### Department of Environmental Quality

Amanda Smith

Executive Director

DIVISION OF AIR QUALITY Cheryl Heying

Director 10795



## State of Utah

GARY R. HERBERT

Governor

GREG BELL

Lieutenant Governor



## Title V Operating Permit

PERMIT NUMBER: 4900018003

DATE OF PERMIT: October 28, 2009 Date of Last Revision: October 28, 2009

This Operating Permit is issued to, and applies to the following:

Name of Permittee:

Provo City Power Department of Energy

251 West 800 North

Provo UT 84601 Permitted Location:

Provo City Power: Power Plant

702 North 300 West

Provo UT 84601

UTM coordinates: 443,455 m Easting, 4,454,710 m Northing SIC code: 4911 (Electric Services)

UTAH AIR QUALITY BOARD

By: Prepared By:

_________________________________ _____________________________ M. Cheryl Heying, Executive Secretary Robert Grandy

150 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414

www.deq.utah.gov
Printed on 100% recycled paper

## ENFORCEABLE DATES AND TIMELINES

The following dates or timeframes are referenced in Section I: General Provisions of this permit.

Annual Certification Due: March 31, and on that date of every calendar year that this permit

is in force.

Renewal application due: April 28, 2014

Permit expiration date: October 28, 2014

Definition of “prompt”: written notification within 14 days.



## ABSTRACT

The Provo Downtown Power Plant is located in Provo, Utah County, Utah. The plant has five electric generators. Four dual fuel internal combustion engin es and two natural gas boilers are used to power the generators. Each engine and boiler has a separate stack for the exhaust emissions.

All generation units are best economic resource units for the Utah Municipal Power Agency (UMPA). The power production of the plant varies depending on weather conditions, rainfall, and economics of operation. An emergency generator has been installed to provide backup pow er to the iProvo headend facility. The Provo Downtown Power Plant is a major source of NO

x and is subject to the Utah State Implementation Plan (SIP) IX.H.3.d.

Project OPP0107950007 Page 2 Titl e V Operating Permit #4900018003

## OPERATING PERMIT HISTORY

Permit/Activity Date Issued Recorded Changes

Title V renewal application (Project #OPP0107950007) Additions:

-Renewal

-Updated the Utah SIP citation (from IX.H.1.b.D to IX.H.3.d.)

-Added maintenance condition from R307-401-8(2).

Title V administrative amendment by DAQ (Project #OPP0107950005) 2/22/2005 Changes: to incorpor ate conditions from new approval order issued to Provo City Power for new emergency

generator.

Title V renewal application (Project #OPP0107950004) 5/22/2003

Title V reopening for cause by DAQ (Project #OPP0107950003) 7/14/1998 Changes: to modify Provision I.U.1 of the permit to reference the inventory rule directly.

Title V administrative amendment by DAQ (Project #OPP0107950002) 8/8/1997 Changes: The permit was modified to correct an error in

the abstract and to corr ect the initial compliance

certification date to 3/31/98.

Title V initial application (Project #OPP0107950001) 6/3/1997

Project OPP0107950007 Page 3 Titl e V Operating Permit #4900018003

## Table of Contents

ENFORCEABLE DATES AND TIMELINES .............................................................................................. 2

ABSTRACT ...................................................................................................................................................... 2

OPERATING PERMIT HISTORY ................................................................................................................ 3

SECTION I: GENERAL PROVISIONS ........................................................................................................ 5

Federal Enforcement. ..................................................................................................................................... 5 Permitted Activity(ies). .................................................................................................................................. 5 Duty to Comply.............................................................................................................................................. 5 Permit Expiration and Renewal...................................................................................................................... 6 Application Shield. ......................................................................................................................................... 6 Severability. ................................................................................................................................................... 6

Permit Fee. ..................................................................................................................................................... 6 No Property Rights. ........................................................................................................................................ 6 Revision Exception. ....................................................................................................................................... 6 Inspection and Entry. ..................................................................................................................................... 6

Certification. ................................................................................................................................................... 7 Compliance Certification. .............................................................................................................................. 7

Permit Shield. ................................................................................................................................................. 8 Emergency Provision. .................................................................................................................................... 8 Operational Flexibility. .................................................................................................................................. 9 Off-permit Changes. ....................................................................................................................................... 9

Administrative Permit Amendments. ............................................................................................................. 9

Permit Modifications. ..................................................................................................................................... 9 Records and Reporting. .................................................................................................................................. 9 Reopening for Cause.

............................................................................................................................... .... 11 Inventory Requirements. .............................................................................................................................. 1 1 Title IV and Other, More Stringent Requirements ....................................................................................... 11

SECTION II: SPECIAL PROVISIONS ....................................................................................................... 12

Emission Unit(s) Permitted to Discharge Air Contaminants. ...................................................................... 12 Requirements and Limitations ..................................................................................................................... 12 Conditions on permitted source (Source-wide). ....................................................................................................... 12 Conditions on Dual Fuel Internal Combustion Engines. .......................................................................................... 14

Conditions on Natural Gas Fired Boilers. ................................................................................................................ 17 Conditions on Emergency Generator....................................................................................................................... 19 Emissions Trading

............................................................................................................................... ......... 20 Alternative Operating Scenarios .................................................................................................................. 20

SECTION III: PERMIT SHIELD ................................................................................................................ 20

SECTION IV: ACID RAIN PROVISIONS ................................................................................................. 20

This source is not subject to Title IV. This section is not applicable. .......................................................... 20

REVIEWER COMMENTS ........................................................................................................................... 21

Project OPP0107950007 Page 4 Titl e V Operating Permit #4900018003Issued under authority of Utah Code Ann. Section 19- 2-104 and 19-2-109. 1, and in accordance with Utah Administrative Code R307-415 Operating Permit Requirements.

All definitions, terms and abbreviations used in this pe rmit conform to those used in Utah Administrative Code R307-101 and R307-415 (Rules), and 40 Code of Federal Re gulations (CFR), except as otherwise defined in this permit. Unless noted otherwise, references cited in the permit conditions refer to the Rules.

Where a permit condition in Section I, General Provisions, pa rtially recites or summarize s an applicable rule, the full text of the applicable portion of the rule shall govern interpretations of the requirements of the rule. In the case of a conflict between the Rules and the permit terms and conditions of Section II, Special Provisions, the permit terms and conditions of Secti on II shall govern except as noted in Provision I.M, Permit Shield.



## 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 th at are specifically designated as "State Requirements". (R307-415-6b)

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)

I.C Duty to Comply.

I.C.1 The permittee must comply with all c onditions 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 re newal 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 perm it. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Execu tive Secretary, within a reasonable time, any information that the Executive Secretary 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 Executive Secretary 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))

I.C.4 This permit may be modified, revoked, re opened, 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 notif ication of planned changes or anticipated noncompliance shall not stay any permit condition, except as pr ovided under R307-415- 7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Project OPP0107950007 Page 5 Titl e V Operating Permit #4900018003I.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 fr ont of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this perm it 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 reas on. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted afte r the due date listed in I.D.2 above shall be accepted for processing, but shall not be consid ered 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 permitte e's right to operate unless a timely and complete renewal application is submitte d 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))

I.E Application Shield.

If the permittee submits a timely and comple te application for renewal, the permittee's failure to have an operating permit will not be a violation of R307-415, until the Executive Secretary takes final action on the permit renewa l 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 Executive Secretary any additional information identified as being needed to process the application. (R307-415-7b(2))

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 re main valid and in force. (R307-415-6a(5))

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Executive Secretary 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))

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))

I.I Revision Exception.

No permit revision shall be required, unde r 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))

I.J Inspection and Entry.

Project OPP0107950007 Page 6 Titl e V Operating Permit #4900018003I.J.1 Upon presentation of credentials and ot her documents as may be required by law, the permittee shall allow the Executive Secretary 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 unde r 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 perm it. (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 regul ated 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 appli cable 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))

I.K Certification.

Any application form, report, or complian ce 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 certif ication 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)

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Executive Secretary an annual compliance certification, certifying compliance with the terms and cond itions contained in this permit, including emission limitations, standards, or work prac tices. 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-re ference 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 othe r means used by the permittee for determining the compliance status with each term and cond ition during the certification period. Such methods and other means shall include, at a minimum, the monitoring and related recordkeeping and reporting requirements in th is 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

Project OPP0107950007 Page 7 Titl e V Operating Permit #4900018003Provision 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 Executive Secret ary may require to determine the compliance status.

I.L.2 The permittee shall also submit all complia nce certifications to the EPA, Region VIII, at the following address or to such other address as ma y be required by the Executive Secretary: (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

I.M Permit Shield.

I.M.1 Compliance with the provisions of th is permit shall be deemed compliance with any applicable requirements as of the da te 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 Executive Secretary 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))

I.N Emergency Provision.

I.N.1 An "emergency" is any situation aris ing 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 operati on, and that causes the source to exceed a technology-based emission limitation under th is permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equi pment, lack of preventive maintenance, careless or improper operation, or operator error. (R307-415-6g(1))

Project OPP0107950007 Page 8 Titl e V Operating Permit #4900018003I.N.2 An emergency constitutes an affirmativ e defense to an action brought for noncompliance with such technology-based emission limitations if the affirmative defense is demonstrated through properly signed, contemporaneous opera ting 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 tim e 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 emissi on standards, or other requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the em ergency to the Executive Secretary 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 pe rmittee 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))

I.O Operational Flexibility.

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

I.P Off-permit Changes.

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

I.Q Administrative Permit Amendments.

Administrative permit amendmen ts are governed by R307-415-7e.

I.R Permit Modifications.

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

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. Su pport 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 describe d in Section II, Special Provisions, the source shall record the following information, where applicable: (R307-415-6a(3)(b)(i))

Project OPP0107950007 Page 9 Titl e V Operating Permit #4900018003I.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 entit y 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 Executive Secretary 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 Executive Secretary shall be no tified promptly of any deviations from permit requirements including those attributable to up set 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, sh all 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 una voidable breakdowns shall be reported in accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submi ssions required by this permit to be submitted to the Executive Secretary are to be sent to the follo wing address or to such other address as may be required by the Executive Secretary:

Utah Division of Air Quality

P.O. Box 144820 Salt Lake City, UT 84114-4820

Phone: 801-536-4000

I.S.3.b All reports, notifications or other submis sions 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 Executive Secretary:

For annual compliance certifications:

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

Project OPP0107950007 Page 10 Ti tle V Operating Permit #4900018003Denver, CO 80202-1129

For reports, notifications, or other corr espondence related to permit modifications, applications, etc.:

Environmental Protection Agency, Region VIII Office of Partnerships & Regulatory Assistan ce Air & Radiation Program (mail code 8PAR)

1595 Wynkoop Street Denver, CO 80202-1129

Phone: 303-312-6440

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 app licable 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 whic h this permit is due to expire, unless the terms and conditions of this permit have been exte nded pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Executive Secretary or EPA determines that this permit contains a material mistake or

that inaccurate statements were made in estab lishing the emissions standards or other terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Executive Secretary 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 existi ng 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 pro cedures as apply to initial permit issuance and shall affect only those pa rts of this permit for which cause to reopen exists. (R307-415-7g(2))

I.U Inventory Requirements.

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

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))

Project OPP0107950007 Page 11 Ti tle V Operating Permit #4900018003

## 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 Natural Gas Fired Boilers Two (2) 9,200 kW boilers

II.A.3 Dual Fuel Internal Combustion Engines Includes four (4) 2,585 kW engines

II.A.4 Miscellaneous Emission Units Includes the following units: natural gas fired boiler (3.4 MMBtu/hr), two portable kerosene heaters (0.1 MMBtu/hr each), underground diesel storage tank (50,000 gallons), four diesel day tanks, diesel fuel pumps, three stoddard solvent parts washers No unit-specific applicable requirements.

II.A.5 Emergency Generator Small diesel fuel generator for iProvo Headend facility.

II.B Requirements and Limitations

The following emission limitations, standards, and op erational 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 pl ant equipment, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable ope rating and maintenance procedures are being used

will be based on information available to the Execu tive Secretary which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [Authority granted unde r R307-401-8(2); condition originated in DAQEAN0795006-04].

II.B.1.a.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Records documenting scheduled and unscheduled main tenance shall be maintained. A copy of all manufacturers' instructions, established operati ng instructions, or established maintenance practices for pollution control equipment and pollution emitting equipment shall be made available upon request.

Project OPP0107950007 Page 12 Ti tle V Operating Permit #4900018003II.B.1.a.3 Reporting:

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

II.B.1.b Condition:

Emissions of NO

x shall be no greater than 254 tons per rolling 12-month period for Unit Engines and Unit Boilers combined. [Authority granted under Utah SI P IX.H.3.d and R307-401- 8(1)(a) [BACT]; condition originated in DAQE-AN0795006-04].

II.B.1.b.1 Monitoring:

Compliance with the emission limitation shall be determined by the following equation:

Emissions (tons/rolling 12-month period) = (P ower production in kW-hrs/rolling 12-month period) x (Emission factor in grams/kW-hr) x (1 lb/453.59 g) x (1ton/2000 lbs)

The emission factors for NO

x shall be derived from the most recent emission test results. Emission testing frequency shall follow schedule found in Conditions II.B.2.a and II.B.3.a.

NO

x emissions shall be the sum of emissions fro m each engine and boiler. Power production shall be determined on a rolling 12-month total. Within the first 10 days of each month a new 12- month total shall be calculated using da ta from the previous 12 months.

II.B.1.b.2 Recordkeeping:

The number of kilowatt hours generated by each en gine and boiler shall be recorded on a monthly

basis.

Results shall be maintained in accordance w ith Provision I.S.1 of this permit.

II.B.1.b.3 Reporting:

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

II.B.1.c Condition:

Emissions of NO

x shall be no greater than 2.45 tons per day for Unit Engines and Unit Boilers combined. [Authority granted under Utah SIP IX.H.3.d and R3 07-401-8(1)(a) [BACT]; condition originated in DAQE-AN0795006-04].

II.B.1.c.1 Monitoring:

Compliance with the emission limitation shall be determined by the following equation:

Emissions (tons/day) = (Power production in kW-hrs/day) x (Emission factor in grams/kW-hr) x (1 lb/453.59 g) x (1 ton/2000 lbs)

The emission factors for NO

x shall be derived from the most recent emission test results. Emission testing frequency shall follow schedule found in Conditions II.B.2.a and II.B.3.a.

NO

x emissions shall be the sum of emissions from each engine and boiler. Power production and

Project OPP0107950007 Page 13 Ti tle V Operating Permit #4900018003emissions from each engine and boile r shall be determined daily.

II.B.1.c.2 Recordkeeping:

The number of kilowatt hours generated by each en gine and boiler shall be recorded on a daily

basis.

Results shall be maintained in accordance w ith Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

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

II.B.1.d Condition:

If plantwide NO

x emissions from the engines exceed 200 tons per rolling 12-month period, the permittee shall submit a plan to install continuous emission monitoring systems (CEM) for Nox on each stack. The plan shall propose specifications for the installa tion, calibration and maintenance of a CEM. The CEM shall be on line within 12 months following the a pproval of the plan. [Authority granted under R307-401- 8(1)(a) (BACT); condition originated in DAQE-AN0795006-04].

II.B.1.d.1 Monitoring:

NO

x emissions shall be determined by the following equation:

Emissions (tons/rolling 12-month period) = (P ower production in kW-hrs/rolling 12-month period) x (Emission factor in grams/kW-hr) x (1 lb/453.59 g) x (1 ton/2000 lbs)

The number of kilowatt hours generated by each en gine and boiler shall be recorded on a monthly

basis. The emission factors for NO

x shall be derived from the most recent emission test results.

NO

x emissions shall be the sum of emissions from each engine and boiler. Each month, a new 12- month total shall be calculated using da ta from the previous 12 months.

II.B.1.d.2 Recordkeeping:

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

II.B.1.d.3 Reporting:

The permittee shall submit a report of the emissions to the Executive Secretary within 30 days of determining that NO

x emissions exceeded 200 tons over the previous 12 months. Within 90 days of such determination, the permittee shall submit to the Executive Secretary for approval of the CEM installation plan.

II.B.2 Conditions on Dual Fuel Internal Combustion Engines.

II.B.2.a Condition:

Emissions of NO

x shall be no greater than 10.4 g/kW-hr and 1,660 ppmdv for each engine. [Authoritygranted under Utah SIP IX.H.3.d and R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0795006-04].

Project OPP0107950007 Page 14 Ti tle V Operating Permit #4900018003II.B.2.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. The engine shall be tested every 8,760 hours of operation and/or at least every five years based on the date of the last stack test.

(b) Notification. At least 30 days before the t est, 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.

(c) The emission sample point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1. In addition, Occupationa l Safety and Health Administration (OSHA) approved access shall be provided to the test location. (R307-165-2)

(d) Methods to be used:

(1) To determine stack volumetric flow rate - 40 CFR 60, Appendix A, Method 2.

(2) To test for NO

x emissions - 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D,

or 7E.

(e) Calculations. To determine mass emission ra tes (g/kW-hr) the pollutant concentration as determined by the appropriate methods above sh all be multiplied by the volumetric flow rate, divided by the engine's power output during th e test and multiplied by any necessary conversion

factors.

(f) 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. (R307-165- 3).

II.B.2.a.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance w ith the associated test method and Provision S.1 in Section I of this permit.

II.B.2.a.3 Reporting:

Results of required stack testing shall be submitted to the Executive Secretary within 30 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit

shall use the most recent test results as a basis fo r stating compliance status for this limitation.

Project OPP0107950007 Page 15 Ti tle V Operating Permit #4900018003II.B.2.b Condition:

The permittee shall use natural gas as the primary fuel in all of the dual fuel engines. Distillate fuel oil #1 or #2, or a combination of #1 and #2, may be used only during a 15-minute start-up and 15 minutes shutdown period; backup fuel during periods of natural g as curtailment; for maintenance firings; for break in firing; system electrical power outages; and as pilot fuel. Pilot fuel is used to ignite the gaseous portion of the fuel charge and shall be used according to the manufacture's specifi cations. Natural gas curtailment is defined as period when the natural gas provider/supplie r imposes a curtailment or interruption of service, and the curtailment is involuntary and beyond the c ontrol of the permittee. [Authority granted under R307-401-8(1)(a) (BACT); condition or iginated in DAQE-AN0795006-04].

II.B.2.b.1 Monitoring:

An operation log shall be used to record the e ngine running time during start-up, shut-down and normal operation. Documentation, such as test reports or manufacturers' specifications, shall be available to demonstrate that diesel usage meets the definition of pilot fuel.

II.B.2.b.2 Recordkeeping:

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

II.B.2.b.3 Reporting:

A semi-annual monitoring report shall be subm itted to the Executive S ecretary in accordance with Provision I.S.2 of this permit. An annual compliance certification shall be submitted to the Executive Secretary in accordance with Provision I.L of this permit.

II.B.2.c Condition:

Combined hours of operation shall be no greater than 48 hours per day for the four engines. [Authority granted under R307-401-8(1)(a )[BACT]; condition originated in DAQE-AN0795006-04].

II.B.2.c.1 Monitoring:

An hour meter installed on each unit shall be used to continuously monitor the hours of operation for the affected equipment.

II.B.2.c.2 Recordkeeping:

Operational hours of each engine shall be recorded daily.

Compliance with the limitation shall be determined daily by taking readings of each meter and summing the hours of operation for all engines.

Results shall be maintained in accordance w ith Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

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

Project OPP0107950007 Page 16 Ti tle V Operating Permit #4900018003II.B.2.d Condition:

Visible emissions shall be no greater than 10 percent opacity except for 15 minutes at start-up and shutdown. When straight diesel fuel is used, visible emissions shall be no greater than 20 percent opacity except for operation not exceeding 3 minutes in any hour. [Authority granted under R307-401-8(1)(a) [BACT] and R307-305-3(3); condition originated in DAQE-AN0795006-04].

II.B.2.d.1 Monitoring:

Opacity observations of emissions shall be conducted semi-annually in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.2.d.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance w ith the associated test method and Provision S.1 in Section I of this permit.

II.B.2.d.3 Reporting:

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

II.B.2.e Condition:

Sulfur content of the fuel oil combusted shall be no greater than 0.45 percent by weight. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0795006-04].

II.B.2.e.1 Monitoring:

Compliance with this limitation shall be determin ed either by testing each fuel delivery for the sulfur content or by inspection of the fuel sulfu r-content specifications provided by the vendor in purchase records. Sulfur content in either in stance shall be determin ed in accordance with ASTM-4294, or equivalent.

II.B.2.e.2 Recordkeeping:

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

II.B.2.e.3 Reporting:

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

II.B.3 Conditions on Natural Gas Fired Boilers.

II.B.3.a Condition:

Emissions of NO

x shall be no greater than 1.46 g/kW-hr and 155 ppmdv for each boiler. [Authority granted under Utah SIP IX.H.3.d and R307-401- 8(1)(a) [BACT]; condition originated in DAQEAN0795006-04].

II.B.3.a.1 Monitoring:

Stack testing shall be performed as specified here:

Project OPP0107950007 Page 17 Ti tle V Operating Permit #4900018003(a) Testing and Frequency. Boiler No. 4 shall be tested every 8,760 hours of operation and/or at least every five years based on date of last stack te st. Boiler No. 5 shall have an initial test within 180 days of it becoming active and then t esting shall follow the schedule thereafter.

(b) Notification. At least 30 days before the t est, 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.

(c) The emission sample point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1. In addition, Occupationa l Safety and Health Administration (OSHA) approved access shall be provided to the test location. (R307-165-2)

(d) Methods to be used:

(1) To determine stack volumetric flow rate - 40 CFR 60, Appendix A, Method 2.

(2) To test for NO

x emissions - 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or

7E.

(e) Calculations. To determine mass emission ra tes (g/kW-hr) the pollutant concentration as determined by the appropriate methods above sh all be multiplied by the volumetric flow rate, divided by the engine's power output during th e test and multiplied by any necessary conversion

factors.

(f) 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. (R307-165- 3).

II.B.3.a.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance w ith the associated test method and Provision S.1 in Section I of this permit.

II.B.3.a.3 Reporting:

Results of required stack testing shall be submitted to the Executive Secretary within 30 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit

shall use the most recent test results as a basis fo r stating compliance status for this limitation.

II.B.3.b Condition:

Visible emissions shall be no greater than 0 percen t opacity except for 15 minutes at start-up when theboilers are cold. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0795006-04].

II.B.3.b.1 Monitoring:

Opacity observations of emissions shall be conducted semi-annually in accordance with 40 CFR 60, Appendix A, Method 9.

Project OPP0107950007 Page 18 Ti tle V Operating Permit #4900018003II.B.3.b.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance w ith the associated test method and Provision S.1 in Section I of this permit.

II.B.3.b.3 Reporting:

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

II.B.4 Conditions on Emergency Generator.

II.B.4.a Condition:

Visible emissions shall be no greater than 20 percent opacity except for 15 minutes at start-up and shutdown.. [Authority granted under R307-401-8(1)(a ) [BACT] and R307-305-3(3); condition originated in DAQE-AN0795006-04].

II.B.4.a.1 Monitoring:

Opacity observations of emissions shall be c onducted every 50 hours of operation in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.4.a.2 Recordkeeping:

Results of all monitoring shall be recorded and maintained in accordance w ith the associated test method and Provision S.1 in Section I of this permit.

II.B.4.a.3 Reporting:

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

II.B.4.b Condition:

Emergency generators shall be used for electricity producing operation only during the periods when electric power from the public utilities is interrupted, or for regular maintenance of the generators. [Authority granted under R307- 401- 8(1)(a) (BACT) ; condition originated in DAQE-AN0795006-04].

II.B.4.b.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.4.b.2 Recordkeeping:

Records documenting generator usage shall be kept in a log and they shall show the date the generator was used, the duration in hours of the generator usage, and the reason for each

generator usage.

Project OPP0107950007 Page 19 Ti tle V Operating Permit #4900018003II.B.4.b.3 Reporting:

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

II.B.4.c Condition:

The permittee shall combust only #1 or #2 low sulf ur fuel oils. [Authority granted under R307-401- 8(1)(a) [BACT]; condition originated in DAQE-AN0795006-04].

II.B.4.c.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.4.c.2 Recordkeeping:

Fuel receipts shall be maintained to demonstrat e usage of the following lo wsulfur fuels having a sulfur content less than 0.5 percent by weight: Grade Low Sulfur No. 1 Diesel, Grade Low Sulfur No. 2 Diesel, Grade No. 1 Diesel, Grade No. 2 Diesel.

II.B.4.c.3 Reporting:

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

II.C Emissions Trading (R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios

. (R307-415-6a(9))

Not applicable to this source.

II.E Source-specific Definitions- There are no source specific definitions.



## SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.



## SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Title IV. This section is not applicable.

Project OPP0107950007 Page 20 Ti tle V Operating Permit #4900018003

## REVIEWER COMMENTS

This operating permit incorporates all applicable requirements contained in the following documents:

Incorporates Utah SIP IX.H.3.d dated July 6, 2005 Incorporates DAQE-AN0795006-04 dated December 10, 2004

1. Comment on an item originating in regarding Permitted Source regarding Permitted Source: Compliance Assu rance Monitoring (CAM )applicability has been evaluated. There are no CAM requirement s in this permit. [Last updated June 9, 2009]

2. Comment on an item originating in regarding Dual Fuel Internal Combustion Engines DAQE-032-97, Condition #11 regarding Dual Fuel Internal Combustion Engines (Unit Engines) [This is a historical comment]: Fuel Usage: The "dual fuel" engine is defined as a gaseous fueled engine using the combustion of a tiny spray of liquid diesel fuel to ignite the gas-air mixture in place of a spark plug. The tiny bit of liquid diesel fu el is called "pilot fuel" because it acts as a "pilot light" to ignite the gaseous portion of the fuel charge.

The traditional "dual fuel" engine uses about 95% gaseous fuel ignited by about 5% liquid pilot fuel at a full load normal operation, in terms of heat input. The amount of diesel fuel injected to an engine is fixed by rack setting while the natural gas is supplied based on the loading requirement. The pr oportion of fuel consumption during normal operation is a feature of an engine desi gn, therefore, documentation showing the engine's pilot fuel usage recommended fr om the manufacturer shall be able to demonstrate compliance with the pilot fuel condition. It does not make sense for the owner/operator to use more diesel fuel since th e purpose of the pilot fuel is to ignite the combustion and diesel is much more expensive th an the natural gas. [Last updated July 8, 2009]

3. Comment on an item originating in regarding Dual Fuel Internal Combustion Engines DAQE-032-97, Condition #8 regarding Dual Fuel Internal Combustion Engines (Unit Engines): Visible Emissions: There are several periods when the visible emissions from engines can exceed 10% opacity, i.e., during shut-down, maintenance firing, break in firing and natural gas curtailment when straight fuel oil is used. The operating permit application requests the exemption from 10% opacity limit for these periods. R307-305-1 requires that visible emissions from diesel engines manufactured after January 1, 1973 be no greater than 20% opacity, the engines used in the plant were manufactured after 1973, therefore, 20% opacity is required when straight diesel is used.

Note: The above is a historical comment on conditions of approval order DAQE-032-97. The document has since been replaced by DAQE-AN0795006-04 which explicitly requires:

¿¿10 percent opacity except for 15 minutes at start-up and shutdown. When straight diesel fuel is used, visible emissions shall be no greater than 20 percent opacity except for operation not exceeding 3 minutes in any hour.¿ [Last updated June 16, 2009]

Project OPP0107950007 Page 21 Ti tle V Operating Permit #49000180034. Comment on an item originating in regarding Dual Fuel Internal Combustion Engines regarding Dual Fuel Internal Combustion Engines (Unit Engines), requirements of the Utah SIP IX.H.1.b.D and DAQE-032-97 : Emission testing requirement (historical comment): : The current Approval Order requires stack testing frequence of every three years. This requirement is changed based on the varied operational schedule of the plant. The intern al combustion (I/C) engines and boilers in the power plant are back up generation units. In good water years, hydroelectric generation is abundant and IC engines and boilers are ready reserve generation. In the years of 1994 and 1995, each engine operate d less than 30 hours. In the year of 1995, only one boiler operated for 177 hours. During a three years period, each engine and Revised February 22, 2005 Page 17 Title V Operating Permit #4900018002 boiler may operate less than 100 hours and 600 hours, respectively. In a 12 month period ending June 30, 2001 Engine 1 operated 535 hours, 2 - 464 hours, 3 - 471 hours, 4 - 399 hours. It is not justifiable to requ ire a stack test every three years. However, the IC engines and boilers would operate more hours in a bad water year. Therefore, it is more reasonable to require emission testing after certain hours of operation. The recent stack tests conducted in 2000 indicated that the highest NO

x concentration and emission rate were 418 ppmdv and 5.94 g/kW -hr, respectively for the four engines tested (Limitions are 1,660 ppmdv and 10.4 g/kW-hr). For boiler No.4, NO

x concentration are emission rate were 99 ppmdv and 0.94 g/kW-hr, respectively (limitions are 155 ppmdv and 1.46 g/kW-hr). The test results showed a safe margin of compliance. Boiler No. 5 is not currently operational and there is no recent stack test data. Special initial testing requirement will be set for this boiler.

Note: The above is a historical comment on co nditions of the Utah SIP IX.H.1.b.D, and the approval order DAQE-032-97. Those two documents have since been replaced by Utah SIP IX.H.3.d, and DAQE-AN0795006-04 which re quire testing every 8,760 hours of operation, and at least every five years. [Last updated July 2, 2009]

Project OPP0107950007 Page 22 Ti tle V Operating Permit #4900018003