insurance company associated with the engine. A petition for approval of additional
hours to be used for maintenance checks and readiness testing is not required if the permittee maintains
records indicating that Federal, State, or local standards require maintenance and testing of emergency
RICE beyond 100 hours per year.

27
(c) The permittee may operate up to 50 hours per year in non-emergency situations, but those 50 hours are
counted towards the 100 hours per year provided for maintenance and testing and shall meet the
requirements in 40 CFR 63.6640(f)(1)(iii).

(2) The permittee shall meet the following requirements at all times, except during periods of startup:

(a) Change oil and filter every 500 hours of operation or annually, whichever comes first.

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.

(3) The permittee have the option to utilize an oil analysis program as described in 40 CFR 63.6625(i) in
order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

(4) During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.

(5) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ. [Origin: 40 CFR 63.6595(a)(1), 40 CFR 636603(a), 40 CFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table
2d(4), 40 CFR 63 Subpart ZZZZ Table 2d(footnote 1), 40 CFR 63 Subpart ZZZZ Table 8].
[40 CFR 63 Subpart ZZZZ]

II.B.4.d.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under Federal, State, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
the unacceptable risk under Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

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The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

II.B.4.d.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation, including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for demand response
operation, the permittee shall keep records of the notification of the emergency situation, and the
time the engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.4.d.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the Federal, State or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8.
[40 CFR 63.6640(e)]

29
There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. A generator use log is kept and was provided. The generator only operated for
emergency operation, maintenance, and testing. No non-emergency operating hours were logged.
Maintenance and readiness testing is performed during a weekly, one half hour run, and has been
kept under the 100 hour per year limit. Maintenance is contracted to Wheeler Caterpillar and is
recorded. The generator does have a non-resettable hour meter, which showed 736.7 total lifetime
hours of run time.

II.C Emissions Trading

Not applicable to this source.

II.D Alternative Operating Scenarios.

Not applicable to this source.

II.E Source-specific Definitions.

The following definitions apply to the permittee. They include terms not defined in state or federal rules
or clarify or expand on existing definitions.

II.E.1 Startup. Startup begins when the fuel flow is detected and gas turbine generator load is less or equal to 45
MW.

II.E.2 Shutdown. Shutdown begins when the gas turbine generator load is less or equal to 45 MW. Shutdown
ends when the fuel flow is not detected.

II.E.3 Downtime. Downtime is that time between the end of shutdown and the beginning of startup.

II.E.4 Maintenance Outage. The removal of a unit from service availability to perform work on specific
components that can be deferred beyond the end of the next weekend, but requires the equipment be
removed from service before the next planned outage. Typically, a Maintenance Outage may occur
anytime during the year, have a flexible start date, and may or may not have a predetermined duration.

II.E.5

Status:
Planned Outage. The removal of a unit from service availability for inspection and/or general overhaul of
one or more major equipment groups. This outage usually is scheduled well in advance.

This is not an inspection item.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

30
SECTION IV: ACID RAIN PROVISIONS

IV.A Utah Acid Rain Program Authority.

Authority to implement the Acid Rain Program is contained in R307-417, Permits:
Acid Rain Sources, and R307-415-6a(4), Standard permit requirements [for operating
permits].

IV.B Permit Requirements.

IV.B.1 The designated representative of the source and each affected unit at the source shall:

IV.B.1.a Submit a complete Acid Rain permit application (including a compliance
plan) under R307-417 and 40 CFR Part 72 in accordance with the deadlines
specified in 40 CFR 72.30; and

IV.B.1.b Submit in a timely manner any supplemental information that the Director
determines is necessary in order to review an Acid Rain permit application
and issue or deny an Acid Rain permit;

IV.B.2 The owners and operators shall:

IV.B.2.a Operate each affected unit at the source in compliance with a complete Acid
Rain permit application or a superseding Acid Rain permit issued by the
Director; and

IV.B.2.b Have an Acid Rain Permit.

Status: The Utah Division of Air Quality has been given authority to implement portions of the
Title IV Acid Rain Program. This permit serves as the Phase II permit as the Title IV
component is included. The provisions of Title IV are incorporated into this permit. In
compliance.

IV.C Sulfur Dioxide Requirements.

IV.C.1 The owners and operators of each affected unit at the source shall:

IV.C.1.a Hold allowances, as of the allowance transfer deadline, in the unit's
compliance subaccount (after deductions under 40 CFR 73.34(c)) not less
than the total annual emissions of sulfur dioxide for the previous calendar year
from the unit; and

IV.C.1.b Comply with the applicable Acid Rain emissions limitations for sulfur
dioxide.

IV.C.2 Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for
sulfur dioxide shall constitute a separate violation of the Act.

IV.C.3 An affected unit shall be subject to the requirements under Provision IV.C.1. of the
sulfur dioxide requirements as follows:

31
IV.C.3.a Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or

IV.C.3.b Starting on the later of January 1, 2000 or the deadline for monitor
certification under 40 CFR Part 75, an affected unit under 40 CFR 72.6(a)(3).

IV.C.4 Allowances shall be held in, deducted from, or transferred among Allowance Tracking
System accounts in accordance with the Acid Rain Program.

IV.C.5 An allowance shall not be deducted in order to comply with the requirements under
Provision IV.C.1.a. of the sulfur dioxide requirements prior to the calendar year for
which the allowance was allocated.

IV.C.6 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain
Program. No provision of the Acid Rain Program, the Acid Rain permit application,
the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no
provision of law shall be construed to limit the authority of the United States to
terminate or limit such authorization.

IV.C.7 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
does not constitute a property right.

Status: This is an EPA program which has not been delegated to the State of Utah.

IV.D Nitrogen Oxides Requirements.

The owners and operators for each affected unit at the source shall be compliance with
the applicable Acid Rain emissions limitations for nitrogen dioxide.

Status: 40 CFR 76 – Acid Rain Nitrogen Oxides Emission Reduction Program only applies to
coal-fired utilities. UAMPS does use low NOx technology.

IV.E Monitoring Requirements.

IV.E.1 The owners and operators and, to the extent applicable, designated representative of
each affected unit at the source shall comply with the monitoring requirements as
provided in 40 CFR Parts 74, 75, and 76.

IV.E.2 The emissions measurements recorded and reported in accordance with 40 CFR Part
75 shall be used to determine compliance by the unit with the Acid Rain emissions
limitations and emissions reduction requirements for sulfur dioxide and nitrogen
oxides under the Acid Rain Program.

32
IV.E.3 The requirements of 40 CFR Parts 74 and 75 shall not affect the responsibility of the
owners and operators to monitor emissions of other pollutants or other emissions
characteristics at the unit under other applicable requirements of the Act and other
provisions of the operating permit for the source.

Status: Part 74 is the SO2 allowance program which is managed by the EPA. Part 75 establishes
requirement for the CEMS monitoring, recordkeeping, and reporting of SO2, NOx, and
CO2 emission and opacity data from affected units. UAMPS does have CEMS monitors
for CO, NOx, and O2. Because UAMPS is fired by natural gas, the opacity monitor is not
required. Part 75 requires reporting to EPA. Monitoring plan requirements are in the
Title V permit. Part 76 covers the NOx program as discussed above.

IV.F Recordkeeping and Reporting Requirements.

IV.F.1 Unless otherwise provided, the owners and operators for each affected unit at the
source shall keep on site at the source each of the following documents for a period of
5 years from the date the document is created. This period may be extended for cause,
at any time prior to the end of 5 years, in writing by the Administrator, USEPA, or
Director:

IV.F.1.a The certificate of representation for the designated representative for the
source and each affected unit at the source and all documents that demonstrate
the truth of the statements in the certificate of representation, in accordance
with 40 CFR 72.24; provided that the certificate and documents shall be
retained on site at the source beyond such 5-year period until such documents
are superseded because of the submission of a new certificate of
representation changing the designated representative;

IV.F.1.b All emissions monitoring information, in accordance with 40 CFR Part 75;

IV.F.1.c Copies of all reports, compliance certifications, and other submissions and all
records made or required under the Acid Rain Program; and,

IV.F.1.d Copies of all documents used to complete an Acid Rain permit application
and any other submission under the Acid Rain Program or to demonstrate
compliance with the requirements of the Acid Rain Program.

IV.F.2 The designated representative of each affected unit at the source shall submit the
reports and compliance certifications required under the Acid Rain Program, including
those under 40 CFR Part 72 Subpart I and 40 CFR Part 75.

Status: In compliance. Records and reports are maintained by UAMPS for 5 years.

IV.G Excess Emissions Requirements.

IV.G.1 The designated representative of an affected unit that has excess emissions in any
calendar year shall submit a proposed offset plan to the Administrator, USEPA, as
required under 40 CFR Part 77.

33
IV.G.2 The owners and operators of an affected unit that has excess emissions in any calendar
year shall:

IV.G.2.a Pay without demand the penalty required, and pay upon demand the interest
on that penalty, to the Administrator, USEPA, as required by 40 CFR Part 77;
and

IV.G.2.b Comply with the terms of an approved offset plan, as required by 40 CFR Part
77.

Status: This is an EPA program which has not been delegated to the state.

IV.H Liability.

IV.H.1 Any person who knowingly violates any requirement or prohibition of the Acid Rain
Program, a complete Acid Rain permit application, an Acid Rain permit, or a written
exemption under R307-417, 40 CFR 72.7 or 40 CFR 72.8, including any requirement
for the payment of any penalty owed to the United States, shall be subject to
enforcement pursuant to section 113(c) of the Act.

IV.H.2 Any person who knowingly makes a false, material statement in any record,
submission, or report under the Acid Rain Program shall be subject to criminal
enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001.

IV.H.3 No permit revision shall excuse any violation of the requirements of the Acid Rain
Program that occurs prior to the date that the revision takes effect.

IV.H.4 Each affected source and each affected unit shall meet the requirements of the Acid
Rain Program.

IV.H.5 Any provision of the Acid Rain Program that applies to an affected source (including
a provision applicable to the designated representative of an affected source) shall also
apply to the owners and operators of such source and of the affected units at the
source.

IV.H.6 Any provision of the Acid Rain Program that applies to an affected unit (including a
provision applicable to the designated representative of an affected unit) shall also
apply to the owners and operators of such unit. Except as provided under 40 CFR
72.44 (Phase II repowering extension plans) and 40 CFR 76.11 (NOx averaging
plans), and except with regard to the requirements applicable to units with a common
stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners
and operators and the designated representative of one affected unit shall not be liable
for any violation by any other affected unit of which they are not owners or operators
or the designated representative and that is located at a source of which they are not
the owners and operators, owners or operators, or the designated representative.

IV.H.7 Each violation of a provision of 40 CFR Parts 72, 73, 74, 75, 76, 77, and 78 by an
affected source or affected unit, or by an owner or operator or designated
representative of such source or unit, shall be a separate violation of the Act.

34
IV.H.8 The owners and operators of a unit governed by an approved early election plan shall
be liable for any violation of the plan or 40 CFR 76.8 at that unit. The owners and
operators shall be liable, beginning January 1, 2000, for fulfilling the obligations
specified in 40 CFR Part 77.

Status: This is an EPA program which has not been delegated to the state. DAQ authority is
included in the Title V permit.

IV.I Effect on Other Authorities.

No provision of the Acid Rain Program, an Acid Rain permit application, an Acid
Rain permit, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as:

IV.I.1 Except as expressly provided in Title IV of the Act, exempting or excluding the
owners and operators and, to the extent applicable, the designated representative from
compliance with any other provision of the Act, including the provisions of Title I of
the Act relating to applicable National Ambient Air Quality Standards or the Utah
State Implementation Plan;

IV.I.2 Limiting the number of allowances, a unit can hold; provided, that the number of
allowances held by the unit shall not affect the source's obligation to comply with any
other provisions of the Act;

IV.I.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, including any prudence review requirements under such State law;

IV.I.4 Modifying the Federal Power Act or affecting the authority of the Federal Energy
Regulatory Commission under the Federal Power Act; or,

IV.I.5 Interfering with or impairing any program for competitive bidding for power supply in
a State in which such program is established.

Status: This is a statement of fact.

35
EMISSIONS INVENTORY: Taken form DAQ’s emissions inventory database for 2022:

PREVIOUS ENFORCEMENT
ACTIONS: No violations issued in the past 5 years

COMPLIANCE STATUS &
RECOMMENDATIONS: UAMPS Nebo Power Plant should be found in compliance with
the Title V Permit conditions evaluated during this inspection.
No further action is recommended.

HPV STATUS: Not applicable

COMPLIANCE ASSISTANCE: None requested

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual

ATTACHMENT: VEO sheet, semi-annual monitoring report, and certified mail
receipt