DAQ-2024-007324

State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-301-24
Site ID 12495 (B5)

Jerame Blevins, Plant Manager
West Valley Power
5935 West 4700 South
West Valley City, UT 84118

Dear Mr. Blevins:

Re: West Valley Power – Pretest Protocol for Carbon Monoxide (CO), Flow, Nitrogen
Oxides (NOx), and Oxygen (O2) Relative Accuracy Test – Salt Lake County

The Utah Division of Air Quality (DAQ) reviewed West Valley Power’s pretest protocol dated
March 18, 2024. The proposed test shall be performed under the following conditions:

West Valley Power’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Unit 1
CO Thermo 48iQ 1200696554
NOx Thermo 42iQLS 1200696549
O2 Thermo 48iQ 1200696554
Unit 2
CO Thermo 48iQ 1200696555
NOx Thermo 42iQLS 1200696550
O2 Thermo 48iQ 1200696555
Unit 3
CO Thermo 48iQ 1200696556
NOx Thermo 42iQLS 1200696551
O2 Thermo 48iQ 1200696556
Unit 4
CO Thermo 48iQ 1200696557
NOx Thermo 42iQLS 1200696552
O2 Thermo 48iQ 1200696557
Unit 5
CO Thermo 48iQ 1200696558
NOx Thermo 42iQLS 1200696553
O2 Thermo 48iQ 1200696558

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DAQC-301-24
Page 2

Alliance Technical Group will conduct a relative accuracy/performance specification test on
West Valley Power’s continuous monitoring system.

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour.

The DAQ understands that testing will be conducted as follows:

Test Date Point
Source Parameter EPA Reference Method
June 17, 2024 Unit 1
CO, CO2, Flow,
H2O, NOx, and O2 Method 1, 3A, 7E, 10, and 19
June 18, 2024 Unit 2
June 19, 2024 Unit 3
June 20, 2024 Unit 4
June 21, 2024 Unit 5

• Reference Method 1 – Sample and Velocity Traverses for Stationary Point
Sources as outlined in 40 CFR 60 Appendix A shall be used to determine the
location and number of sampling points as applicable.

• Reference Method 3A – Determination of Oxygen and Carbon Dioxide
Concentrations in Emissions from Stationary Point Sources – (Instrumental
Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 7E – Determination of Nitrogen Oxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.

• Reference Method 10 – Determination of Carbon Monoxide Emissions from
Stationary Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR
60 Appendix A.

• Reference Method 19 – Determination of Sulfur Dioxide Removal Efficiency and
Particulate Matter, Sulfur Dioxide, and Nitrogen Oxides Emission Rates as
outlined in 40 CFR 60 Appendix A.

• Reference Method 205 – Verification of Gas Dilution Systems for Field
Instrument Calibrations).

• Deviations – The Director or the representative of the Director must be notified of
and approve deviations of the Reference Method test. Any deviation from these
conditions without approval from the DAQ may constitute rejection of these tests.

DAQC-301-24
Page 3

Acceptance of a protocol does not relieve the owner/operator and the testing contractor
from strict adherence to all applicable EPA methods, DAQ policies, Utah Air Quality
Rules (UAQR), and methods approved by the Director. Any deviation from EPA
methods, DAQ policies, UAQR, and methods approved by the Director must be
addressed separately and express written consent given prior to commencement of
testing.

• Field data (Point Source emission data and test data) shall be turned over to the
DAQ in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system
based on Point Source continuous emission monitoring data and test data acquired
by the staff member of the DAQ during the test.

• All test reports must be submitted to the Director no later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with
date and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and
maintained process conditions representative of normal operations, and operated
under such other relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements
and information contained in the report are true, accurate, and complete.

DAQC-301-24
Page 4

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

HB:RL: jl

cc: Salt Lake County Health Department
Alliance Technical Group
* $ . # ( ) - — - A E v A ? A C @ @ w @ B ˜
Rob Leishman Jr