DAQ-2025-002600

1
DAQC-CI108190001-25
Site ID 10819 (B1)

MEMORANDUM

TO: FILE – SPRINGVILLE CITY CORPORATION – Whitehead Power Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: May 5, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: April 3, 2025

SOURCE LOCATION: 450 West 700 North
Springville, UT 84663
SOURCE CONTACTS: Shawn Black, Superintendent
801-420-1607, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Springville City Power operates a peak shaving plant that
generates electricity for the Utah Associated Municipal Power
System (UAMPS) grid consisting of seven engines. Engines K-1
and K-2 have CleanBurn Technology and can operate on both
diesel fuel and natural gas. Engines K-3, K-4, K-5, K-6, and K-7
are four-stroke, lean burn, natural gas-fired engines. Diesel fuel
is brought to the facility by tanker truck and off-loaded into the
facility's three, 20,000-gallon fuel storage tanks. The diesel fuel
from these tanks is transferred to a 1,100-gallon day tank. In the
day tank, the diesel is allowed to sit for a period of time, so that
impurities can settle out of the fuel. Natural gas is fed directly to
each engine from the gas company.

All engines remain on hot stand-by until ordered into service by
the UAMPS grid dispatch office in Sandy, Utah. At start-up,
compressed air, generated by the plant's single electric
compressor, is used to turn the pistons in each engine. Each
engine powers an electric generator, which produces the
electricity. The electricity flows into the UAMPS grid and is
carried to customers throughout the system. All engines are
water-cooled. Water is circulated around the piston jackets of
each engine, absorbing excess heat. The heated water is then
pumped to each engine's cooling tower. Inside each tower, the
heat is transferred via heat exchanger to the ambient air. There
are no emissions associated with the cooling towers. Combustion
emissions are vented to ambient through each engine's
40"-diameter stack approximately 61' above ground level.
) $ ' $ '
2
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN108190010-25, dated January
28, 2025
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines,
NESHAP (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Springville City Corporation- Whitehead Power
Plant

450 West 600 North 450 West 700 North
Springville, UT 84663 Springville, UT 84663

SIC Code: 4911: (Electric Services)

Section I: GENERAL PROVISIONS

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

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

3
I.7 The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and
Monitoring. [R307-150]

Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available during the
inspection. No breakdowns have been reported since the previous inspection. An emissions
inventory was submitted for 2024, and emissions data are reported below.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Springville City Corporation White Head Power Plant
II.A.2 B-1 Boiler Fuel: Natural gas Rating: 6.0 MMBtu/hr
II.A.3 Engines K-1 and K-2 Enterprise DGSRV-16-4 engine generators Fuel: Dual fuel (diesel and natural gas) Rating: 5.5 MW/hr
II.A.4 K-3 through K-7 Engine Type: Four (4) stroke lean burn Fuel: Natural gas Control: SCR and oxidation catalyst Rating: 3422 hp
II.A.5 Cooling Towers
Status: In Compliance. No unapproved equipment was observed at the time of inspection. The boiler is associated with operations at Springville City's sewage treatment plant.

II.B Requirements and Limitations
II.B.1 Site-Wide Requirements II.B.1.a Visible emissions from any point or stationary fugitive emission source associated with the installation or control facilities shall not exceed 10% opacity, with the exception of an initial start-up period of 15 minutes. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. Method 9 was utilized to verify opacity limits. See attached VEO form. II.B.1.b The owner/operator shall use the specified fuel mixtures as a primary fuel in the following equipment: A. No less than 99% natural gas in the K-1 and K-2 engine/generators, except during a period of 30 minutes for start-up or shutdown B. Natural gas 100% of the time in the 6.0 MMBTU/hr boiler
4
C. Natural gas 100% of the time in the K-3 through K-7 engine/generators The engine/generators (K-1 and K-2) may be operated using diesel fuel only during the initial startup mode, shutdown mode or during natural gas curtailment. Hours of operation during natural gas curtailment shall be limited to 72 hours per calendar year. The owner/operator shall notify the Director within 24 hours of natural gas being curtailed, the reason for the curtailment, and the expected length of the curtailment. [R307-401, R307-401-8] Status: In Compliance. The source is familiar with the requirements of this condition and confirmed they operate accordingly. The source stated that curtailments are rare and typically only happen in winter months. They reported no curtailments in the past year. II.B.1.c Stack testing to demonstrate compliance with daily and rolling 12-month emission limitations shall be performed in accordance with the following: A. Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing methods acceptable to the Director. Occupational Safety and Health Administration (OSHA) approvable access shall be provided to the test location. B. Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. C. NOx: 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing methods acceptable to the Director. D. CO: 40 CFR 60 Appendix A, Method 10, 10B, or other EPA-approved testing methods acceptable to the Director. E. Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors to give the results in the specified units of the emission limitation. A stack test protocol shall be provided at least 30 days prior to the test. A pretest conference shall be held if directed by the Director. F. The production rate during all compliance testing shall be no less than 90% of the maximum production rate achieved in the previous three (3) years. If the desired production rate is not achieved at the time of the test, the maximum production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. The owner/operator shall request a higher production rate when necessary. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum allowable production rate is achieved. G. Stack testing on each internal combustion engine shall be performed once every 8,760 hours of operation of that engine, but no less frequently than once every three (3) years, whichever condition is met first. [40 CFR 60 Subpart JJJJ, R307-165] Status: In Compliance. A review of the source file indicates stack testing is conducted in accordance with all requirements of this condition. Stack testing for K-1 and K-2 was conducted October 17, 2024. Refer to DAQC-070-24 for more details. Stack testing for K-3, K-4, K-5, K-6, and K-7 was conducted October 14-16, 2024. Refer to DAQC-073-25 for more details.

5
II.B.2 K-1, K-2, K-3, K-4, K-5, K-6, and K-7 Engine Requirements II.B.2.a Emissions to the atmosphere from the engine generators K-1 and K-2 shall each not exceed the following rates and concentrations: NOx 18.01 lb/hr CO 2.5 lb/hr Emissions to the atmosphere from the engine generators K-3 through K-7 shall each not exceed the following rates and concentrations: NOx 0.07 g/hp-hr CO 0.108 g/hp-hr Stack testing to show compliance with the above emission limitations shall be performed as outlined in condition II.B.1.c. [R307-165, R307-401-8] Status: In Compliance. Emissions results are as follows: K-1 NOx - 12.723 lb/hr K-1 CO - 0.270 lb/hr K-2 NOx - 8.634 lb/hr K-2 CO - 0.462 lb/hr See DAQC-070-25 for more details. K-3 NOx - 0.037 g/hp-hr K-3 CO - 0.071 g/hp-hr K-4 NOx - 0.049 g/hp-hr K-4 CO - 0.069 g/hp-hr K-5 NOx - 0.052 g/hp-hr K-5 CO - 0.065 g/hp-hr K-6 NOx - 0.016 g/hp-hr K-6 CO - 0.068 g/hp-hr K-7 NOx - 0.033 g/hp-hr K-7 CO - 0.080 g/hp-hr See DAQC-073-25 for more details. II.B.2.b NOx emissions from the operation of all engines and boilers at the plant shall not exceed 1.68 tons per day and 45.4 tons per rolling 12-month period. CO emissions from the operation of all engines and boilers at the plant shall not exceed 1.15 tons per day and 18.5 tons per rolling 12-month period. Stack testing to show compliance with the above emission limitations shall be performed as outlined in condition II.B.1.c. [R307-165, R307-401-8] Status: In Compliance. See the attached summary table for all seven engines. For the rolling 12-month period from March 2024 - February 2025, a total 7.05 tons of NOx and 0.41 tons of CO emissions were reported. No individual day exceeded the limits of this condition. See the attached tables and email correspondence for more information. II.B.2.c Internal combustion engine emissions shall be calculated using the emission factors generated from the most recent stack test. Emissions totals from all engines shall be kept in table format, listing month, operating hours, and emissions, for each individual engine. Stack testing shall be performed as outlined in condition II.B.1.c.
6
A day is equivalent to the time period from midnight to the following midnight. Emissions shall be calculated for NOx and CO for each individual engine with the following equations: Daily Rate Calculation: D = (X * H) Where: X = lb/hr rate for each generator (based on the most recent stack test for that generator) H = total hours of operation for that generator each day (recorded by hour meter) D = daily output of pollutant in lbs/day Monthly Rate Calculation: The emissions (lb/hr) for each pollutant shall be calculated by summing the daily emissions for each month. Annual Rate Calculation: The annual emissions shall be calculated by summing the emissions from each of the previous 12-months. The lb per rolling 12-month rate shall be divided by 2000 pounds per ton to calculate tons per rolling 12-month period emissions. The rolling 12-month total shall be calculated by the twentieth day of each month. [R307-170, R307-401-8] Status: In Compliance. All operating parameters for the generators are tracked in the SCADA program and stack testing is conducted in accordance with the requirements of condition II.B.1.c. II.B.2.d The sulfur content of any diesel burned shall not exceed 15 ppm by weight for fuels used in the dual fuel engines. The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent. Certification of diesel fuel sulfur content shall be either by Springville City's own testing or test reports from the fuel marketer. [R307-401] Status: In Compliance. Only ULSD is used at this site. See the attached invoice from Rhinehart Oil. II.B.2.e The stack heights of each engine (K-1 through K-7) shall be no less than 60 feet, as measured from ground level. [R307-410] Status: In Compliance. The stack heights for engines K-1 and K-2 are 61.3 ft. The stack heights for engines K-3, K-4, K-5, K-6, and K-7 are 60 ft. II.B.3 Boiler Requirements II.B.3.a The boiler shall not exceed 5,000 hours of operation per rolling 12-month period. [R307-401] II.B.3.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of operation shall be kept for all periods when the plant is in operation. An hour meter shall determine hours of operation. [R307-401] Status: In Compliance. For the rolling 12-month period from March 2024 - February 2025, the boiler was operated for 2,224.9 hours. See the attached table below for more information.

7
Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Status: In Compliance. Compliance with this subpart is satisfied by installing a certified engine,
maintaining and operating the engines in accordance with the manufacturer's instructions, installation
of a non-resettable hour meter, and maintaining records of use. All information provided at the time of
inspection indicate these engines are being properly maintained and operated in accordance with this
subpart. Stack testing is performed every three years as required.
NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines.

Status: In Compliance. Stationary RICE located at area sources of HAP emissions must comply with
Table 2d to subpart ZZZZ of MACT (Part 63), which requires annual maintenance of hoses, oil, belts,
and filters, and the use of ULSD fuel. Engines K-1 and K-2 are run primarily on natural gas, but use
diesel for periods of start-up or shutdown. All other engines are only run on natural gas. Maintenance is
performed as required by this federal subpart.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. Only ULSD is used at this site. See the attached invoice from Rhinehart Oil.

Stationary Sources [R307-210]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirements NSPS (Part 60) Subpart JJJJ. See Section III above for more information.
National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subpart ZZZZ. See Section III above for more information.

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible emissions were observed from any point at the time of inspection.
See attached VEO Form for additional information.

8
EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Springville City Corporation - Whitehead
Power Plant for the 2024 emissions reporting year. A comparison of the estimated total potential
emissions (PTE) on AO: DAQE-AN108190010-25, dated January 28, 2025, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 60262.00 N/A
Carbon Monoxide 18.43 0.4615
Nitrogen Oxides 45.40 2.11342
Particulate Matter - PM10 4.19 1.07955
Particulate Matter - PM2.5 4.19 0.53431
Sulfur Dioxide 0.24 0.03562
Volatile Organic Compounds 26.37 4.25678

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 17320 0.04
Generic HAPs (CAS #GHAPS) 7800 N/A

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN108190010-25,
dated January 28, 2025, the overall status is: In Compliance. The
facility is well-maintained and operated. Records were provided
at the time of inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at typical frequency for this type of source.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO form, email correspondence, emissions tables, ULSD
verification