DAQ-2025-004715

DAQE-GN157360005-25

{{$d1 }}

Collon Kennedy
Global Carbon Strategies Corporation
1524 East 8th Avenue
Denver, CO 80218
[e-mail]

Dear Collon Kennedy:

RE: Replacement of an Identical Engine
Project Number: N157360005

The Utah Division of Air Quality (DAQ) received your request on July 22, 2025, requesting an
administrative amendment to replace an identical engine. The DAQ reviewed the request and found that
the current Approval Order (AO) DAQE-AN157630003-18, dated September 19, 2018, will not be
affected as a result of the replacement. The DAQ, therefore, has determined that a new AO is
unnecessary. Global Carbon Strategies Corporation shall continue to comply with the terms and
conditions contained in the above-mentioned AO.

As authorized by the Utah Legislature, the fee for reviewing your request and issuing this letter is the
actual time spent by the review engineer and all other staff on the project. Payment should be sent to the
DAQ upon receipt of the invoice.

If you have any questions, please contact Enqiang He, who can be reached at [phone] or
[e-mail].

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:EH:jg

cc: EPA Region 8
Salt Lake County Health Department
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

September 16, 2025

1/2

Date: July 22, 2025

Ramboll Americas Engineering
Solutions, Inc.

257 E 200 S
Suite 550
Salt Lake City, UT
84111
https://ramboll.com

REPLACEMENT‐IN‐KIND NOTICE 
Subject Global Carbon Strategies Corporation: Replacement-in-Kind of
Generator Engine
Date July 22, 2025
To Alan Humpherys UDAQ
From Collon Kennedy, Global Carbon Strategies Corporation
Megan Neiderhiser, Ramboll

Dear Mr. Humpherys,
Ramboll Americas Engineering Solutions, Inc. (“Ramboll”) has prepared
this notification to the Utah Division of Air Quality (“UDAQ”) pursuant to
Utah Administrative Code (“UAC”) R307-401-11(2)(a) on behalf of Global
Carbon Strategies Corporation (“GCS”). GCS intends to replace their
existing 9 kW propane-fired generator engine with an identical generator
engine.
GCS operates a methane emissions reduction project at the West Ridge
Mine in Carbon County, Utah. The facility consists of an enclosed ground
flare system, four degasification engines, a propane generator and
propane storage tanks. The existing generator engine is permitted to
operate under condition II.A.7 of Approval Order DAQE-AN157360003-18,
dated September 19, 2018. The permitted equipment is a Generac
Guardian Series Residential Standby Generator with a 9 kW 60 Hz
propane-fired engine.
GCS intends to replace the existing generator engine with an identical
model or to replace major parts of the existing generator engine with
components taken from the new generator engine. GCS is not proposing to modify any operating limits
of the replaced equipment. The specification sheet applicable for both the existing and replacement
generator engine are provided in Attachment A.
The propane generator together with a larger degasification engine (No. 614 under Approval Order
condition II.A.6) retrofitted with a generator are the key components of the site’s uninterruptible power
supply (“UPS”). The UPS provides power for automation of the flare, computers and other equipment
in the control shed, the remote monitoring and security systems as well as recharges a bank of
batteries. The propane generator is efficient and provides lower emissions than the larger degasification
engine during the site’s permitted flaring operations.
According to UAC R307-401-11 (Replacement-in-Kind Equipment), existing process equipment that is
covered by an existing approval order may be replaced using these procedures if the replacement
equipment meets conditions (a) through (h) of UAC R307-401-11(1). GCS intends to replace the
existing generator with the same make and model or to replace major parts of the existing generator
engine with parts from the new generator engine. Both options meet the requirements in R307-401-
11(1)(a) through (h) as indicated in blue italics:
(a) the potential to emit of the process equipment is the same or lower;
 The replaced equipment will meet the emissions standards from the existing equipment
based on Generac certification data submitted to the EPA, and the operating limits will not
change. The potential to emit will be equivalent.
(b) the number of emission points or emitting units is the same or lower;

2/2

 The replaced equipment will have the same number of emissions points (1) and emissions
units (1) as the existing equipment.
(c) no additional types of air pollutants are emitted as a result of the replacement;
 The replaced and existing equipment will have the same type of air pollutants resulting from
propane combustion.
(d) the process equipment or pollution control equipment is identical to or functionally equivalent to
the replaced equipment;
 The replaced and existing equipment are identical in engine model and function.
(e) the replacement does not change the basic design parameters of the process unit or pollution
control equipment;
 The replaced and existing equipment are identical in engine model and design parameters.
(f) the replaced process equipment or pollution control equipment is permanently removed from
the stationary source, otherwise permanently disabled, or permanently barred from operation;
 The existing equipment will be removed or replaced entirely by the new equipment or parts.
(g) the replacement process equipment or pollution control equipment does not trigger New Source
Performance Standards or National Emissions Standards for Hazardous Air Pollutants under 42
U.S.C. 7411 or 7412; and
 The replaced equipment will be subject to the same federal requirements as the existing
equipment: New Source Performance Standards Subpart JJJJ and National Emissions
Standards for Hazardous Air Pollutants Subpart ZZZZ.
(h) the replacement of the control apparatus or process equipment does not violate any other
requirement of Title R307.
 The replaced equipment will continue to meet the requirements of Title R307 as reviewed
when the Approval Order was issued for the existing identical equipment.

Thank you for reviewing GCS’s replacement-in-kind request. Please do not hesitate to contact myself or
Collon Kennedy ([e-mail]) with any questions, and please inform GCS at your earliest
convenience once the request has been reviewed.
Sincerely,

Megan Neiderhiser, PE
Principal
D [phone]
M [phone]
[e-mail]

3/2

ATTACHMENT A
GENERATOR ENGINE SPECIFICATION SHEET
ISO9001:2008
GENERAС