DAQ-2024-006984

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

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-258-24
Site ID 10238 (B5)

Terry Guthrie, Environmental Manager
PacifiCorp Huntington Plant
P.O. Box 680
Huntington, UT 84528

PacifiCorp
1407 West North Temple, Suite 210
Salt Lake City, UT 84116

Dear Mr. Guthrie:

Re: PacifiCorp (Huntington Plant) – Pretest Protocol for Carbon Monoxide (CO), Carbon Dioxide
(CO2), Flow, Nitrogen Oxides (NOx), and Sulfur Dioxide (SO2) Relative Accuracy Test – Emery
County

The Utah Division of Air Quality (DAQ) reviewed Huntington Plant’s pretest protocol dated February 20,
2024. The proposed test shall be performed under the following conditions:

Huntington Plant’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN Range
Unit 1
CO Thermo Fisher 48iQ-CAN -- 1000
CO2 Thermo Fisher 410iQ-CAN 133 20
NOx Thermo Fisher 42iQ-ACANN 132 500
SO2 Thermo Fisher 43iQ-CAN 131 800
Unit 2
CO Thermo Fisher 48iQ-CAN -- 1000
CO2 Thermo Fisher 410iQ-CAN 234 20
NOx Thermo Fisher 42iQ-ACANN 232 500
SO2 Thermo Fisher 43iQ-CAN 231 800

Montrose Air Quality Services, LLC, will conduct a relative accuracy/performance specification test on
Huntington Plant’s continuous monitoring system.

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DAQC-258-24
Page 2

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
April 9-10, 2024 Units 1
and 2
Low/High Load Flow, CO, CO2,
NOx, and SO2 RATA
Method 1, 2G/2H, 3A, 4, 6C, 7E,
10, and 19

• 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 2G - Determination of Stack Gas Velocity and Volumetric Flow Rate with
Two-Dimensional Probes as outlined in 40 CFR 60 Appendix A.

• Reference Method 2H - Determination of Stack Gas Velocity Taking into Account Velocity
Decay Near the Stack Wall as outlined in 40 CFR 60 Appendix A.

• 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 4 - Determination of Moisture Content in Stack Gases as outlined in 40
CFR 60 Appendix A shall be used to determine the stack gas moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide 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.

• 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.

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.

DAQC-258-24
Page 3

• 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 not 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.

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: Southeast Utah Health Department
Montrose Air Quality Services, LLC
* $ . # ( ) - — - @ D v A ? A C @ E w B C ˜
Rob Leishman Jr